Proposed high-risk cosmetic procedure regulations in England: what clinics need to know
The government has opened a consultation on proposed restrictions for high-risk cosmetic and wellbeing procedures in England.
If introduced, the rules would restrict cosmetic surgery, PRP, deep chemical peels, subcision and certain other procedures to specified healthcare professionals. Providers offering these services would also need the appropriate Care Quality Commission (CQC) registration.
These are proposals, not rules currently in force. The consultation applies only to England and closes at 11:59pm on 13 January 2027. Final regulations would still require government consideration, parliamentary scrutiny and a transition period before taking effect.
Clinics can read the official GOV.UK consultation and the more detailed DHSC consultation document.
Consultation summary
- Cosmetic surgery would be restricted to doctors.
- Body filler outside the face, including liquid BBLs, would be treated as cosmetic surgery.
- Listed high-risk non-surgical procedures could be performed only by doctors, dentists and independent prescribing nurses, midwives or pharmacists.
- Providers would need the appropriate CQC registration.
- Cosmetic and wellbeing procedures within scope would generally be prohibited for under-18s.
- The final procedure list, CQC guidance, fees, transition arrangements and commencement date remain undecided.
What is the government proposing?
The Department of Health and Social Care (DHSC) proposes adding two regulated activities to the CQC framework:
- Surgical procedures for cosmetic purposes, performed only by doctors registered with the General Medical Council.
- High-risk non-surgical cosmetic and wellbeing procedures, performed only by specified regulated healthcare professionals.
A provider would commit an offence if it allowed a covered procedure to be performed by someone outside the permitted professional groups. CQC would be responsible for investigating potential breaches and taking enforcement action.
The proposal is intended to close a gap in the current system. At present, the application of CQC regulation can depend partly on the activity, the person performing it and the way the service is provided. The proposed framework would place the highest-risk procedures into specifically defined regulated activities.
Which cosmetic procedures would be covered?
| Proposed category | Procedures included |
|---|---|
| Cosmetic surgery | Cosmetic surgical procedures generally, together with filler injected into any part of the body other than the face. This would include liquid BBL and other body-augmentation filler procedures. |
| Deep chemical peels | Peels penetrating deeper than the dermal–epidermal junction. The wording does not include every superficial peel. See the iGlowly chemical peels guide. |
| Dermal microcoring | Procedures in which a needle removes small cores of skin tissue. |
| Intravenous procedures | Introduction of any substance intravenously for a cosmetic or wellbeing purpose, including purposes such as improving energy, focus or stamina. |
| Certain laser and IPL procedures | Ablative lasers removing tissue beyond the epidermis; lasers introduced through a puncture or incision, including Endolaser and Vaser treatments; and laser or IPL used on the eyelid or within the periorbital rim. See the guides to laser skin resurfacing and CO₂ laser resurfacing. |
| Non-resorbable facial fillers | Subcutaneous, submucous or intradermal injection of a non-resorbable filler into facial tissue. |
| Separately injected anaesthetic | Any cosmetic procedure that includes administration of an anaesthetic as a separate injection. |
| Blood- or plasma-derived products | Procedures introducing a therapeutic product derived from human blood or plasma into the body, including cosmetic PRP. Read the iGlowly PRP guide. |
| Subcision | Procedures using a needle to cut fibrous bands connecting the skin to underlying tissue, including cellulite subcision. Read the iGlowly subcision guide. |
Some categories are defined by the technique rather than a brand or treatment name. Clinics should therefore review how a procedure is actually performed instead of relying only on the name used in their menu.
Older guides based on the 2023 green, amber and red lists may no longer reflect the latest proposal. Notably, the October 2026 draft expressly includes cosmetic PRP, subcision and procedures using a separately injected anaesthetic within the proposed high-risk regulated activity.
Who could perform these procedures?
Cosmetic surgery would be restricted to doctors.
The listed non-surgical procedures could be performed by:
- doctors;
- dentists;
- nurses with independent prescribing responsibilities;
- midwives with independent prescribing responsibilities; and
- pharmacists with independent prescribing responsibilities.
Being part of one of these groups would not automatically make someone competent to perform every procedure on the list.
DHSC does not propose specifying a separate qualification for every treatment in the legislation. Practitioners would remain responsible for working within their individual competence, professional standards, training and scope of practice.
For nurses, midwives and pharmacists, being registered would not be enough by itself: they would also need independent prescribing responsibilities.
Who could perform PRP in England?
If the proposals become law in their current form, cosmetic PRP involving the introduction of a therapeutic blood- or plasma-derived product could be performed only by:
- a doctor;
- a dentist;
- an independent prescribing nurse;
- an independent prescribing midwife; or
- an independent prescribing pharmacist.
The service provider would also need the appropriate CQC registration.
This is not the rule today. Clinics should not claim that non-healthcare practitioners are already legally prohibited from performing PRP under these proposed regulations.
What would CQC registration mean?
The provider offering a procedure within scope would need to be registered for the relevant new regulated activity.
Clinics would need to consider:
- which legal entity provides the treatment;
- which locations are covered by the registration;
- which regulated activities the provider is registered for;
- who performs each procedure; and
- whether staffing, governance and safety arrangements satisfy CQC requirements.
Existing CQC registration may not automatically cover the new activities. Some registered providers could need to change or extend their registration, while currently unregistered businesses may face more substantial operational changes.
CQC has not yet published the final registration guidance or fees. It is expected to consult on its implementation arrangements separately.
CQC registration is not the proposed aesthetics licence
This consultation concerns CQC regulation of the highest-risk procedures. It is separate from the government’s planned local-authority licensing scheme for lower-risk non-surgical treatments.
Botulinum toxin treatments and ordinary resorbable facial fillers are not automatically included in this high-risk list. They are expected to be addressed through the separate licensing programme, whose detailed requirements and implementation date remain outstanding.
What is proposed for under-18s?
The draft regulations would generally prohibit cosmetic surgery and the listed high-risk cosmetic or wellbeing procedures for people under 18.
The proposed restriction would not cover procedures:
- provided by the NHS; or
- performed by a healthcare professional to treat a medical condition.
Existing legislation already restricts cosmetic botulinum toxin and filler injections for under-18s in England. The draft regulations have been designed to avoid creating overlapping offences, although other proposed requirements—including CQC registration—could still apply to a covered filler procedure.
Clinics should not rewrite their policies as though the wider ban is already law. They can, however, review whether their existing age checks and consent pathways could accommodate broader restrictions in future.
What should clinics review now?
There is no need to jump the gun, but clinic owners can use the consultation period to get their house in order.
1. Do we offer anything that may be in scope?
Audit treatments by technique, treatment depth, product, administration route and anatomical area—not simply by brand name. Pay particular attention to PRP, subcision, IV infusions, deep peels, body filler, injectable anaesthesia and higher-risk laser procedures.
2. Who performs each procedure?
Record the practitioner’s professional regulator, registration status, prescribing qualification, training and scope of practice. Do not assume that every registered healthcare professional would qualify to provide every treatment.
3. Would our provider need CQC registration?
Identify the legal entity responsible for each service and the locations where it is delivered. Check whether existing CQC registration covers the relevant activity rather than relying on a general “CQC registered” statement.
4. What should change on our website?
For now, explain the development as a consultation rather than a new law. Review:
- treatment pages and terminology;
- practitioner names, credentials and registration details;
- CQC statements and rating displays;
- age and eligibility information;
- risks, suitability and recovery information;
- booking questions and consent pathways; and
- claims about who is legally allowed to provide a procedure.
Our guide to aesthetic clinic website rules in the UK covers the rules currently affecting advertising, prescription-only medicines, CQC information, patient data and online enquiries.
What penalties are proposed?
DHSC proposes two new offences:
- allowing a high-risk procedure to be performed by someone outside the approved professional groups; and
- allowing a covered procedure to be performed on someone under 18.
The proposed offences could attract an unlimited fine following conviction. The draft also provides for fixed penalties of £4,000 for service providers and £2,000 for registered managers as an alternative to prosecution.
These penalties would apply only if the proposals complete the legislative process and come into force.
What remains undecided?
The consultation asks whether the right procedures and professional groups have been included. Respondents can recommend that procedures or professions be added or removed.
Other details still to be settled include:
- the final wording and scope of the regulations;
- how borderline treatments will be classified;
- CQC registration guidance and fees;
- transitional arrangements for existing providers;
- when registration applications will open;
- when the restrictions will take effect; and
- the timing and content of the lower-risk licensing scheme.
Once the consultation closes, DHSC will analyse the responses and publish its final policy position. Final regulations must then be debated in Parliament. A transition period is expected so providers can apply for CQC registration, but there is no confirmed commencement date.
How can clinics respond?
Clinic owners, practitioners, professional organisations and members of the public can respond to the DHSC consultation online.
Responses must be submitted by 11:59pm on 13 January 2027.
For more practical guidance on clinic content, patient information and digital compliance, visit the iGlowly clinic website insights hub or browse the A–Z directory of aesthetic guides.
This article provides general information about a public consultation. It is not legal, regulatory or clinical advice. Clinics should review the final legislation and CQC guidance before making compliance decisions.