Regulation and indemnity
Until now, regulation and indemnity in the aesthetics arena have remained grey areas, often left to the discretion of practitioners. This has enabled non-medically qualified individuals to carry out high-risk procedures with little accountability or safeguards. In September 2024, the death of a 33 year old mother of five following a "liquid Brazilian butt lift" procedure – which involved large amounts of dermal filler inserted into the buttocks - tragically highlighted the potentially deadly consequences of this regulatory vacuum. Her death being a stark reminder of the urgent need for reform to protect vulnerable individuals from avoidable harm.Last month the BBC reported that in the six weeks leading up to 18 July 2025 there were 38 cases of botulism poisoning recorded in England, after the suspected use of unlicensed Botox-like products. The absence of a clear regulatory framework stipulating who can administer these treatments continues to put patient safety at risk, with limited avenues for regulatory accountability and the concern about rogue practitioners ever increasing.
Despite calls for reform dating back at least over a decade and cross-party support and statutory powers granted under the Health and Care Act 2022, progress towards implementing a framework has been slow. As far back as 2013 Sir Bruce Keogh, then NHS England Medical Director, warned that dermal fillers were "a crisis waiting to happen."
The 'Plan for Change'
In July 2025, the Government issued a press release confirming its intention to introduce new licensing rules for aesthetic procedures, as part of its wider 'Plan for Change.'
This announcement marks a significant shift in policy, responding to years of concern over unregulated practice and public safety risks. The press release outlines a tiered licensing framework and other safeguards, signalling the start of a more defined and accountable approach to aesthetic regulation.
This 'Plan for Change' offers a structured response to these concerns, proposing a tiered licensing scheme: high-risk cosmetic procedures will be restricted to qualified healthcare professionals working from CQC-registered premises, while so-called "lower-risk" treatments like Botox and fillers will require local authority licensing. The plan also introduces age restrictions, enforcement powers, and a public consultation to shape future regulation.
Crucially, the proposals aim to provide the much needed consistency when it comes to accountability. Currently, healthcare professionals most commonly associated with providing aesthetic treatment are registered with the General Medical Council, General Dental Council and the Nursing & Midwifery Council – all of whom are held to strict professional standards and are required to have their own indemnity / insurance cover. However, in the absence of broader regulatory oversight, professional regulators are being tasked with investigating concerns out of necessity, even when the issues fall outside of their core remit. Meanwhile, unregulated practitioners are not held to the same standards and may operate without any safeguards in place, which can be extremely problematic if something goes wrong.
The proposed framework stipulates the fundamental shift that all aesthetic practitioners hold appropriate indemnity/insurance. In a parallel move to improve safety, the Nursing & Midwifery Council announced that from 1 June 2025, nurse and midwife prescribers are required to conduct face-to-face consultations before issuing prescriptions for non-surgical cosmetic procedures, such as Botox. This change prohibits remote prescribing via telephone, email, or online platforms and requires a comprehensive clinical assessment. The decision aligns with broader regulatory standards and aims to reduce risks associated with unregulated environments and insufficient practitioner oversight.
For those affected by the above, it is hoped that these proposals will improve standards and ensure regulatory oversight that is currently lacking for some. If implemented, the "Plan for Change" proposals could transform the cosmetic sector from a regulatory wasteland into a safer, more transparent industry.
Further consultation
The proposals will be subject to public consultation and Parliamentary scrutiny prior to implementation. The aim is to develop further proposals for a licencing regime aimed at lower-risk procedures, including standards for education, training, qualifications, infection control and insurance. This is likely to be a heavily debated and highly topical issue, especially given the previous consultation on the licensing of non-surgical cosmetic procedures launched in September 2023 received almost 12,000 responses.
If you are impacted by any of these issues and/or wish to discuss the provision or regulation of aesthetic procedures, please get in touch with our expert Healthcare Team.
Authors: Lee Biddle & Abbey Goldberg
