Aesthetics Clinics to Require Licences for Botox and Fillers: A New Era of Cosmetic Regulation

The current regulatory framework on non-surgical cosmetic procedures places few restrictions on who can perform the procedures. This has caused issues surrounding patient safety, consent and the competency of those providing the procedures.  

However, the UK government has recently announced a major regulatory reform for the non-surgical aesthetics sector. Clinics offering Botox and dermal fillers will be required to obtain a licence.  

This change is part of a broader crackdown designed to raise safety standards, increase accountability and provide clearer protections for patients seeking injectable cosmetic treatments. 

What the new regime will cover: 

Key elements of the licensing scheme include: 

• Practitioners will need to be licensees to perform specific non-surgical cosmetic procedures.  
• The premises will also have to have mandatory licences for delivering injectable treatments. 
• Practitioners will have to meet specific minimum qualifications and training requirements. 
• Practitioners will need to operate from premises which meet the necessary standards of hygiene, infection control and cleanliness 

The new licensing framework will apply to providers of injectable treatments including Botox and dermal fillers.  

How will the new framework work? 

The framework will categorise procedures according to the risks associated with them.  

• Green: these procedures can be carried out with a licence.  
• Amber: these will require non-healthcare professionals to be licensed and have relevant oversight by a regulated healthcare professional (who has gained an accredited qualification to prescribe, administer and supervise aesthetic procedures). Qualified and regulated healthcare professionals are eligible to perform these procedures without oversight where they meet agreed standards. 
• Red: which include high risk procedures – will be regulated by the Care Quality Commission (CQC). This will mean that they can only be carried out by qualified and regulated healthcare professionals.  

Legal implications for providers 

Clinics and practitioners should prepare now to manage the legal consequences of the new regime. It will be important for providers to avoid non-compliance.  

Although there was widespread support for these measures after a public consultation in 2023, further consultation is needed for the Government to figure out exactly how this will work in practice.  

The BBC have earlier this week, 30th of September 2025, published an article which highlights the extent of the issues caused by a sector which is so loosely regulated.  

However, Associate Solicitor, Martha Odysseos, who works within Olliers’ Regulatory department points out: 

“There are already a lot of regulated professionals working within the sector, sometimes to supplement their main source of income and it is they, amongst others who are already flouting basic safety and hygiene expectations and putting patients at risk. It is therefore impossible to say whether the proposed regulatory reforms will have a positive impact on the industry or result in more backstreet clinics.” 

How Olliers can help 

If you are facing a regulatory investigation or the possibility of an investigation and wish to speak to one of our team please contact us at the earliest possible opportunity for a confidential discussion. We are able to represent you wherever you are based across England and Wales and have extensive experience of working with those who are regulated by the NMC, GMC and CQC.