England's licensing scheme for non-surgical cosmetic procedures, explained

Here is the short version: there is no licence to apply for yet. As of June 2026, no practitioner or premises in England holds a licence under the proposed scheme, because the regulations that would create it have not been laid before Parliament. The legal power exists, the design has been consulted on, and the government has confirmed it intends to proceed, but the scheme itself is not in force. Anyone telling you that you must buy a licence today, or selling a course that “guarantees” you one, is ahead of the law.

Checked against official sources at the date shown above. Regulation in this sector is moving; if you spot something out of date, email [email protected] and we will correct it.

Where the scheme came from

The legal foundation is section 180 of the Health and Care Act 2022, which came into force on 1 July 2022. It does not create a licensing scheme by itself. It gives the Secretary of State for Health and Social Care the power to make regulations requiring practitioners and premises in England to be licensed before specified non-surgical cosmetic procedures can be carried out. Until those regulations are made, nothing changes on the ground.

The push for the power followed years of reports, most prominently the 2013 Keogh review, warning that someone could pick up a needle and inject dermal filler with no training, no insurance and no oversight. That remains broadly true today for procedures outside CQC scope, which is exactly the gap the scheme is meant to close.

The 2023 consultation and the traffic-light proposal

The Department of Health and Social Care ran a public consultation on the design of the scheme from 2 September to 28 October 2023. The central proposal was a three-tier, risk-based classification of procedures, usually described as a traffic-light system:

• Green: the lowest-risk procedures, which any practitioner could perform once licensed and meeting agreed standards.
• Amber: medium-risk procedures. Non-healthcare practitioners could perform these under the oversight of a named, regulated healthcare professional; suitably qualified healthcare professionals could perform them independently.
• Red: the highest-risk procedures, restricted to suitably qualified, regulated healthcare professionals and brought within Care Quality Commission regulation, meaning they could only be delivered by CQC-registered providers.

Local authorities would administer the licensing of green and amber procedures, in a similar way to how they already license tattooing and piercing premises. Red procedures would sit with the CQC. If you are unsure where the CQC boundary falls today, before any of this takes effect, our guide to CQC registration for aesthetics clinics covers the current position.

What the government decided in August 2025

The government published its response to the consultation on 7 August 2025. The key confirmations:

• The tiered green, amber and red approach will go ahead.
• Local authorities will run the licensing scheme for green and amber procedures; red procedures will come under CQC regulation.
• Procedures will be restricted to people aged 18 and over, unless approved by a doctor and carried out by a healthcare professional, consistent with the existing law on botulinum toxin and fillers for under-18s.
• The highest-risk procedures come first. The government said it would prioritise restricting procedures aimed at augmenting the breast, buttocks and genitals with dermal fillers, a decision made in the shadow of the death of Alice Webb after a so-called liquid Brazilian butt lift in September 2024.

The response also promised a further public consultation on the detail of those high-risk restrictions, expected in spring 2026. At the time of writing we could not find that follow-up consultation published on the original GOV.UK page. Check GOV.UK directly for the current position before relying on any secondary commentary.

What is still unconfirmed

It is worth being precise about what does not yet exist, because a great deal of confident-sounding material online fills the gaps with guesswork:

• The procedure lists. No final list of which procedures sit in green, amber or red has been published. Commentary assigning specific treatments to specific tiers is informed speculation.
• Training and qualification standards. The government has said education and training requirements need further work. No qualification has been confirmed as the entry ticket to a licence.
• Fees. No licence fee has been set. Ignore any figure you see quoted.
• Dates. The government has not confirmed when regulations will be laid or when the scheme will open. The “2026” attached to this scheme refers to expected consultation activity, not a confirmed start date.

England only

Section 180 powers, as the government is using them, apply to England. Scotland is pursuing its own legislation to regulate non-surgical procedures through the Scottish Parliament. Wales already licenses certain “special procedures” such as tattooing, piercing, acupuncture and electrolysis under the Public Health (Wales) Act 2017, though that regime was not designed around injectables. Northern Ireland has no equivalent scheme confirmed. If you practise across borders, you will eventually be dealing with different rules in each nation.

What you can usefully do now

Waiting for the scheme is not the same as doing nothing. Every signal from the consultation and the government response points to the same fundamentals, and they are the things a licensing inspector, an insurer or a solicitor would ask about anyway:

• Records. Keep a complete, contemporaneous treatment record for every patient: medical history, batch numbers, doses, injection sites, photographs and aftercare given. Our treatment record template shows the fields that matter. AesthetiClinic structures treatment records, consent versions and audit trails for exactly this.
• Consent. Use written, procedure-specific consent that documents risks, alternatives and the cooling-off conversation. A signature on a generic form is weak evidence; see our botulinum toxin consent form for what good looks like.
• Training evidence. Gather certificates, CPD logs and evidence of supervised practice into one place. Whatever the final standards say, you will need to prove what you trained in and when.
• Premises standards. Clean, clinical-grade treatment areas, sharps and clinical waste contracts, and infection control protocols are near-certain to feature in any local authority licensing regime, because they already do in adjacent schemes.
• Insurance. Confirm your cover actually matches every procedure you offer. Our aesthetics insurance guide explains the cover types and the questions to ask.

If you are setting up from scratch, the licensing scheme is only one line on a longer list; our guide on how to open an aesthetics clinic covers the rest, and the guides index collects everything in this series.

The honest summary: the direction of travel is settled, the detail is not. Build your records, consent and training evidence now, and the eventual application will be an administrative exercise rather than a scramble.