Scottish Government Recommendations on Aesthetics Licensing: What Practitioners Need to Know

The Scottish Government has recently proposed significant changes to the regulation and licensing of aesthetics practitioners.

These recommendations aim to enhance patient safety, establish clear standards, and ensure that all providers—whether medically qualified or not—operate within a robust regulatory framework. With the popularity of aesthetics treatments rising, this movement reflects the growing need for accountability and professionalism within the sector.

It is important to remember these are recommendations and do not apply legally until these have been debated in the Scottish government and moved into Scottish legislation – which could take many months.

This does not mean that the rest of the UK will follow in the same format/arrangements. This is the continuation of a lengthy process of development across the healthcare regulatory landscape which requires practitioners to remain calm, focused and reflective. This is however an important opportunity for reflection and preparation for responsible practitioners.

The Key Recommendations

The government’s report outlines a series of recommendations intended to improve the quality and safety of aesthetic practices.

Among the most notable measures are:

Mandatory Licensing: All practitioners offering aesthetics treatments, including botulinum toxin, dermal fillers, and skin rejuvenation, will need specific licenses to operate legally.
Regulated Training Standards: A minimum competency level will be introduced for aesthetics practitioners. This includes theoretical study, supervised practice, and examinations.
Facility Certification: Clinics offering aesthetics treatments must meet strict hygiene, equipment, and safety standards to gain certification.
Patient Consultation Protocols: Practitioners will need to follow standardized consultation procedures, ensuring informed consent and pre-treatment risk disclosures.

Groups Suggested for Regulation

The government has identified specific groups that fall under the scope of these recommendations:

Group 1: Should be carried out in a licensed premises by a licensed practitioner but may also be carried out in a clinic or other setting regulated by Healthcare Improvement Scotland (HIS).

Treatments:

Laser and Light Treatments including: Laser hair & tattoo removal and Laser treatments for acne scaring, sun damage and treatment of skin lesions, (but only non-ablative treatments)
Microneedling to a depth of 1.5mm
Photorejuvenation
Fruit peel or glycolic acid chemical peels that effect only the viable epidermis or outer layer of skin
Radiofrequency treatments
High frequency ultrasound (for non-intimate use)
Cryolipolysis
Electrocautery, also known as advanced electrolysis
Cryotherapy

Group 2: Would be restricted to a clinic or other setting regulated by HIS, under the supervision of, or delivered by a healthcare professional.

“Healthcare professional” meaning:

a medical practitioner (doctor)
a dental practitioner
a registered prescribing nurse
a registered prescribing pharmacist

Treatment: All non-surgical cosmetic procedures where substances are injected into or under the skin meet these criteria.

These would include:

Toxins such as botulinum toxin (Botox®)
Any prescription only medicine, including hayfever injections
Dermal fillers (as far as they are injected for the purpose of smoothing or providing limited increased volume e.g. to the face or neck, not where they are used for body augmentation or procedures on the genitals or anus)
Vitamin solutions

Group 3: Must only be undertaken only by an appropriate healthcare professional in a HIS registered setting.

These criteria will be met by procedures which require:

the use of any anaesthesia or sedation requiring a prescription-only medicine or any other product or technique likely to impair consciousness or undermine the ability of a pain response from the client (e.g., hypnosis, acupuncture)
the safe handling of biological products such as blood for reinjection into the client
intravenous procedures

The following procedures meet this definition:

Phenol Peels
Platelet Rich Plasma and Biotherapy
Injection Microsclerotherapy
Injection Lipolysis
Dermal Micro coring
Microneedling where the needles used penetrate the skin to a depth greater than 1.5mm
Use of dermal fillers to reshape or augment any part of the body, including any procedure where over 2ml of injectable substance is used in one site at one time e.g. Brazilian butt lifts, liquid breast augmentation etc.
Ablative laser treatment
Carboxytherapy
Cellulite subcision
Insertion of threads and cogs
Any procedure listed in Group 1 or 2 where an anaesthetic is used
Any introduction of substances (e.g. vitamin infusions) by IV
Any procedure above, except hair removal, where the procedure is carried out on the genitals, anus or on an area around the genitals or anus.

Action Plan for Aesthetics Practitioners

To align with these recommendations, practitioners must proactively prepare for the changes. Below is a simple action plan tailored to medical and non-medical aesthetics providers:

Step 1: Understand the Licensing Requirements

Research the licensing criteria outlined by the Scottish Government. Familiarize yourself with the types of certifications required for your practice and the treatments you offer.

Step 2: Enroll in Accredited Training

Ensure you have completed government-approved training programs that meet the new standards of competency. This applies to both medical professionals and beauticians. Consider refresher courses if needed.

Step 3: Prepare Your Clinic for Inspection

Audit your facility to meet hygiene, safety, and equipment standards. Make adjustments where necessary to secure certification.

Step 4: Revise Patient Consultation Protocols

Develop or update consultation procedures to ensure you are meeting the informed consent and risk disclosure requirements. Provide detailed post-treatment care instructions.

Step 5: Stay Updated

Monitor updates from the Scottish Government and relevant regulatory bodies. Consider joining professional associations for aesthetics practitioners to stay informed.

Step 6: Collaborate with Your Team

Train your staff to understand the new regulations and their roles in maintaining compliance. Ensure everyone is on the same page regarding safety and professionalism.

Conclusion

The Scottish Government’s recommendations mark a pivotal step in the aesthetics sector, aiming to safeguard patient welfare and standardize practice across the board. While these changes may seem daunting, they also provide an opportunity for practitioners to elevate their services and build greater trust with clients.

By following the action plan and engaging with the new licensing framework, aesthetics professionals—medical and non-medical alike—can navigate this transformation with confidence and clarity.

To explore how these changes could impact your business and develop tailored strategies for compliance, contact Rachel at GIVE Consulting. Visit www.give-consulting.co.uk or call 07437572601 to book a discussion session today.