Regulation and Licensing of Non-Surgical Cosmetic Procedures

The beauty industry in Scotland continues to evolve and with it comes the need for tighter regulations. The Scottish Government issued a consultation paper (which closed on 14^th February 2025) on the proposed licensing rules for non-surgical cosmetic procedures (NSCPs) such as Botox, dermal fillers and laser treatments to reduce potential harm to consumers from riskier procedures. Current gaps in regulations are likely to be closed to prevent the performance of procedures by practitioners without formal training or qualifications.

The Scottish government proposes that certain procedures should take place in a licensed premises by a licensed practitioner. However, this will not affect procedures which take place in a Healthcare Improvement Scotland (HIS) regulated setting, this will continue to be regulated through existing HIS processes. This blog breaks down the upcoming changes and what your business needs to do to stay compliant.

Why is the Scottish Government considering regulation?

Non-surgical treatments are popular, but they come with risks – especially when performed in unsafe environments or by underqualified professionals. The Scottish Government’s new licensing system aims to boost public safety and raise professional standards across the industry. Similar regulation already applies to skin piercing and tattooing in Scotland, and it is expected that new regulations will mirror the requirements of the Civic Government (Scotland) Act 1982 (Licensing of Skin Piercing and Tattooing) Order 2006.

Key changes

The main change that the Scottish Government’s consultation paper proposes is that private, NSCPs should only take place in certain circumstances. The paper introduces a tiered system of procedures, with only procedures falling into Tier 1 being permitted to be carried out in a non-HIS regulated premises. Premises wishing to carry out procedures that are categorised in Tier 1, will be required to have a premises licence and individual licence. Any procedure falling into any other category, must be carried out either by an appropriate healthcare professional or under their supervision.

How will this affect your business?

The introduction of new licensing requirements for NSCPs in Scotland marks a significant step forward in ensuring the safety and professionalism of this fast-growing industry. It is only a matter of time before these procedures become subject to licensing law, and there will therefore be various requirements that an individual and premise must adhere to. Failing to adhere to the regulations may result in repercussions, such as financial penalties, business closure and even criminal offences.

While the changes may initially seem overwhelming, taking proactive steps to comply by ensuring that you are aware of the commencement date of any new legislation and carrying out your business under any best practice guidelines will not only help you avoid repercussions but also enhance the trust and confidence your clients place in your business. If you have any questions or concerns about the new licensing requirements, the Licensing team at Gilson Gray is here to help. Contact us today to learn more about how we can support your business in navigating the upcoming changes.

Co-written by Karen Gatherum, Senior Solicitor and Rosemary McCann, Trainee Solicitor.

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