Cosmetic procedures licensing England: what salons must do

Cosmetic procedures licensing in England is on its way, but not all at once. The government is consulting until 13 January 2027 on restricting a list of high-risk procedures to regulated healthcare professionals. A separate licensing scheme for lower-risk treatments such as Botox and lip filler has been promised, but it has no start date yet. Nothing is law today, so this is the time to check your treatment menu, training, insurance and records.

This week's headlines have mixed a few different things together, so here is what has actually happened, in order.

What has happened, and when?

• 6 August 2025: the Department of Health and Social Care (DHSC) said it would bring in a two-part system. The highest-risk procedures would be limited to qualified healthcare professionals working in providers registered with the Care Quality Commission (CQC). Botox, lip fillers and facial dermal fillers would go under a new local authority licensing system, with standards on safety, training and insurance.
• 21 October 2026: DHSC opened a consultation called Restrictions on the performance of high-risk cosmetic and wellbeing procedures in England. It closes at 11:59pm on 13 January 2027. The government says it wants Parliament to pass the regulations in spring 2027.
• 2 November 2026: DHSC updated the consultation page to clarify the under-18 offence. It now covers making, or allowing someone else to make, arrangements for a procedure. The draft regulations did not change.
• 4 November 2026: the Commons Science and Technology Committee published a report calling cosmetics regulation a "confusing mess". It wants mandatory national training and qualification standards for Botox. At the time of writing, I haven't seen a government response.

One thing to be clear about: the current consultation is not the Botox and lip filler licensing scheme. The government describes that scheme as separate and still to come.

What would the new restrictions actually cover?

According to the consultation document, these would be limited to specified regulated healthcare professionals, working in CQC-registered providers:

• deep chemical peels (deeper than the dermal-epidermal junction)
• dermal microcoring
• intravenous procedures of any substance for cosmetic or wellbeing purposes
• some lasers and intense pulsed light (IPL): lasers that remove skin layers (ablative), lasers introduced through a puncture or incision (such as Endolaser and Vaser), and lasers or IPL used on the eyelid or around the eye socket
• non-resorbable facial fillers
• any cosmetic procedure that includes a separately injected anaesthetic
• procedures using products from human blood or plasma, such as cosmetic PRP
• subcision, including cellulite subcision

Cosmetic surgery, including fillers injected anywhere other than the face (the "liquid BBL"), would be doctors only.

The professionals named are doctors, dentists, and independent prescribing nurses, midwives and pharmacists. Under-18s would be barred from these procedures, with exceptions for NHS care or treating a medical condition.

Does this affect laser hair removal?

The consultation document does not name laser hair removal, so it isn't clearly in scope. The laser and IPL categories listed are narrower: ablative lasers, lasers through a puncture or incision, and lasers or IPL on the eyelid or periorbital area.

That last one matters if you treat near the eyes. Don't assume your current service list is safe or unsafe. Read the wording and, if you are unsure, ask your insurer or trade body.

What about Botox and fillers?

Botox is already prescription-only, but, as the MPs pointed out, nothing currently regulates who can administer it. Since October 2021 it has been illegal in England to inject Botox or filler for cosmetic reasons into anyone under 18.

The new licensing scheme for Botox, lip filler and other lower-risk treatments is where training, insurance and premises standards are expected to be set. DHSC has said the detail will come through further consultation. No timeline has been published.

Who does this affect?

It affects any business in England that offers, or is thinking of offering, the treatments above. That includes beauty salons adding injectables, clinics, and independent therapists renting a room.

The consultation is a DHSC proposal for England. I haven't checked the position in Scotland, Wales, Northern Ireland or the Republic of Ireland, and the rules there may differ. If you trade there, check with your local regulator or trade body before assuming anything either way.

If you only do facials, waxing, nails, lashes, brows and similar, this isn't aimed at you. It is still worth knowing where your menu sits, because customers will ask.

How serious are the penalties?

The draft rules set out these penalties:

Offence	Penalty
Carrying on a regulated activity without CQC registration	A fine, up to 12 months in prison, or both. The fixed penalty is £4,000
Allowing someone who isn't an approved professional to perform a procedure	Unlimited fine on summary conviction. Fixed penalties of £4,000 for the provider and £2,000 for the registered manager
Allowing or arranging a procedure on someone under 18	Same fines and fixed penalties (the 2021 Act applies instead for Botox and filler, with an unlimited fine)

These are proposals until Parliament passes them. DHSC says a transition period will let providers apply for CQC registration, with timings set after the regulations pass.

What should you do now?

1. List every treatment you offer, and sort it

Write down your whole menu, including anything a freelancer in your building offers under your roof. Next to each treatment, mark it:

• Clearly on the proposed restricted list (for example, a deep peel or an IV drip)
• Possibly caught (IPL or laser near the eye area, anything with a separate anaesthetic injection)
• Likely to fall under the later licensing scheme (Botox, lip filler)
• Not affected

This gives you something to take to your insurer and your trade body, and it shows you where the risk really sits.

2. Check who is doing the work

For each restricted treatment, ask a simple question: is the person holding the syringe or device a doctor, dentist, or independent prescribing nurse, midwife or pharmacist? If not, that treatment is the one at risk under the proposals.

Also check that any prescriber involved is genuinely involved. Remote "sign-off" arrangements are the sort of thing the committee and the government are looking at.

3. Dig out your training certificates and insurance

Put them all in one folder. For each practitioner, you want:

• the course provider, level and date
• whether it is accredited
• any refresher training
• the insurance policy, and the treatments it names

Then ring your insurer and ask, in writing, whether each treatment you offer is covered, and whether they expect to change terms as the rules develop. Don't rely on a certificate or policy summary alone.

4. Look at your premises

Whatever happens with licensing, think about whether your treatment room would stand up to scrutiny: cleanable surfaces, a handwash basin, safe storage and disposal for sharps and clinical waste, and a clear place to keep any prescription-only medicines. If you rent a chair or room to a freelancer, you need to know what they do in it.

5. Tidy your client records and consent

Good records help in any inspection and with any insurance claim. For each injectable, laser or similar treatment, you want to be able to show:

• who the client is, with their date of birth, so you can show an under-18 wasn't treated
• their medical history and any contraindications
• a signed consent form, dated
• what was done, with product, batch number and notes

If you use paper, make sure it's stored safely. If you use software, check that you can pull up a client's full history quickly. BoneBook's client records and consent forms let clients sign consent on their phone before the appointment, and keep treatment notes and private before-and-after photos on the client file (Pro plan). It isn't an insurance or compliance tool, and the consent templates should be reviewed by a legal professional before you use them.

6. Have your say before 13 January 2027

The consultation asks which procedures and professional groups should be included, and what the effect would be on you or your business. If you run a small salon, your answer is useful, because the committee itself warned that regulation shouldn't reduce access for female-led businesses. You can respond online through the consultation page, or email cosmetic.consultation@dhsc.gov.uk with questions.

7. Don't spend big on something that may not be allowed

If you were about to buy an IPL machine, book a pricey injectables course or hire a practitioner just for these treatments, pause. Check the treatment against the consultation list first, and talk to your insurer. A treatment that is perfectly legal today could need a CQC-registered provider next year.

What if you're a hair, nail or lash business?

Most of this won't touch you directly. But clients are reading the same news, and they will start asking what qualifications you hold. It's a good moment to put your training and insurance details on your booking page and social profiles. Lash and brow studios doing anything near the eye should read the eyelid wording above carefully; lash and brow studios that stick to extensions, lifts and tints are a different matter from those using lasers or IPL.

If you offer laser hair removal, this page on laser hair removal shows how a booking setup can handle machine time and consent. That's the practical side, though; the legal question is for your insurer and trade body.

Where is the best place to follow this?

Use the official sources rather than social media summaries. The consultation page and draft regulations are on GOV.UK, and the Committee report is on the Parliament website. Both are linked below. Set yourself a reminder for the week the consultation closes, and another for when the government publishes its response.

Your plan for this month

1. Write your full treatment list and mark each one against the consultation.
2. Gather training certificates and insurance schedules in one place.
3. Email your insurer to ask whether each treatment is covered, and keep the reply.
4. Check your consent forms and client records are complete and easy to find.
5. Read the consultation document and respond before 13 January 2027.
6. Hold off on new equipment or courses for restricted treatments until you've checked them.

If you want to see how a booking system could help with consent and records, you can look at the Beauty salons page or the pricing. But the first job is the boring one: know exactly what you offer, and who does it.