Key takeaways
High-risk cosmetic and wellbeing procedures could be restricted
Cosmetic surgery to be reserved to specified regulated healthcare professionals.
Providers offering in-scope procedures may be required to register with the CQC
Parts of the aesthetics and wellbeing sector brought within formal regulatory regime.
Organisations should consider the potential impact on governance and service offerings
Compliance obligations and risk exposure set to increase.
Background
The cosmetic and aesthetics sector in England is currently subject to a limited regulatory framework, with few restrictions on who can perform cosmetic procedures. In response to concerns about patient safety and serious harm arising from inadequately trained practitioners, the Department of Health and Social Care (DHSC) has launched a consultation on proposals to introduce a new regulatory regime for high-risk cosmetic and wellbeing procedures.
The proposals build on the government's 2023 consultation, which introduced a three-tier risk framework categorising procedures as green, amber or red according to their complexity, invasiveness and risk of complications. Following its 2025 commitment to introduce legislation targeting the highest-risk (’red’) procedures, the government is now consulting on measures that would restrict certain treatments to regulated healthcare professionals and bring providers within the scope of Care Quality Commission (CQC) regulation.
Key proposals
Restriction to regulated healthcare professionals
Certain high-risk cosmetic and wellbeing procedures would only be permitted where carried out by specified regulated healthcare professionals, including doctors, dentists, independent prescribing nurses, independent prescribing midwives and independent prescribing pharmacists. Cosmetic surgery would be restricted to doctors only.
Procedures in scope
The proposals cover a range of higher-risk treatments, including cosmetic surgery, deep chemical peels, dermal micro-coring, intravenous procedures and infusions, certain high-risk laser and intense pulsed light (IPL) treatments, non-resorbable facial fillers, subcision, platelet-rich plasma (PRP) therapy and procedures involving separate anaesthetic injections.
Mandatory CQC registration
Providers offering these procedures would be required to register with the CQC, making them subject to CQC oversight and enforcement powers.
Age restrictions
The government proposes restricting these procedures to individuals aged 18 and over, subject to limited exceptions where treatment is provided by the NHS or for a medical condition.
Enforcement
The consultation proposes criminal sanctions for non-compliance. Providers carrying out regulated procedures without the required CQC registration could face unlimited fines, imprisonment for up to 12 months, or both.
Providers permitting unqualified practitioners to perform regulated procedures may also face unlimited fines.
What does this mean in practice?
If implemented, the reforms would represent a significant step towards greater regulation of the aesthetics and wellbeing sectors.
For providers, the proposals may require a review of:
whether their practitioners fall within the categories of professionals permitted to perform the procedures
whether CQC registration will be required
governance, training and clinical oversight arrangements
the viability of services currently delivered by non-regulated practitioners.
Insurers may wish to consider:
how the proposed restrictions and practitioner eligibility requirements could affect the risk profile, insurability and claims exposure of insured providers
whether existing policy wordings adequately address procedures that become subject to additional regulation or eligibility requirements
the impact of mandatory CQC registration on risk assessment processes.
Next steps
The consultation closes on 13 January 2027. Subject to the outcome and parliamentary approval, the government intends to introduce legislation in spring 2027, with a transition period to allow affected providers to obtain CQC registration before the new restrictions take effect.
We will be monitoring developments closely and will provide updates as the consultation progresses and the Government's proposals develop. Providers and insurers operating in the cosmetic and wellbeing sectors may wish to assess the potential impact of the reforms at an early stage, particularly where services involve higher-risk procedures or are delivered by non-regulated practitioners.
You can read the government’s full consultation document here.
Find out more about our Healthcare Regulation expertise or contact us today to discuss how we can support you.
This article was co-authored by Trainee Solicitor, Victoria Stuart.
