Key takeaways
NMC introduces stricter prescribing standards
New rules aim to enhance patient safety in aesthetics.
Face-to-face consultations become mandatory
Remote prescribing is no longer permitted for injectables.
Practitioners must update compliance procedures quickly
Adapting policies now avoids regulatory and reputational risk.
The scalpel has fallen on remote prescribing for non-surgical cosmetic medicines. Prior to 1 June 2025, remote prescribing was permitted by the Nursing and Midwifery Council (“NMC”).
However, as of 1 June 2025, the NMC requires all nurses and midwife practitioners to prescribe prescription-only medicines to hold a face-to-face consultation prior to doing so.
The new guidance applies to prescriptions for any non-surgical cosmetic procedure.
What is defined as a non-surgical cosmetic procedure?
The Health and Care Act 2022 defines a ‘cosmetic procedure’ as a procedure, other than a surgical or dental procedure, that is or may be carried out for cosmetic purposes; and the reference to a procedure includes:
the injection of a substance;
the application of a substance that is capable of penetrating into or through the epidermis;
the insertion of needles into the skin;
the placing of threads under the skin;
the application of light, electricity, cold or heat.
The NMC has applied a broad definition which includes “elective interventions, procedures or treatments that are carried out with the primary purpose of changing or enhancing a person’s physical appearance for cosmetic reasons, rather than for medical necessity”. Accordingly, the NMC’s definition is not necessarily limited to the procedures that are listed in the Health and Care Act 2022 Act when prescribing is involved.
Further information can be accessed here.
The message is clear: if there is no patient in the room, there is no prescription on the table
Remote consultations are therefore expressly disallowed for initial prescriptions and any follow-ups or repeat prescribing. In addition, an appropriate clinical assessment of the intended recipient of the medicine must be undertaken and documented before patients can be prescribed any product used for any elective non-surgical cosmetic procedure.
This standard applies to all nurse and midwife practitioners working in the UK who are eligible to prescribe.
The NMC’s changes aim to enhance safety and practice across the cosmetic industry and underscores the importance of adequate holistic assessment; physical, mental, and social – through in-person contact. This was something that the Joint Council for Cosmetic Practitioners (JCCP) emphasised and recommended that remote prescribing of cosmetic injectables to be stopped.
What do these changes mean for the industry?
Commercial: Clinics and practitioners (particularly those using third-party prescribers or telehealth platforms) will need to re-assess their prescribing workflows, consent procedures, as well as employment and contractual arrangements with third parties. Pricing structures and T&Cs may need to be revisited given the likely increased costs associated with the need for prescribers attending clinics in person for face-to-face appointments.
Litigation: Remote prescribing has tended to be a liability wrinkle, contributing to more clinical negligence claims. It is hoped these new rules will help to reduce the number of claims in the industry for non-surgical procedures, particularly those relating to lack of informed consent, given the NMC’s requirement for a thorough face to face clinical assessment to be undertaken and documented before prescriptions can be issued.
Regulatory: Prescribers who issue remote prescriptions after 1 June 2025 risk fitness-to-practise investigations by the NMC, leading potentially to suspension or removal. The NMC has also made it a requirement that:
When a prescriber delegates the administration of a medicine as part of a non-surgical cosmetic procedure, they must ensure that the person they delegate to is suitably qualified and be satisfied that they are competent/proficient in administering the medicine. They must also ensure the procedure is carried out at suitable premises;
Prescribers remain responsible for the overall oversight and care of each individual (i.e patient/customer), including assessing outcomes and managing any adverse incidents or complications;
Any nursing or midwifery professional who chooses to provide elective non-surgical cosmetic procedures are expected to adhere to professional standards. Accordingly, they must ensure that they are appropriately trained, follow the NMC Code and Royal Pharmaceutical Society competency frameworks, manage consent, oversee medicine delegation, and maintain indemnity coverage.
The above are points that insurers will wish to consider carefully to ensure that policies are amended and risk is managed appropriately, given the increased regulatory oversight.
Hill Dickinson LLP as a full-service offering firm able to assist with all legal matters that may arise following these changes.
This article was co-authored by Shannon Hoey.
