Ongoing delays in UK government plans to regulate non-surgical cosmetic procedures have triggered a spate of alarming headlines describing a ‘crisis waiting to happen’ in a ‘wild west’ where practitioners offering dermal fillers need ‘no knowledge, training or previous experience’.
Back in 2023 the UK Government launched a ‘Consultation into unregulated cosmetic procedures’. Citizens and businesses were ‘invited to share their views on how to make non-surgical cosmetic procedures – including Botox, laser hair removal and dermal fillers – safer as thousands complain of ‘botched’ procedures’, with views from people who have had these procedures to shape regulations.
The Government’s ‘first-ever consultation on treatments – also known as aesthetic procedures – will be used to shape a new licensing scheme for practitioners and cosmetic businesses which operate in England’. This could include age limits for those undergoing cosmetic procedures and restrictions on who can perform certain high-risk procedures, including those involving injecting fillers into intimate parts of the body (including the breasts and buttocks)’.
The government press release stated: ‘Any new licensing scheme would protect patients from potential harm associated with poorly performed procedures. This will provide reassurance to people that wherever they go to get their treatments, they will receive the same high standards of practice.’
Those promises were made two years ago – and the industry is still waiting for formal action.
‘IT’S NOW BELIEVED THERE COULD BE BETWEEN 100,000 AND 200,000 ‘AESTHETIC PRACTITIONERS’ OPERATING IN HIGH STREETS AND FROM HOMES AROUND THE COUNTRY.’
Tattooist posing as doctor
Meanwhile, 2025 started with an avalanche of disturbing headlines in the UK, after a BBC investigation revealed a former tattooist, who left a woman ‘looking like a gargoyle’ after giving her botched face fillers, had been posing as a doctor at his aesthetics clinic.
It prompted aesthetic-medicine specialist Dr Paul Charlson to warn ‘there will be more deaths and more disfigurement’ if plans to regulate non-surgical cosmetic procedures, such as Botox and fillers, continue to be delayed.
Dr Charlson, a member of the Joint Council for Cosmetic Practitioners, told the BBC that the government must ‘get on with’ enacting the regulatory legislation the industry has put forward.
Andrea, the 60-year-old woman who ‘paid the fake doctor thousands for fillers’ described how she covers her face when she leaves the house, because she worries people will laugh at her, two years after having the cosmetic procedures. She summed up: ‘Now I look like a gargoyle. I live a nightmare every single day.’
Andrea initially visited a cosmetics clinic in Hull for breast fillers, after reading on its website that it had won ‘Best Aesthetics Clinic in Yorkshire in 2022 at the England Business Awards’. She was seen by the former tattooist, who was referred to on the clinic’s social media pages as a ‘Dr’; however, the BBC discovered he was not medically trained – he was a tattooist for 33 years before opening his clinic in 2019 – and he subsequently confessed that he ‘naively and regretfully’ bought an honorary doctorate in business consultancy online and displayed the certificate in his clinic.
Two months after receiving breast fillers, Andrea says he then encouraged her to have facial fillers in her cheeks, chin and jaw; but her face started swelling and dark marks appeared and, from there, the supposedly ‘simple procedure’ turned into a catalogue of botched treatments.
Over the course of 10 months, Andrea had more than 30 appointments with the fake doctor, including for fillers, Botox and threads. Andrea sold jewellery and borrowed money to pay for the treatments, which added up to thousands of pounds, but says the reaction got worse. The BBC reported it ‘is aware of at least three other complaints made about (the tattooist) and the use of a fake qualification’.
Government health and safety officers visited his premises in 2024 after concerns were raised. They found ‘a number of issues requiring improvement, but no formal action was taken because the business was receptive to its requests’.
The BBC investigation concluded that ‘warnings about the aesthetics industry have been made for years’, and noted: ‘In 2013, a review of the regulation of cosmetics concluded dermal fillers were ‘a crisis waiting to happen’ because anyone can be a practitioner, ‘with no requirement for knowledge, training or previous experience’.
In 2022, the UK Health and Care Act gave the government powers to introduce licensing for non-surgical cosmetic procedures in England. This is yet to be enacted.
As a result, ‘It’s now believed there could be between 100,000 and 200,000 ‘aesthetic practitioners’ operating in high streets and from homes around the country’, reported London’s The Mirror newspaper.
UK ‘contrast’ to Europe and US
In contrast to Europe and North America, there is ‘nothing to stop individuals in the UK with non-medical backgrounds’ from carrying out Botox and dermal filler injections, as long as they’ve completed relevant training courses’, noted Scottish newspaper The Herald in its own investigation into the industry.
The courses can be completed ‘in as little as two weekends’. And although Botox can only be prescribed by doctors, dentists and prescribing nurses and pharmacists, ‘it’s clear non- healthcare practitioners are buying cheap Botox online’ or getting prescriptions for themselves and then ‘injecting it into customers’.
Dr Alastair Lowrie, an NHS plastic surgeon, told The Herald, ‘to get treatment by regulated [practitioners]’, you ‘pay a lot of money’, so ‘there’s an increased incentive’ to seek out ‘unregulated practitioners doing it on the cheap’.
In 2024, after Alice Webb, 33, became the first person in the UK to die after a non-surgical cosmetic procedure (she’d had a liquid Brazilian butt lift) her partner joined forces with the campaign group Save Face and the British Association of Aesthetic Plastic Surgeons to demand action to ‘stop devastating cosmetic procedures in Britain’, reported The Mirror.
They’re demanding liposuction, surgical facelifts and surgical eye lifts should only be carried out by properly trained surgeons on the General Medical Council specialist register; they also want ‘all operations and high-risk procedures to be surgically safe, and carried out in clinics and hospitals inspected by the Care Quality Commission’.
And they want it to ‘become a legal requirement for beauty clinics who offer non-surgical interventions to have malpractice insurance’.
A Department of Health and Social Care spokesperson told the BBC it was ‘unacceptable’ that ‘inadequately trained operators in the cosmetic sector’ were putting people’s lives at risk, and said the government was ‘urgently exploring options for further regulation’.
Speaking to The Mirror, Health Secretary Wes Streeting admitted he was ‘worried about the wild west in cosmetic surgery,’ and the government has ‘a lot more to do on this’.
Promises, promises
Back in 2023, the UK Government’s announcement of its ‘Consultation into unregulated cosmetic procedures’ emphasised that the beauty industry ‘is hugely important for the UK economy and is largely made up of female-owned, small- and medium-sized businesses, with the non-surgical cosmetic industry previously being valued at an estimated £3.6 billion’.
The much-hyped new regulations ‘will support businesses by introducing high standards across the sector, raising the reputation and professionalism of the industry’.
Minister for the Women’s Health Strategy Maria Caulfield said at the time: ‘Whether it’s Botox, dermal fillers or even a chemical peel, we have heard too many stories of people who’ve had bad experiences from getting a cosmetic procedure from someone who is inexperienced or underqualified.
‘There’s no doubt that the popularity of cosmetic procedures is increasing, so it’s our role to ensure consistent standards for consumers and a level playing field for businesses and practitioners. We want to make sure we get this right for everyone, which is why we want to hear your opinions and experiences through our new consultation.’
An estimated 900,000 Botox injections are carried out in the UK each year. Save Face – a government-approved register of accredited practitioners – received almost 3,000 complaints in 2022, with over two-thirds of those relating to dermal fillers and almost a quarter relating to Botox.
Save Face director Ashton Collins said: ‘Whilst we appreciate that we are still at very early stages of any potential licensing scheme being implemented in England, we are delighted to have been invited by the government to contribute our thoughts and ideas ahead of the release of this public consultation.
‘Being involved in the process has enabled Save Face to actively contribute to roundtable discussions with ministers, policy makers and key stakeholders.
‘As the largest and longest established Professional Standards Authority accredited register, we are able to provide a unique level of insight based on 10 years gathering data from practitioner and clinic audits as well as patient reported complaints, adverse reactions and complications.
‘This will enable us to help develop a fit-for-purpose scheme that has public safety as its primary focus. We look forward to continuing to work closely with the government and key stakeholders during the next stages of the process.’
Among other hopeful stakeholders, Professor David Sines CBE, Chair of the Joint Council for Cosmetic Practitioners, said: ‘I warmly welcome the government’s decision to consult on this new, proposed licensing scheme. It will help ensure people who undergo non-surgical cosmetic procedures receive treatment from practitioners who are properly trained and qualified, have the necessary insurance cover and operate from premises that are safe and hygienic.
‘I would urge everybody to seize the opportunity provided by this consultation and support the move towards sensible and proportionate regulation in this important sector.’
And Victoria Brownlie, Chief Policy Officer at the British Beauty Council added: ‘Since its inception, the British Beauty Council has been working to raise the reputation of the beauty industry and we see greater checks and balances around aesthetic procedures as a key part of this. Having worked with the government to achieve the ban on injectables for under 18s in 2021, we are delighted they have continued this momentum with the commitment to introduce a licensing scheme covering a raft of higher-risk aesthetic treatments, many of which are largely unregulated.
‘Those seeking treatments deserve to do so with confidence that their practitioner is properly qualified in the service they’re offering, to the appropriate level of government-approved educational standards. The Council has worked closely with the Department of Health and Social Care to get to this point, so we look forward to seeing the outcome of the consultation and helping to shape the regulatory framework as it progresses.’
The Consultation was announced to ‘run for 8 weeks and will close on Saturday 28 October 2023’. Under the proposed resultant scheme, which will be operated by local authorities in England, ‘practitioners will need to be licensed to perform specific procedures, and the premises from which they operate will also need to be licensed’.
The government noted it ‘has already made it illegal for under 18s to access Botox and filler treatments for cosmetic purposes and banned TV and social media adverts targeting under 18s with cosmetic procedures.
‘Anyone considering a cosmetic procedure should reflect fully on the possible impact of the procedure on both their physical and mental health and, if they decide to go ahead, take the time to find a reputable, insured and qualified practitioner.’
‘WHETHER IT’S BOTOX, FILLERS OR A CHEMICAL PEEL, WE’VE HEARD TOO MANY STORIES OF BAD EXPERIENCES FROM GETTING A PROCEDURE FROM SOMEONE WHO IS INEXPERIENCED OR UNDERQUALIFIED.’
68% of injections not by doctors
At the same time the UK Government was announcing its urgent ‘patient and business Consultation’, a study published in the Journal of Plastic, Reconstructive & Aesthetic Surgery revealed 68% of UK cosmetic practitioners who are administering injections such as Botox and dermal fillers are not medical doctors.
The survey by researchers from University College London identified 1,224 independent clinics and 3,667 practitioners who were delivering cosmetic injections: only 32 percent were doctors, 13 percent were nurses, 24 percent were dentists and 8 percent were dental nurses; 23 percent were other professions.
Dr David Zargaran (UCL Surgery & Interventional Science), an author of the study said: ‘There are well-documented, yet to date unaddressed challenges in the UK cosmetic injectables market. Without knowledge of the professional backgrounds of practitioners, we cannot adequately regulate the industry.
‘Our research highlights that the majority of practitioners are not doctors and include other healthcare professionals, as well as non-healthcare professionals such as beauticians. The range of backgrounds opens a broader question relating to competence and consent. One of the key challenges facing the government’s licensing scheme is to ensure that practitioners granted a licence possess the skills and experience required to safely administer their treatment to minimise risks to patients.
‘It is important for patients to be able to feel comfortable and confident that the person administering their treatment is competent in the procedure as a fundamental foundation of informed consent. This research provides a unique insight into the sector to help inform regulators and patients, and work towards a safer and more transparent cosmetic injectables industry in the UK.’
A second study from the same authors, also published in 2023, found 69 percent of respondents had experienced ‘long-lasting adverse effects, such as pain, anxiety and headaches’. Professor Julie Davies (UCL School Global Business School for Health), a co- author of the study commented: ‘The UK cosmetic injectables industry has expanded rapidly in recent years. This has happened largely without scrutiny or oversight.
‘Our findings should be a wake- up call for legislators to implement effective regulation and professional standards to safeguard patients from complications. Although the risks associated with injections are often mild and temporary, the physical complications can be permanent and debilitating. There are also serious psychological, emotional and financial consequences for patients when procedures go wrong.’
Professor Ash Mosahebi (UCL Surgery & Interventional Science), senior author of the study added: ‘Botulinum toxin has revolutionised aesthetic as well as medical treatment options. However, there is a lack of knowledge around its potential complications, partly due to lack of reporting and regulations around its administration.
‘IT IS IMPORTANT FOR PATIENTS TO BE ABLE TO FEEL CONFIDENT THAT THE PERSON ADMINISTERING THEIR TREATMENT IS COMPETENT IN THE PROCEDURE AS A FUNDAMENTAL FOUNDATION OF INFORMED CONSENT.’
Fake Botox from China was beef gelatine
A major 2024 investigation of the UK injectables industry by The Herald in Scotland reported ‘campaigners and healthcare professionals have warned lives are being put at risk by a growing number of unregulated practitioners performing everything from Botox injections to ‘butt lift’ procedures without any medical training’.
The investigation ‘has heard of an alarming string of injuries and near misses, including 15 women hospitalised with life-threatening allergic reactions after being injected with counterfeit Botox from China which turned out to be beef gelatine’.
There were also cases of ‘surgical procedures being carried out in hair salons, high-risk liposuction procedures performed by people straight out of retail jobs, and patients requiring emergency care from plastic surgeons due to ‘raging infections’ after undergoing potentially dangerous thread-lift facials on the high street’.
Dr Nestor Demosthenous, a trustee of the British College of Aesthetic Medicine and specialist in non-surgical facial rejuvenation, commented: ‘It is a UK-wide issue but in Scotland we are the laughing stock of Europe.’
He questioned why Scotland had not tightened regulations nor even followed England’s example by banning under-18s from getting Botox and fillers and said: ‘If I were to see a patient outside of a regulated clinic and treated them in premises not registered with the health board, I – as a doctor – would be taken to the procurator fiscal. But if a plumber were to inject a 16-year-old girl with filler in the back of a van, [it is] completely legal. It is absolutely ridiculous.’
As a prescription drug, Botox ‘should not be available to anyone without prescriber credentials (doctors, dentists, nurse prescribers or prescribing pharmacists’, noted The Herald. ‘In many cases, non-healthcare practitioners are buying cheap [botulinum toxin] online or obtaining supplies from online consultations with medics which they are then injecting into customers.’
Campaign group Save Face director Ashton Collins said: ‘You will be able to go onto Instagram today and find dozens of clinics in Scotland which will give you Botox on the day. They’re not healthcare professionals, you won’t see anybody other than them, and that’s going on all throughout the UK.
‘That’s our frustration because there really should be no clinics in Scotland that offer Botox that aren’t operating from a Healthcare Improvement Scotland-regulated clinic, because if they offer Botox they need a prescriber and that clinic or that salon should therefore be a registered HIS premises.
‘HIS knows this, Scottish Government knows this, but they acknowledge that HIS has not got the resources or the teeth to be able to enforce those rules properly, and they don’t know how many people are not registered with them that should be.
‘We raised grave concerns about it in 2016. We said, ‘you are starting with regulating the regulated’ when it’s the non-healthcare professionals who pose the greatest risk to the public. Eight years on, that landscape hasn’t changed.’
Collins said that over the past 10 years, Save Face has handled around 15,000 complaints from the public, of which 85 percent related to non-healthcare professionals.
She said they tended to operate ‘like ghosts’, with mobile practices visiting clients at home, advertising via social media, ignoring and blocking customers who complain about adverse effects, and repeatedly closing their profile pages only to pop up with a new identity to avoid being traced.
Collins said: ‘At the moment, throughout the UK – not just in Scotland – you’ve got non- healthcare professionals offering extremely dangerous procedures like liquid Brazilian butt lifts. People are nearly dying from these. We’ve seen people doing surgical liposuction who a couple of weeks before were working in retail. It’s ridiculous.
‘In about 50 percent of the complaints that we’ve managed, people have had sepsis. Luckily they’ve gone to hospital just in time, but we are calling for a blanket ban on high-risk procedures by non- healthcare professionals.
‘What we’re seeing now is that non-healthcare professionals are buying things like Botox and fillers from China and Korea at very cheap prices and importing it. There is no healthcare involvement whatsoever, and we’re seeing horrendous complications from people who think they’ve had Botox but God knows what it is.’
In Aberdeenshire, cosmetic nurse Linda Strachan told The Herald she feared governments across the UK have dumped cosmetic regulation into the ‘too difficult’ box.
Strachan, who runs her own aesthetics business and recently stepped down after five years as Scotland representative for the British Association of Cosmetic Nurses (BACN) said patients should regard cheap Botox like fake designer handbags. She said: ‘There’s a massive influx of counterfeit product. You’ve got online pharmacies offering slashed- price dermal fillers claiming that it’s genuine product when it isn’t.
‘You’ve got people going online seeing Botox for £50 instead of £150 and thinking they’ve found a bargain. People wouldn’t buy a Gucci handbag for £50 because they’d know it was fake, but they’ll buy Botox. We know people are using products that aren’t licensed for use in humans, coming from Korea and China.
‘We’re seeing footage of non-sterile ‘laboratories’ – more like factories – churning out counterfeit dermal filler that ends up in some of our salons. Same with liposuction: I’ve seen videos on Instagram and TikTok of really invasive procedures happening by beauticians without the correct care. They’re doing surgical procedures in hair salons. So many things could go wrong – it’s horrific.
‘The government tells us they know they need regulation, but they ‘have to get it right’. But while we’re doing nothing, there are more and more types of products and procedures coming onto the market, and greater and greater harm potentially happening to people.’ AMP
UK aims to tighten regulations
The UK is moving towards tighter regulations in the aesthetics industry, involving several key developments:
1. Proposed mandatory licensing scheme: The UK government has proposed a mandatory licensing scheme for non-surgical cosmetic procedures, aimed at improving safety and professionalism in the sector. This scheme would require both practitioners and clinics to be licensed for high-risk procedures
such as Botox injections, dermal fillers, chemical peels and laser treatments. Charlotte Steele, a spokesperson for the Department of Health, told Aesthetics Today that current stakeholder consultation ‘ensures we develop a framework that not only protects patients but also supports practitioners who are committed to high standards of care. The licensing scheme will be a cornerstone of consumer protection in the aesthetics industry.’
2. Age restrictions: The proposed regulations include banning high-risk cosmetic procedures for individuals under 18, except for medically necessary treatments performed by healthcare professionals.
3. Training and qualifications: The new regulations emphasise mandatory training standards for all aesthetic practitioners, as advocated by the Joint Council for Cosmetic Practitioners (JCCP).
4. Implementation timeline: While full implementation was initially planned for 2026, delays have occurred due to political changes. As of January 2025, the regulations have not yet been implemented, and the timeline has been pushed back.
5. Regional developments: Wales implemented a new licensing scheme for premises conducting non-surgical cosmetic procedures in November 2024, although it doesn’t specifically mention injectable treatments. Scotland launched a public consultation on 20 December 2024, proposing a three-category system for regulating aesthetic procedures based on risk levels.
Despite these proposals, progress has been slower than anticipated. The last official update from the UK government regarding aesthetics regulation in England was in September 2023. The delay is partly attributed to the general election in May 2024 and subsequent changes in government.
While full implementation of the regulatory framework is unlikely to occur in 2025, significant progress towards introducing the planned aesthetics licensing scheme and broader regulation is expected.
Impact on existing UK practitioners
The proposed new licensing scheme for non-surgical cosmetic procedures will have several impacts on existing practitioners:
1. Mandatory licensing
All practitioners will be required to obtain a licence to perform non-surgical cosmetic procedures. This includes experienced practitioners who have been operating without formal licensing.
2.Training and qualifications
Practitioners will need to demonstrate they are ‘suitably trained and qualified’ to obtain a licence. This may require some existing practitioners to undergo additional training or certification to meet the new standards.
3. Indemnity cover
Licensed practitioners will be required to hold appropriate indemnity cover.
4. Premises standards
The scheme will introduce a separate licence for premises, requiring them to meet standards of hygiene, infection control and cleanliness.
5. Age restrictions:
The scheme will introduce a minimum age of 18 for those seeking to receive licensed procedures.
6. Procedure-specific regulations:
The licensing scheme will categorise procedures into different tiers, with some requiring additional supervision. Practitioners may need to adjust their practice based on the specific requirements for each procedure they offer.
7. Local authority enforcement
The scheme will be administered and enforced by local government officials.
8. Potential practice limitations
Depending on the final regulations, some practitioners may find their scope of practice limited if they do not meet the requirements for certain high-risk procedures.
9. Compliance costs
Existing practitioners will likely face additional costs associated with obtaining and maintaining their licences, as well as ensuring their premises meet the new standards.
10. Professional competition
The licensing scheme aims to level the playing field by ensuring all practitioners meet minimum standards. This could potentially benefit competent practitioners by reducing competition from less qualified providers.
While these changes may present challenges for some existing practitioners, the overall goal is ‘to improve safety and standards across the industry, potentially enhancing public trust in licensed professionals’.
Impact on competition among practitioners
The licensing scheme for non-surgical cosmetic procedures is expected to significantly impact competition among aesthetic practitioners in several ways:
1. Level playing field: The scheme aims to create a more level playing field by ensuring all practitioners meet consistent standards. This will reduce unfair competition from less qualified providers who currently operate with low levels of competence and inadequate training.
2. Quality differentiation: Licensed practitioners who meet the new standards may gain a competitive advantage. The scheme will help competent practitioners who already operate to high standards stand out from those with lower qualifications.
3. Barrier to entry: The licensing requirements will create a barrier to entry for new practitioners. This may reduce overall competition, but could benefit existing practitioners who can meet the new standards.
4. Increased costs: Practitioners will need to invest in obtaining and maintaining licences, additional training and ensuring their premises meet new standards. This could lead to increased operational costs, potentially affecting pricing strategies.
5. Consumer confidence: The licensing scheme is expected to build public confidence in the safety of the aesthetic industry. This could potentially expand the market, benefiting licensed practitioners.
6. Specialisation: The tiered approach to procedures may lead to increased specialisation among practitioners, as some may focus on specific types of treatments based on their qualifications and the licensing requirements.
7. Local authority enforcement: With local authorities administering and enforcing the scheme, there may be variations in how strictly the rules are applied in different areas, potentially creating regional competitive differences.
8. Market consolidation: Smaller practices that struggle to meet the new standards may be forced out of the market, potentially leading to consolidation and fewer, but more qualified, competitors.
While the full impact of the licensing scheme on competition is yet to be seen, it is clear that it will reshape the competitive landscape of the aesthetics industry in England, prioritising safety and qualifications over price-based competition.
