From 1 June 2025, nurse and midwife prescribers cannot remotely prescribe for elective non-surgical cosmetic procedures. The same face-to-face requirement applies to GMC-registered doctors and GPhC-registered pharmacist prescribers. Before any cosmetic injectable prescription is issued, the prescriber must see the patient in person, examine their facial anatomy, review their medical history, and document informed consent.
What the remote prescribing ban covers
The Nursing and Midwifery Council announced its updated position on 29 April 2025, with the requirement taking effect on 1 June 2025. Nurse and midwife independent prescribers are no longer permitted to issue prescriptions for non-surgical cosmetic medicines via telephone, email, video call, or through a third-party intermediary.
The medicines in scope are prescription-only products (POMs) used in aesthetic practice: botulinum toxin preparations including Botox, Dysport, and Vistabel, hyaluronidase, and any other prescription-only medicine used for a cosmetic indication. Dermal fillers are not prescription medicines in the UK and are not covered by this specific rule, though they are subject to the separate age restriction legislation introduced under the Health and Care Act 2022.
The General Medical Council and General Pharmaceutical Council issued aligned guidance in the same period. GMC-registered doctors must conduct a face-to-face physical examination before prescribing any injectable cosmetic medicine. GPhC guidance updated in April 2025 brings pharmacist prescribers in line: prescription and administration may only follow a physical examination of the patient.
Three of the UK's main prescribing regulators have now reached the same position. The remote prescribing route for cosmetic injectables is closed.
Which prescribers does the ban apply to?
The requirement covers all UK-registered prescribers involved in the aesthetic injectable supply chain:
- Nurse and midwife independent prescribers (NMC registrants): a face-to-face consultation is required before each new course of treatment. Remote methods such as video call, telephone, online form, or patient assessment via a non-prescribing intermediary do not satisfy the requirement. Nurses found to be remotely prescribing after 1 June 2025 are in breach of NMC guidance and face fitness-to-practise risk.
- GMC-registered medical practitioners: the GMC requires a face-to-face physical examination before prescribing any injectable cosmetic medicine.
- GPhC-registered pharmacist prescribers: GPhC's April 2025 update aligned pharmacist prescribers with the NMC and GMC position. The face-to-face assessment requirement now applies consistently across all three registers.
The ban covers elective cosmetic prescribing. Prescribing for medical indications, such as botulinum toxin for hyperhidrosis under a dermatology protocol, sits within different clinical governance frameworks and is not affected in the same way.
What a compliant face-to-face assessment must include
The requirement is not simply a presence tick-box. The regulators set out what a face-to-face assessment for cosmetic prescribing must involve:
- A documented in-person assessment at which the prescriber can examine facial anatomy directly
- Review of skin integrity, including prior treatment history and any known filler placement
- Full medical and medication history, including contraindications and allergy screening
- Informed consent, obtained without time pressure and before any prescription is written
Each new course of treatment requires a fresh face-to-face assessment. Repeat prescriptions cannot be issued on the basis of a prior consultation without seeing the patient again. The prescriber must be physically present with the patient at the point of assessment, not relying on notes or images submitted by a non-prescribing administrator.
The detail matters: in a fitness-to-practise context, the question will be whether the prescribing record demonstrates a genuine clinical assessment or a form-filling exercise. Documentation should show that anatomy was examined, history was taken, contraindications were considered, and consent was secured.
How the ban affects non-prescribing practitioners
Many practitioners administering prescription-only injectables are not independent prescribers. Nurses without a prescribing qualification, healthcare practitioners working under patient group directions, and practitioners from non-clinical backgrounds who have trained in aesthetics all depend on a prescribing professional within their governance structure.
Before June 2025, some practitioners operated under arrangements where a remote prescriber reviewed a form or photograph and issued the prescription without seeing the patient. That model is no longer compliant.
The prescriber must now be physically available to examine the patient before any prescription is issued. This means practitioners working under a prescribing supervisor need a named individual who can attend face-to-face assessments for each patient and each treatment course. Documentation of that arrangement, and of each face-to-face assessment, should be held in the patient record.
For some clinics, this represents a material change to their operating model. If the prescribing doctor or nurse prescriber was providing oversight remotely, the clinic now needs either to bring that prescriber on-site or to restructure the prescribing arrangement entirely.
The regulation overview at Aesthetics Unlocked maps the current UK framework in full, including how oversight responsibilities interact with the forthcoming licensing scheme.
What the JCCP says
The JCCP welcomed the NMC's updated position and had been consistent in supporting the view that the prescribing relationship in aesthetics should involve direct clinical responsibility. The JCCP and the Council for Surgical and Invasive Procedure Safety (CPSA) both contributed to stakeholder engagement that preceded the NMC's final guidance.
The JCCP Code of Practice has long required practitioners to work within clear governance structures and to document clinical decision-making. The prescribing ban aligns with that position: prescriber involvement must be genuine, evidenced, and face-to-face.
For practitioners seeking listing on the JCCP Practitioner Registry, demonstrating compliant prescribing arrangements is part of the standards review. Governance structure and prescribing oversight are assessed, not assumed.
The standards page for the JCCP covers what the voluntary registry requires and how the Code of Practice maps to day-to-day clinic governance.
Governance questions for 2026
The direction from the NMC, GMC, and GPhC is now aligned and clear. For practitioners reviewing their clinic governance in the light of the June 2025 changes, the questions to work through are:
- Is the prescribing practitioner physically present for every patient's face-to-face assessment?
- Is the consent process conducted by, or in the direct presence of, the prescriber?
- Is each face-to-face assessment documented with sufficient clinical detail?
- Is the prescribing practitioner named in the patient record for each treatment course?
- If the prescribing arrangement involves an external prescriber, is there a written governance agreement in place?
The free two-day RAG mini covers the fundamentals of prescribing governance and helps practitioners identify where their current arrangements meet the regulatory standard and where gaps exist.
From Regulation to Reputation™ is £200 off until 20 July, £299 instead of £499, with code REG299. From Regulation to Reputation is the four-week programme built on the regulatory framework Bernadette set out in her book Regulation to Reputation: mastering successful aesthetic practice. It covers the full prescribing-chain governance, documentation standards, and compliance infrastructure practitioners need to operate with confidence under the tightening regulatory environment.
FAQ
Does the remote prescribing ban apply to all aesthetic injectables?
The ban applies to prescription-only medicines used in aesthetic practice, including botulinum toxin preparations and hyaluronidase. Dermal fillers are not prescription-only products in the UK and are not covered by this specific rule, though they are subject to the age restriction legislation introduced under the Health and Care Act 2022.
Can a nurse prescriber use video consultation and then prescribe?
No. Since 1 June 2025, NMC guidance requires nurse and midwife prescribers to conduct an in-person face-to-face consultation before prescribing for elective non-surgical cosmetic procedures. Video, telephone, and online methods do not satisfy the requirement.
What are the consequences of continuing to prescribe remotely?
Remote prescribing after 1 June 2025 puts a nurse prescriber in breach of NMC guidance and creates a fitness-to-practise risk including potential removal from the register. It also creates indemnity exposure, since most professional indemnity policies require practitioners to operate within their regulator's current guidance.
Does this apply to doctors and pharmacists as well as nurses?
Yes. The GMC requires face-to-face physical examination before cosmetic injectable prescribing. GPhC updated its guidance in April 2025 to the same standard. The face-to-face requirement now applies consistently to NMC, GMC, and GPhC registrants.
How does this affect practitioners who do not hold a prescribing qualification?
Non-prescribing practitioners who administer injectables under a prescribing arrangement now need a prescribing supervisor who is physically present for face-to-face patient assessments. Any remote prescribing arrangement that existed before June 2025 needs to be reviewed and, if necessary, restructured to meet the current standard.