The UK aesthetics licensing scheme is the regulatory framework that, once fully in force, brings non-surgical cosmetic procedures in England under formal control. Higher-risk procedures move under the Care Quality Commission. Lower-risk procedures move under local-authority licensing. The DHSC consultation closed in October 2023; implementation is rolling out in stages through 2024, 2025, and 2026.
What the scheme actually is
The licensing scheme sits inside the Health and Care Act 2022, Part 5, Section 180. It gives the Secretary of State for Health and Social Care the power to require practitioners, and the premises they operate from, to hold a licence to deliver named non-surgical cosmetic procedures.
Once the secondary legislation is laid, working without a licence in scope will not be a grey area. It will be unlawful.
What's in scope, and what isn't
The Department of Health and Social Care's consultation response set out a tiered model. The plan splits procedures into three risk bands:
- Highest risk. Procedures with the most serious harm potential, including liquid Brazilian butt lifts and other deep-injection work, move under CQC regulated activities. These will require formal CQC registration of the clinic, not just a local-authority licence.
- Medium risk. Procedures such as injectables and energy-based devices fall under the local-authority licensing tier, with practitioner-level licences and premises-level licences both required.
- Lower risk. Procedures with limited harm potential remain under local-authority licensing, with lighter-touch standards.
The risk banding is doing the heavy lifting. Where any specific procedure lands inside the scheme is the difference between needing a CQC application and needing a council licence. The JCCP's guidance reads the bands the same way.
What the consultation actually said
The DHSC consultation ran from September to October 2023. It received over 11,800 responses, a high figure for a consultation of this kind, which tells you something about the heat in the field. The majority of respondents agreed with the government's proposals.
A few specific commitments emerged from the response:
- Age restrictions. The government committed to age restrictions for those undergoing non-surgical cosmetic procedures. Performing in-scope work on under-18s outside specific exemptions will be on the wrong side of the framework.
- Education and training standards. Throughout 2024 and 2025, expert groups have been working on the standards underpinning the scheme, qualifications, infection control, hygiene, and the insurance model.
- Premises licensing. It is not just the practitioner. The clinic itself will need a licence, with separate fees and standards.
Where things stand in 2026
Implementation is staged. The highest-risk procedures are coming under CQC first. Local-authority licensing for medium-risk and lower-risk procedures rolls out through secondary legislation, practitioner-level licences first, then premises licences.
The exact procedure list, what counts as high, medium, low, is the piece I'd watch most closely. The JCCP's risk-based framework is the most likely template for how those bands are defined when the regulations finally land.
For practitioners in Scotland, Wales, and Northern Ireland, the position is different. The licensing scheme is an England-only construction. Devolved nations are developing their own positions, with HIS, HIW and RQIA as their respective clinical regulators. Expect divergence.
What practitioners need to do now
A few practical moves work regardless of where the lines finally land:
- Document your scope of practice in writing, what you do, what you don't, what you refer.
- Map your procedures to the JCCP risk bands so that when the official banding is published, you already know where each of your services sits.
- Anchor consent forms to current best practice, the JCCP's standards and the CPSA competence framework are the right reference points.
- Decide on your CQC position. If any procedure you offer is likely to fall under CQC regulated activity, the application work starts now, registration is not a fast process.
- Watch the secondary legislation timeline. When the regulations are laid in Parliament, the implementation date will become known and the runway closes quickly.
If you want the structured walk-through, the RAG Pathway is the four-week programme I designed to land practitioners aligned with JCCP, CPSA, MHRA and the licensing-scheme expectations before the regulations tighten. It covers scope, consent, risk banding, and the documentation each tier of the scheme is going to expect.
FAQ
Is the UK aesthetics licensing scheme in force in 2026?
Not fully. The Health and Care Act 2022 provides the legal power. The DHSC's consultation closed in October 2023. Secondary legislation, the regulations that bring specific procedures into scope, is rolling out in stages through 2024, 2025, and 2026. Higher-risk procedures move under CQC first.
Does the licensing scheme apply outside England?
No. The Health and Care Act 2022 licensing scheme is England-only. Scotland, Wales, and Northern Ireland are each developing their own positions, with Healthcare Improvement Scotland, Healthcare Inspectorate Wales, and the RQIA as their respective clinical regulators.
Will I need both a practitioner licence and a premises licence?
Yes, for in-scope procedures. The DHSC's consultation response confirmed both the practitioner and the clinic will need to hold their own licences, with separate fees and standards underpinning each.
Are higher-risk procedures going under CQC or local authority?
CQC. The government's response confirmed that the highest-risk procedures, including liquid Brazilian butt lifts, move under CQC regulated activities, not local-authority licensing. Lower-risk procedures stay under the local-authority tier.
What about age restrictions?
The government has committed to introducing age restrictions for those undergoing non-surgical cosmetic procedures. Performing in-scope work on under-18s outside specific exemptions will be unlawful once the regulations are in force.