As recently highlighted by Amina Amin, Senior Solicitor at MFMac, in her article in the Scotsman, non-surgical cosmetic procedures in Scotland have long operated in a regulatory grey area. These procedures have been available to individuals under 18, and there have been no mandatory medical qualifications required to administer such treatments.
A recent survey revealed a concerning trend: one-third of doctors in Scotland have treated patients as young as 16 for complications arising from non-surgical cosmetic procedures. The current landscape for treatments like facial fillers and injectables is inconsistent, with individuals performing procedures without formal oversight or training, and using products of varying quality and safety.
However, change is on the horizon. On 6 May 2025, the Scottish Government announced its Programme for Government 2025 to 2026, which includes the introduction of the "Non-surgical Cosmetic Procedures Bill." This bill aims to regulate the delivery of certain cosmetic or lifestyle non-surgical procedures, ensure that these procedures are performed in suitable premises and registered with an appropriate body, and establish standards for service providers. The primary goal is to enhance the safety of individuals undergoing such procedures and ensure they receive consistent, high-quality care across Scotland.
This legislative move follows a public consultation launched by the Scottish Government in December 2024, which concluded in February 2025. The proposed regulatory system categorises procedures based on the level of risk they pose to patients:
- Low-risk treatments: These do not require medical expertise and can continue to be performed without formal qualifications.
- Medium-risk treatments: These require supervision by a medical professional.
- High-risk treatments: These invasive and/or complex procedures must be performed by qualified medical practitioners.
The bill is set to be introduced in the Scottish Parliament before the elections in May 2026.
Providers of non-surgical cosmetic procedures and manufacturers of related products should closely monitor the development of this bill, and proactively assess how their businesses may need to adapt to comply with the new legislation.
