17 Sep 2026
By Arlene Dunbar, Licensing Team Lead, Licensing, Gilson Gray
Beauty is in the eye of the regulator as Scotland’s aesthetics rules change
The days of offering a quick cosmetic treatment from the spare room, beauty salon or a client’s home could soon be numbered. From September 2027, Scotland’s aesthetics industry will face a significant regulatory shake-up, bringing a range of non-surgical cosmetic procedures within a formal licensing framework for the first time.
For an industry that has grown rapidly, fuelled in part by social media and increasingly accessible treatments, the scale of the market is significant. The UK’s cosmetic surgery industry is estimated to be worth £3.6 billion, with non-surgical treatments such as Botox and dermal fillers accounting for 90% of that figure[1].
From 6 September 2027, certain non-surgical procedures will require a licence under the Civic Government (Scotland) Act 1982[2], while others will face additional restrictions under the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026[3]. Together, the reforms create a more structured framework for treatments that pierce or penetrate the skin and are carried out for cosmetic or wellbeing purposes.
The changes represent a major shift for an industry that has historically sat in something of a regulatory grey area. Treatments have become increasingly sophisticated and widely available, but the rules governing who can perform them, where they can be carried out and what standards must be met have not always kept pace.
The new regime aims to change that. At the heart of the reforms is a distinction between procedures that can be managed through local authority licensing and those considered to require greater clinical oversight. Certain lower-risk treatments, including some forms of microneedling and non-ablative laser hair removal, will fall within the new licensing regime.
Higher-risk procedures, including injectable treatments like dermal fillers and botulinum toxin, will face tighter controls. These treatments will need to be carried out in specified permitted premises, such as registered independent clinics or hospitals and certain medical, dental or pharmacy settings.
For practitioners and clinic owners, this means that knowing your treatment menu inside out will become more important than ever. A procedure that could previously be offered without a specific licence may soon come with a very different compliance checklist.
Businesses will need to consider whether their premises, qualifications, training, insurance and operating procedures meet the new requirements. For smaller operators, particularly those working from home or offering mobile services, the changes could require a significant rethink of how and where treatments are delivered.
Although the new regime is not due to come into force until 2027, businesses should begin preparing sooner rather than later, while recognising that further guidance and detail are still expected. Reviewing the treatments offered, understanding which regulatory category they fall into and keeping under review which licences and premises requirements are likely to apply should therefore be a priority.
The reforms are also expected to give local authorities a much bigger role to play in administering the new licensing regime. However, detailed operational guidance for councils has not yet been published, meaning there remains uncertainty around how applications, inspections and enforcement will work in practice. With 32 local authorities involved, clear national guidance will be important to support consistency, particularly for businesses operating across different parts of Scotland.
For consumers, however, the changes should be reassuring. Greater oversight should make it easier to distinguish practitioners who meet recognised standards from those operating with little formal accountability. It may also give customers more confidence that treatments are being delivered from suitable premises by appropriately trained professionals.
There is, of course, no such thing as regulation without a price tag. New licensing, training, premises and compliance requirements are likely to create additional costs for businesses, some of which may ultimately be passed on to customers. Some mobile or informal operators may also find that their existing business model is no longer viable.
But regulation could bring opportunities as well as obligations. For responsible practitioners, a more level playing field could help good businesses stand out in an increasingly crowded market. When consumers can compare qualifications, standards and compliance alongside price and reputation, the industry may become more professional as a result.
Scotland is also not the only part of the UK moving in this direction. In England, the Health and Care Act 2022[4] gives the UK Government powers to introduce a licensing scheme for non-surgical cosmetic procedures, including requirements for practitioners and premises. The detail of that regime is still to be established, but the wider picture is clear: the days of treating aesthetics as a largely unregulated space are coming to an end.
For Scotland’s aesthetic businesses, September 2027 may sound like a long way away. In regulatory terms, however, it is just around the corner.
The message for practitioners is simple: don’t leave your licence to the last minute. Understanding the new rules, reviewing current practices and taking advice where necessary will give businesses the best chance of being ready when the new regime comes into force – and of turning a regulatory shake-up into an opportunity to raise standards across the industry.
[1]https://www.heraldscotland.com/news/24524281.cosmetic-sector-regulation-going/
[2]https://www.legislation.gov.uk/ukpga/1982/45/contents
