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UK Government Launches Consultation on Unregulated Cosmetic Procedures

Concerns have been expressed about the regulation of doctors carrying out cosmetic surgery and the unclear nature of some of the organisations accrediting them. The Royal College of Surgeons of England has long campaigned for better regulation of cosmetic surgery. Many people do not realise that the law allows any doctor – surgeon or otherwise – to perform cosmetic surgery in the private sector. There are many excellent surgeons working in the cosmetic surgery industry, but it is difficult for patients to identify these highly trained surgeons from those who should not be practising.

Since 2017, the Intercollegiate Cosmetic Surgery Oversight Committee (ICSOC) – along with representatives of the four surgical royal colleges in the UK and Ireland, and seven surgical specialty associations – has run a voluntary certification scheme for cosmetic surgeons who meet certain standards of knowledge, training and professional behaviour. A key requirement for certification is being on the General Medical Council’s specialist register. There is a resource on the RCS England website where patients considering cosmetic surgery can check if their surgeon has been certified.

RCS England, together with ICSOC, is calling on the GMC to make the certification scheme a formal regulated credential to ensure that patients are safe in an industry that has been largely unregulated to date.

Consultation Complete

People and businesses were invited to share their views on how to make non-surgical cosmetic procedures safer as thousands complain of ‘botched’ procedures. People and businesses were being 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.

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 and restrictions for high-risk procedures, including those involving injecting fillers into intimate parts of the body – including the breasts and buttocks. 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.

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 in the UK. New regulations will support businesses by introducing high standards across the sector, raising the reputation and professionalism of the industry.

Thoughts and Quotes

Minister for the Women’s Health Strategy, Maria Caulfield said: “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. She went on to say “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 complaints relating to dermal fillers and almost a quarter relating to Botox.

Ashton Collins, Director, Save Face said that “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 of 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.”

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 to ensure that 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.” He went on to say “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.”

Victoria Brownlie, Chief Policy Officer at the British Beauty Council stated “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 that 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 ran for 8 weeks and closed on Saturday 28 October 2023. It followed the passing of the Health and Care Act in April 2022, which gave the Health and Social Care Secretary the power to introduce a licensing regime. Under the proposed 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 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.


Regulating invasive cosmetic procedures in the UK is “an absolute nightmare” with many of those claiming to be qualified to perform them not able to work as consultants in the NHS, a leading plastic surgeon has said. Maniram Ragbir, the president of the British Association of Plastic, Reconstructive and Aesthetic Surgeons (Bapras), urged people considering procedures to check their doctor was registered as a plastic surgeon on the General Medical Council’s specialist register, which lists those qualified to work as consultants in the UK. I would be willing to bet that a significant proportion, if not more than 50% of people who are claiming to be cosmetic surgeons, will not be on a specialist register or would be ineligible for a job [as a plastic surgeon] in the NHS,” he said.

Ragbir also raised concerns about the growing number of organisations with credible-sounding names that surgical and non-surgical practitioners can advertise themselves as members of. These do not necessarily check the credentials of applicants, he said, making it difficult for the public to identify reputable practitioners. “The word ‘college’ is not a protected word. You could run a weekend course in liposuction, and then send [participants] away with a certificate – and that person can then advertise that they are a qualified, certified practitioner, which is unfortunately what is happening,” said Ragbir, who is also a consultant plastic surgeon at the Newcastle upon Tyne hospitals NHS foundation trust. His comments come as research published in the Journal of Plastic, Reconstructive and Aesthetic Surgery raised concerns about the state of regulation within the UK aesthetics industry.

Researchers led by Afshin Mosahebi, a professor of surgery at UCL and consultant plastic surgeon at the Royal Free hospital in London, scrutinised the websites of 22 self-regulating organisations that oversee surgical and non-surgical cosmetic procedures within the UK. They concluded that a significant majority were not meeting best practices for effective self-regulation, as laid out by the government, potentially putting patients’ health at risk.

Marimo Rossiter, of University College London, the study’s lead author, said: “Customers want to see that the person taking care of their procedure is qualified and has done adequate training, and one way that a practitioner can make themselves seem credible is to say that they are a member of X organisation. But we found that a lot of these organisations are not checking they have registered practitioners that are qualified, have been trained well, currently practise to a high standard and ensure that patient safety is at the heart of their practice.”

The team called for additional mechanisms to help patients identify government-approved registers that do run more stringent checks and must meet certain standards , as well as tighter cooperation between the Department of Health and Social Care (DHSC) and registers to ensure that clinics are adequately checked.

According to an analysis of nearly 3,000 complaints about botched procedures received by the government-approved register Save Face during 2022, almost nine in 10 patients (86%) reported not being appropriately consented prior to treatment, while 93% were unaware that serious complications could occur. More than eight in 10 of these individuals (84%) were ignored or blocked by their practitioner when they tried to seek help.

Ashton Collins, of Save Face, stressed that many of the organisations covered by the UCL study did not claim to be self-regulatory bodies, but included professional associations and groups supporting continuing professional development. Also, while some of these organisations may include a practitioner finder on their website, they did not necessarily claim that members were checked – unlike Save Face’s register However, Rossiter said: “When an organisation which looks to uphold values of patient safety and transparency lists practitioner members who aren’t checked, then this raises the question of the value of the organisation.

“Patients look to organisations and professional membership groups as a marker of quality. The membership of a reputable professional organisation is currently one of the few ways in which patients can appraise their providers, and as such we think it is important that patients are made aware of the diverse array of providers.”

Victoria Brownlie, the chief policy officer at the British Beauty Council, said: “As the study shows, there are some registers operating wholly responsibly and in line with the government’s criteria for these kinds of bodies, but this is by no means the norm. They should be maintaining the highest possible standards for ensuring the competence of practitioners who, at times, are performing procedures that carry potentially huge risks to the client.” Currently, safe practice in the UK esthetics industry is largely reliant on self-regulatory bodies. If these bodies do not maintain high standards of safety guidelines and properly accredit practitioners, patient safety may be at risk.