Scotland’s New Licensing Framework for Non‑Surgical Cosmetic Treatments (NSCP Bill)

Scotland’s New Licensing Framework for Non‑Surgical Cosmetic Treatments (NSCP Bill)

Scotland is preparing to become the first part of the UK to legislate a regulated, tiered licensing regime for aesthetic procedures—covering both practitioners and premises. The Non‑Surgical Cosmetic Procedures Bill (NSCP Bill), announced in the Programme for Government 2025–26, is slated to be introduced in the Scottish Parliament before May 2026, with full implementation expected to follow afterwards. 

1. Why this Bill matters

• Until now, many commonly used cosmetic treatments were offered without formal qualifications or insurance. A 2025 poll found that over one in three Scottish doctors had treated complications from poorly performed injectable procedures—a problem the upcoming Bill aims to curb. 

• With more than 2,200 responses to the public consultation (Dec 2024–Feb 2025), there was widespread support for clear safety standards, age limits, and licensed settings. 

2. Key Pillars of NSCP Bill

3. Three Risk-Based Treatment Groups

Each procedure falls into a Group based on invasiveness and potential for harm:

➤ Group 1 – Low Risk

• Examples: microneedling (~1.5mm), superficial fruit peels, non-ablative IPL/LED, medical cryotherapy, radiofrequency, tattoo/laser hair removal.

• May be carried out by licensed non-medical practitioners in either a licensed council premises or a HIS-registered setting. 

➤ Group 2 – Moderate Risk

• Examples: botulinum toxin, dermal fillers (≤2 ml), photo‑rejuvenation, HIFU, mesotherapy, cryolipolysis.

• Only in HIS-registered premises, performed by trained non-medics working under the supervision of a healthcare professional (e.g. doctor, prescribing nurse or pharmacist). 

➤ Group 3 – High Risk

• Examples: PRP, lipolysis injections, thread lifts, phenol peels, deep laser, augmentative filler procedures (>2 ml), and other advanced injectable or invasive treatments, including intravenous vitamin infusions.

• Must be performed only by a healthcare professional in a HIS-licensed clinical setting. 

4. What It Means for Different Actors

👩⚕️ Patients

• Only receive treatments in licensed locations, with clear proof of practitioner registration.

• Must be 18+; Group 3 procedures are restricted to medical professionals.

• Avoid very cheap ‘pop-up’ offers—only properly licensed services should be trusted. 

💋 Non-Medical Practitioners (e.g. beauty therapists)

• You can offer Group 1 treatments with just a council licence.

• You may also offer Group 2 procedures—but only under on-site supervision by a medical professional in a registered HIS environment.

• You cannot offer Group 3 services yourself.

🩺 Healthcare Professionals (Doctors, Nurses, Dentists, Pharmacists)

• You can perform both Group 2 and Group 3 procedures, but only from HIS-regulated facilities.

• When supervising Group 2 practitioners, you are responsible for prescription and initial consultations.

• You must ensure your premises and processes meet HIS clinical standards. 

5. Getting Ready: Clinic & Staff Checklist

1. Categorise offerings — list all procedures to determine client age restrictions and where they can be safely offered.

2. Align with upcoming training standards — staff must meet frameworks expected by the Bill for Group 1 or Group 2 services.

3. Update documentation — informed consent forms, consultation templates, and emergency protocols tailored to Group levels.

4. Secure appropriate insurance — especially for Group 2/3 procedures involving prescription meds.

5. Create clear patient communication — explain categories and licencing in FAQs; include your proof of licensing.

6. Summary: Why It Matters

Scotland’s NSCP Bill represents the first law of its kind in the UK to formally regulate aesthetic procedures—with strong health protections for consumers and a clear legal structure.

• It introduces licensing for both practitioners and premises.

• It splits services into three risk-based groups, each with different supervision requirements.

• Age restrictions and standardised enforcement help ensure that aesthetic treatments are safe, consistent, and transparent.

For patients, it brings much-needed reassurance. For practitioners and clinics, early adaptation is key—prepare now to comply and differentiate your service with professionalism and legal integrity from day one.

Need help designing a client‑friendly risk matrix, or a checklist your clinic can use internally? Let me know—happy to assist with templates and layouts.