Scotland’s approach to regulating non-surgical cosmetic procedures is changing. The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill is progressing through the Scottish Parliament and, if enacted, would introduce clearer legal controls over where certain procedures can be performed, who can provide them, and safeguarding requirements for under-18s.

This article summarises the current proposals, what we know from the parliamentary process so far, and practical steps healthcare professionals can take now to prepare.

What has happened so far

The Bill was introduced on 8 October 2025 and is currently at Stage 2. At Stage 2, MSPs can propose amendments, and the Bill is examined in greater detail before proceeding.

On 5 February 2026, the Scottish Parliament agreed to the Bill’s general principles during the Stage 1 debate. This does not make the Bill law. It means Parliament agrees with the overall aims, subject to amendments and later votes.

Why Scotland’s aesthetic regulations are tightening

The proposed legislation is intended to address patient safety concerns in the non-surgical cosmetic sector, including complications arising from poorly performed procedures and inconsistent oversight. A Scottish Government consultation on this topic previously indicated strong public support for stronger regulation and clearer standards for providers.

In practice, the Bill signals a move towards stronger governance around higher-risk procedures, clearer expectations for permitted settings, and legal safeguards for minors.

Which procedures could be regulated?

The Bill proposes a framework to regulate defined non-surgical procedures. The categories referenced in parliamentary briefings and related summaries include treatments such as:

  • Ablative laser treatments
  • Chemical peels (certain types)
  • Microneedling
  • Thread lifts
  • Injectable procedures
  • Intravenous procedures
  • Other higher-risk interventions included in the Bill’s scope

The Scottish Government would also have powers, through subsequent changes, to amend or expand the list over time. This is important for clinics planning services and training pathways.

Permitted premises and Health Improvement Scotland

A key feature of the proposed framework is the restriction of certain procedures to permitted premises. Parliamentary materials describe permitted premises as including independent hospitals and independent clinics registered with Healthcare Improvement Scotland (HIS), as well as certain NHS-related settings and registered pharmacies, subject to specific conditions.

If enacted, the Bill would make it an offence to provide a regulated non-surgical procedure in non-permitted premises. That would be a major shift for providers currently operating outside regulated clinical environments.

Under-18 restrictions

The Bill includes provisions intended to make it illegal for under-18s to access the regulated non-surgical procedures covered by the legislation. For clinics, this increases the importance of robust age verification, documentation, and clear patient communications.

What the Health Committee has flagged

The Scottish Parliament’s Health, Social Care and Sport Committee has supported the Bill’s general principles while also raising practical concerns about how the new framework should operate in real settings.

Points raised include the current variability in training and qualifications across the sector, questions around what clinical supervision should look like for procedures covered by the Bill, and the need for clear standards and effective enforcement.

For responsible providers, these discussions matter because they are likely to shape the final details of implementation and any supporting guidance.

What should Scottish healthcare professionals do now?

While the Bill is not yet law, clinics and practitioners in Scotland can take sensible preparation steps that support good governance regardless of the final wording:

  • Premises review: confirm your setting, registration position, and whether you may need to adapt your operating model if permitted premises rules change.
  • Clinical governance: tighten consent, aftercare, adverse event reporting, audit, and record-keeping processes.
  • Safeguarding: review age-verification workflows and ensure staff adhere to consistent policies.
  • Insurance: verify that your indemnity terms align with your scope of practice and premises setting.
  • Training evidence: keep certificates, competency logs, and CPD records organised and easy to produce if required.

If your clinic has a mixed team, it is also worth mapping who performs which procedures today, which procedures may be affected, and what supervision arrangements are in place

Training and qualifications: strengthening your professional position

As Scotland’s aesthetic regulations evolve, clinics can expect closer scrutiny of training quality, governance, and competence. Even before any legal changes take effect, many providers are choosing to strengthen their position with structured education and recognised qualifications.

For registered healthcare professionals delivering injectables, the OTHM Level 7 Diploma in Clinical Injectable Therapies provides an Ofqual-regulated pathway with structured theory and practical training to support safe practice, informed clinical decision-making, and awareness of complications.

Derma Institute also delivers hands-on training in Scotland for eligible practitioners. You can view our academy location and course availability here: Derma Institute Stirling.

Derma Institute: accredited training for a regulated future

Derma Institute is a doctor-led training academy that provides medical aesthetics education and clinical support to registered healthcare professionals across the UK.

If you are reviewing your practice in light of Scotland’s aesthetics regulations, explore our full range of training options at Derma Institute training courses.

Next steps

The Bill is still progressing through Parliament, and amendments remain possible at Stage 2 and Stage 3 before a final vote. If you practise in Scotland, it is worth monitoring updates and tightening governance now, particularly around premises suitability, documentation, and safeguarding.

To discuss training options in Scotland or how to strengthen your clinical position, visit our website or speak to the Derma Institute team. Start with Derma Institute Stirling or browse all courses.


Mike Sherwood

Mike Sherwood

Aesthetic Business & Marketing Coach | Director of Marketing, Derma Institute

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