The Scottish Government has confirmed a new Bill as part of its Year Five Legislative Programme, outlined in the Programme for Government 2025–26: Building the Best Future for Scotland. This regulation will introduce a framework for non-surgical aesthetic treatments, with the aim of improving safety and accountability across the sector.

“The Scottish Government believes that consumers should be able to receive these procedures with confidence and with minimal risk of harm, wherever they access them. We also believe that providers of these procedures should have a framework within which they can operate safely and responsibly.”

The Bill is set to be introduced to the Scottish Parliament before May 2026, with further details expected as it progresses. This announcement follows a government-led consultation into a potential licensing scheme—mirroring the approach taken in England’s consultation in 2023.

Beauty Backed Trustee and CEO of BABTAC, Lesley Blair MBE has been instrumental in bringing this Bill to parliament, with Lesley being a member of Cosmetics Informed and Empowered Public Sub-Group, part of the Scottish Government's Interventions Expert Group.

"With the media regularly reporting treatments going wrong, our industry is under scrutiny, so it's more important than ever for consumers to be able to identify and support true professionals. This announcement is a huge step forward for client safety and professional standards."

The Scottish consultation proposed categorising aesthetic procedures into three risk-based groups:

Group 1: Low Risk

These procedures are considered the least invasive and lowest in risk. The Scottish Government proposes they can be safely carried out by trained, non-healthcare professionals in either a licensed premises or a Healthcare Improvement Scotland (HIS) regulated setting.

Proposed treatments in Group 1 include:

• Microneedling
• Superficial chemical peels (outermost skin only)
• Intense Pulsed Light (IPL)
• LED therapy
• Laser tattoo removal
• Laser hair removal

Group 2: Medium Risk

Procedures in this group carry more risk and are more invasive than those in Group 1. While the government suggests they may still be carried out by trained, non-healthcare professionals, it proposes that they must be performed in an HIS-regulated setting under the supervision of a qualified healthcare professional.

Group 2 includes:

• Mesotherapy
• Botulinum toxin (botox) injections
• Dermal fillers and other injectable cosmetic products (even non-drugs)
• Medium-depth peels
• Photo rejuvenation
• Radiofrequency
• High-intensity focused ultrasound (HIFU)
• Cryolipolysis

Group 3: High Risk

These procedures are deemed to carry the highest risk and should only be performed by an appropriate healthcare professional within an HIS-regulated setting.

Treatments proposed for Group 3 include:

• PRP and other blood-derived injections
• Injection microsclerotherapy
• Injection lipolysis
• Dermal micro-coring
• Hay fever injections
• Any IV procedures
• Dermal fillers for augmentation (e.g. liquid BBL)
• Deep chemical peels (e.g. phenol)
• Laser treatments targeting deeper dermis
• Carboxytherapy
• Cellulite subcision
• Electrocautery (advanced electrolysis)
• Cryotherapy and cryocautery
• Thread lifts

Group 3 also includes any Group 1 or 2 procedures performed in intimate areas (except for hair removal), with tattooing and skin piercing excluded as they are already licensed separately.

Industry Concerns

As with the England consultation, beauty professionals in Scotland have raised concerns. Many feel that requiring healthcare oversight for procedures such as mesotherapy and radiofrequency, commonly regarded as low-risk could unfairly limit the scope of qualified beauty therapists. Advanced treatments like electrolysis, traditionally offered by highly skilled therapists, may be reclassified for medical professionals only.

At this stage, final classifications have not been confirmed. However, the proposed framework signals a significant shift in how non-surgical aesthetic services may be regulated in the future.

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To read more about BABTAC's involvement, read their full press release here