The Scottish Government has published the Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Bill, introducing a national licensing system for non-medical cosmetic treatments such as dermal fillers, microneedling and chemical peels.
The Bill — announced on 8 October 2025 following a public consultation — aims to prioritise client safety, practitioner accountability and hygiene standards in the aesthetics sector.
What the Bill will change
• Age restrictions
Injectable fillers and strong chemical peels will no longer be permitted for anyone under 18.
• Mandatory licensing for higher-risk procedures
Any procedure that pierces or penetrates the skin — including injectables and advanced skin treatments — must be performed only in licensed premises that meet strict hygiene and safety criteria.
• Future-proof powers
Scottish Ministers will have authority to expand the list of regulated procedures, set qualification requirements and define how compliance is enforced.
The Bill is currently progressing through Parliament and is expected to complete within the present session (ending May 2026). Once approved, it will become illegal to perform regulated procedures on under-18s or in unlicensed premises.
Treatment reclassification ahead of publication
In response to industry feedback during consultation, several treatments were reclassified into a lower-risk (Group 1) category that does not require medical oversight. These include radiofrequency, high-frequency ultrasound (non-intimate), photorejuvenation, superficial fruit peels, cryolipolysis, cryotherapy and electrocautery.
Group 1 also includes microneedling up to 1.5 mm, IPL and LED therapies, and non-ablative lasers for rejuvenation, acne and pigmentation.
Why regulation matters
The Government states the Bill is designed to ensure that non-surgical treatments are safe, proportionate and professionally governed, noting increased concern about physical and psychological risks — particularly for younger clients.
WL Aesthetics Commentary
As a distributor working with clinics across the UK, WL Aesthetics welcomes this move toward clear, proportionate and enforceable safety standards in Scotland.
For clients, the Bill helps create confidence — licensed premises, defined practitioner requirements and age protections all reduce avoidable risk.
For practitioners, the framework supports professionalism:
- Safe, compliant premises will be differentiated from informal or unregulated operators
- Consistent standards protect the reputation of qualified providers
- Clients will increasingly seek out clinics known to meet regulatory expectations
When regulation raises the quality baseline, the market tends to favour trained, compliant and product-sourced-through-regulated-channels providers — which ultimately strengthens the legitimacy and longevity of the aesthetics sector.
WL Aesthetics will continue to support partners in aligning with evolving safety and regulatory expectations while maintaining access to approved products and education.
Summary
Scotland’s Non-Surgical Procedures Bill sets a new benchmark for aesthetic treatment safety, restricting access for under-18s and bringing higher-risk procedures under a licensing system. As the Bill advances, it is expected to influence standards across the wider UK — benefiting clients and strengthening professionally run aesthetic businesses.
