Wednesday 23rd September 2026
The days of offering a quick cosmetic treatment from the spare room, beauty salon or a client’s home could soon be numbered. From September 2027, Scotland’s aesthetics industry will face a significant regulatory shake-up, bringing a range of non-surgical cosmetic procedures within a formal licensing framework for the first time.
For an industry that has grown rapidly, fuelled in part by social media and increasingly accessible treatments, the scale of the market is significant. The UK’s cosmetic surgery industry is estimated to be worth £3.6 billion, with non-surgical treatments such as Botox and dermal fillers accounting for 90% of that figure .
From 6 September 2027, certain non-surgical procedures will require a licence under the Civic Government (Scotland) Act 1982 , while others will face additional restrictions under the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026 . Together, the reforms create a more structured framework for treatments that pierce or penetrate the skin and are carried out for cosmetic or wellbeing purposes.
The changes represent a major shift for an industry that has historically sat in something of a regulatory grey area. Treatments have become increasingly sophisticated and widely available, but the rules governing who can perform them, where they can be carried out and what standards must be met have not always kept pace.
The new regime aims to change that. At the heart of the reforms is a distinction between procedures that can be managed through local authority licensing and those considered to require greater clinical oversight. Certain lower-risk treatments, including some forms of microneedling and non-ablative laser hair removal, will fall within the new licensing regime.
Higher-risk procedures, including injectable treatments like dermal fillers and botulinum toxin, will face tighter controls. These treatments will need to be carried out in specified permitted premises, such as registered independent clinics or hospitals and certain medical, dental or pharmacy settings.
For practitioners and clinic owners, this means that knowing your treatment menu inside out will become more important than ever. A procedure that could previously be offered without a specific licence may soon come with a very different compliance checklist.
Arlene Dunbar, licensing team lead at full-service law firm Gilson Gray


