Chris Dexter, partner at law firm Weightmans, discusses the Women and Equalities Committee’s call to ban high-risk cosmetic procedures and why urgent regulatory reform is needed in England.
We have been closely following the debate around cosmetic reforms. Last year, the government announced long-awaited plans to regulate the non-surgical cosmetics sector. After more than a decade of reviews, warnings and high-profile cases, it seemed that meaningful reform was finally in sight. But no progress has been made since.
The recent Women and Equalities Committee’s (WEC) report has now made clear that further delay is untenable. Its call for an immediate ban on high-harm procedures such as liquid BBLs and liquid breast augmentations reflects mounting evidence that the current framework is failing.
In the absence of robust regulation, the sector has become a wild west in which procedures have reportedly taken place in Airbnbs, hotel rooms, garden sheds and even public toilets. Individuals with as little as a 24-hour training course can carry out potentially dangerous interventions. Meanwhile, existing safeguards, such as controls on prescription-only medicines, are being circumvented or poorly enforced.
The consequences of this regulatory vacuum are not theoretical – they are reflected in the legal claims we handle and the rise in insurer-notified cases involving people who have suffered serious, and sometimes life-changing, injuries as a result. Moreover, although the NHS does not provide most cosmetic procedures, it absorbs the consequences.
A sector-wide issue
This isn’t marginal. The UK’s non-surgical aesthetics industry is worth more than £3 billion and is growing rapidly. Treatments such as Botox, dermal fillers, laser therapy and chemical peels are now commonplace, often promoted heavily through social media. Demand is increasingly driven by younger demographics, shaped in part by online beauty standards and algorithm-driven exposure.
Yet there remains no consistent legislative framework setting out mandatory qualifications or enforceable training standards for many non-surgical procedures. As the WEC put it, regulation hasn’t kept pace with the sector’s expansion.
In 2013, the then-national medical director of NHS England, Bruce Keogh, warned of the risks of under-regulation, remarking that someone undergoing a non-surgical cosmetic intervention had little more protection than someone buying a toothbrush. More than ten years on, the committee’s conclusion is stark – the only thing that has changed is the number of people experiencing complications.
The committee argues that high-risk procedures such as liquid Brazilian butt lifts should be restricted immediately to appropriately qualified medical professionals. In reality, that would amount to a near-total ban. Few mainstream clinicians are prepared to carry out such high-risk interventions, particularly outside regulated clinical settings.
The government previously proposed a tiered licensing framework under the Health and Care Act 2022, classifying procedures by risk and restricting the most dangerous treatments to regulated professionals. In principle, that structure is sensible.
The committee’s central criticism is not about the architecture of reform, but its pace. In the absence of firm timelines and visible implementation, the industry continues to operate in a space where self-regulation fills the gaps.
For high-risk procedures in particular, the committee is signalling that consultation has run its course. Immediate restriction is the only credible response to a sector where harm has already been well documented.
In contrast to England, Scotland is actively advancing reform.
Very recently, MSPs at Holyrood unanimously backed the general principles of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill. The legislation would ban non-surgical cosmetic procedures for under-18s and ensure that treatments such as Botox and dermal fillers are provided only in regulated healthcare settings – including GP surgeries, dental practices, registered pharmacies or licensed private clinics.
Crucially, the bill requires appropriately qualified healthcare professionals to oversee or carry out these procedures. It would also grant ministers powers to set enforceable standards on hygiene, safety and practitioner qualifications, alongside creating criminal offences and penalties for non-compliance.
This isn’t incremental change. It’s a clear signal that self-regulation is no longer sufficient, and that patient safety must be underpinned by enforceable standards.
The contrast with England is becoming harder to ignore.
Beyond injectables
The committee’s report goes further than procedural risk. It identifies a safeguarding gap in relation to mental health, recommending mandatory training in informed consent and psychological screening for those seeking licences to practice.
It raises serious concerns about cosmetic tourism and the strain placed on the NHS when patients return with complications from procedures performed abroad. It calls for systematic recording and annual publication of data on such cases, to quantify the cost and improve public awareness.
It also urges stronger data collection in relation to breast implants, including mandatory recording of implant and explant procedures and improved post-market surveillance.
Taken together, these recommendations point to a common theme – patient safety must be embedded systemically, not reactively. The fact that insurance firms are actively commenting on regulatory reform is strong evidence of systemic risk concerns.
This isn’t about demonising aesthetics. Most practitioners want clear, enforceable standards that reduce harm and create a level playing field.
The government signalled intent last year, and the WEC’s report has now amplified the urgency. With Scotland progressing with its reforms, England must decide whether it intends to follow suit.
In a billion-pound sector carrying real medical risk, delayed regulation could be seen to cause unnecessary risk to patients and damage trust. Licencing would raise standards, cut complaints and claims, and lower premiums. Early movers won’t just be compliant, they’ll be safer and commercially stronger than those scrambling to catch up.
