The cosmetic licensing scheme explained: green, amber and red

GREEN — lower risk. Treatments such as microneedling and non-ablative laser hair removal. Practitioners would need a licence, with requirements proportionate to the risk.

AMBER — medium risk. This is where anti-wrinkle injections and semi-permanent dermal fillers into the face sit. A regulated healthcare professional could perform these without supervision, provided they meet the agreed standards. A non-healthcare practitioner would need a licence and supervision by a named regulated healthcare professional who holds an accredited qualification to prescribe, administer and supervise.

RED — highest risk. Procedures such as breast, genital and buttock augmentation. These would sit under Care Quality Commission regulation and could only be performed by a regulated healthcare professional in a CQC-registered setting.

Almost everything the public thinks of as 'aesthetics' lands in amber. It is also the only tier where the proposal draws an explicit line between a regulated healthcare professional and everybody else, and attaches a practical consequence to it — unsupervised practice on one side, licensed and supervised practice on the other.

That is the first time UK policy has put the nurse-led distinction into a document with legal intent behind it. Until now it has been a marketing claim that clinics make about themselves. Under the proposal it becomes a structural difference in what you are permitted to do alone.

It is worth being precise about what it would and would not mean. Performing without supervision is not the same as prescribing. A nurse who is not an independent prescriber would still need a prescriber to assess each patient before a prescription-only medicine could be used, licensing scheme or not.

SETTLED: the power to create the scheme exists in the Health and Care Act 2022. The consultation ran and the government responded on 7 August 2025. The direction — a risk-tiered licence, with the highest-risk procedures restricted to regulated professionals in regulated settings — is clear.

NOT SETTLED: the amber and green tiers require secondary legislation and a further consultation before they take effect. The government has indicated the initial work will prioritise restrictions on high-risk procedures. Which specific treatments end up in which tier can still move, and the qualification standards attached to each are not final.

So the honest position today is: nothing in the green or amber tiers is in force, no date has been fixed, and any practitioner presenting the amber rules as current law is either mistaken or hoping you will not check.

Treating under-18s for a cosmetic purpose with filler or anti-wrinkle injections has been a criminal offence in England since 1 October 2021, and so has arranging such an appointment. That is settled law, not a proposal.

The prescription-only status of the substance used in anti-wrinkle injections is medicines law and already applies. It is why a prescriber must assess you.

Local authorities already have their own registration requirements for some skin-piercing style activities, which vary by council and sit underneath any national scheme.

Nothing urgent. But it does give you a useful question with a clear answer: ask a clinic where they expect to sit under the licensing scheme, and why. Someone who has read the consultation response will tell you plainly. Someone who has not will change the subject.

And it reframes the check that is already worth doing. If the direction of travel is towards regulated healthcare professionals practising unsupervised and everyone else being supervised, then finding out which of those your practitioner is has moved from a preference to something the state is preparing to formalise.

The scheme is a consultation response, not a law. This is what each part of it currently is.

The bottom two rows are the ones worth separating out, because they are routinely quoted as though they were part of the scheme. They are not — they are already in force, and they are the only parts of this that currently protect you.