Professional indemnity explained

New cosmetic procedure restrictions 2026: what aesthetics practitioners need to know

Reviewed by the Apex broking team · Last reviewed 2026-10-31

The 2026 cosmetic procedure restrictions are Department of Health and Social Care proposals to limit high-risk cosmetic and wellbeing procedures in England to specified healthcare professionals. They would change who can lawfully treat, and therefore what insurers will cover.

Part of: Professional indemnity insurance

In short

On 21 October 2026 the Department of Health and Social Care opened a consultation on restricting high-risk cosmetic and wellbeing procedures in England. Non-surgical high-risk procedures would be limited to doctors, dentists and independent prescribing nurses, midwives and pharmacists; cosmetic surgery, including liquid BBL, to doctors. Procedures would be restricted to people aged 18 and over, with exceptions, and providers would need CQC registration. The consultation closes at 11:59pm on 13 January 2027. Practitioners should review which treatments they offer and whether their insurance assumes the current rules.

What has been announced?

The Department of Health and Social Care published a DHSC consultation titled "Restrictions on the performance of high-risk cosmetic and wellbeing procedures in England" on 21 October 2026. It applies to England and closes at 11:59pm on 13 January 2027. A draft statutory instrument, the Health and Social Care Act 2008 (Regulated Activities) (Amendment) (No. 2) Regulations 2026, is published with it.

These are proposals. The consultation document says there will be a transitional period for CQC registration applications, after which the restrictions come into force, and that timings will be finalised once the regulations complete the parliamentary process. Nothing changes the day the consultation opened, but practitioners who would fall outside the proposed list need time to plan.

The proposals in summary

Area	What the consultation proposes
Procedures in scope	Cosmetic surgery (including fillers anywhere other than the face, such as liquid BBL); deep chemical peels; dermal microcoring; subcision; non-resorbable facial fillers; intravenous cosmetic or wellbeing procedures; specified lasers and intense pulsed light, including on the eyelid or periorbital rim; procedures with a separate anaesthetic injection; and products derived from human blood or plasma, such as PRP
Who may perform non-surgical high-risk procedures	Doctors, dentists, and independent prescribing nurses, midwives and pharmacists
Cosmetic surgery	Doctors only
Age	Restricted to people aged 18 and over, with exceptions for NHS care and for healthcare professionals treating a medical condition
Registration	Providers would need CQC registration for new regulated activities covering cosmetic surgery and non-surgical cosmetic and wellbeing procedures
Enforcement	Proposed offences for allowing an unapproved person to perform a procedure or treating someone under 18, with fixed penalties for providers and registered managers; operating a regulated activity without registration is already an offence

Botulinum toxin and resorbable facial dermal fillers are not on the high-risk list. They remain subject to the Botulinum Toxin and Cosmetic Fillers (Children) Act 2021, which already makes it an offence to give these treatments to under-18s in England for cosmetic purposes.

Where the licensing scheme fits

The new restrictions are separate from the licensing power in section 180 of the Health and Care Act 2022, headed "Licensing of cosmetic procedures". That section lets the Secretary of State introduce a licensing scheme by regulations to reduce the risk of harm to the public, and it came into force on 1 July 2022.

The October 2026 consultation document refers back to the 2023 consultation, which proposed green and amber tiers for lower-risk treatments. It says licensing of high street treatments will subsequently follow. No date is given. In practice, this means two regimes are coming: CQC registration and professional restrictions for the highest risk procedures, and a licensing scheme for practitioners and premises offering lower-risk treatments such as toxins and fillers.

What it means for insurance

Aesthetics insurance is usually built around a treatment list and a description of who performs each treatment. If the law changes who may lawfully perform a procedure, cover is likely to follow the law. Points to expect, subject to each insurer's terms:

Treatment lists will be reviewed. Policies for non-medical practitioners may stop offering high-risk procedures once the restrictions take effect, and most policies exclude work that is unlawful or outside the practitioner's qualifications.
Clinics will need provider-level cover. A business registering with the CQC carries liabilities beyond the individual practitioner's treatment risk. See what CQC registered providers need and aesthetic clinic insurance.
Healthcare professionals may take on more work. Doctors, dentists and prescribers who add procedures should declare them. Dentists should read indemnity for dentists.
Age checks matter. Proof of age and consent records will be central to defending claims and regulatory action.
Past treatments still count. If you stop offering a procedure, claims about earlier treatments may arrive later. Claims made policies may need run-off cover.

Treatment risk sits within medical malpractice insurance; our guide to aesthetic PI explains the main policy terms.

Illustrative examples

These examples are illustrative only and do not describe real cases.

Example 1: the non-medical injector offering IV drips. A beauty therapist offers vitamin drips and PRP. Under the proposals both would be restricted to specified professionals. Once the rules take effect, the therapist would need to stop, or work in a CQC registered setting where an approved professional performs the procedure.
Example 2: the nurse prescriber's clinic. An independent prescribing nurse runs a clinic offering laser treatment around the eyes. The nurse would be an approved professional, but the clinic would need CQC registration and a policy covering the business as well as the individual.
Example 3: the 17 year old client. A clinic treats a client who claims to be 18. The proposals would make treating under-18s an offence for high-risk procedures, and a claim may be harder to defend without age verification records.

Common misunderstandings and what to do now

"The rules apply now." They are proposals until the regulations pass and the transitional period ends.
"Toxins and fillers are banned for non-medics." Not under this consultation; they are expected to fall under the later licensing scheme.
"My insurance will adjust automatically." It will not; tell your broker which treatments you offer and who performs them.

Map each treatment you offer against the high-risk list.
Respond to the consultation before 13 January 2027 if it affects you.
Check your policy treatment list, age and consent requirements, and any exclusion for unlawful acts.
If you plan to register with the CQC, review business cover early. See also work outside your declared business description and the AIpedia for aesthetics.

Apex arranges professional indemnity and treatment risk cover for aesthetics practitioners and clinics; a broker reads every enquiry.

Sources

Frequently asked

When do the new cosmetic procedure rules start?

No start date has been set. The DHSC consultation opened on 21 October 2026 and closes at 11:59pm on 13 January 2027. The government says there will be a transitional period for CQC registration, with timings finalised once the regulations complete the parliamentary process.

Will non-medical practitioners still be able to give Botox and fillers?

Botulinum toxin and resorbable facial fillers are not on the proposed high-risk list. They are expected to be covered by a separate licensing scheme under section 180 of the Health and Care Act 2022, for which no date has been announced. Treating under-18s is already an offence.

Who would be allowed to perform high-risk non-surgical procedures?

Under the proposals, doctors, dentists, and independent prescribing nurses, midwives and pharmacists. Cosmetic surgery, including liquid BBL, would be restricted to doctors. Providers would also need to register with the Care Quality Commission.

Will my aesthetics insurance still cover restricted treatments?

Probably not, if you are not an approved professional once the rules apply. Most policies exclude work that is unlawful or outside your qualifications, and insurers are likely to update treatment lists. Speak to your broker before the rules take effect.

Do the restrictions apply in Scotland, Wales or Northern Ireland?

This consultation covers England. The devolved nations make their own arrangements, and Scotland is taking forward its own legislation on non-surgical procedures. Check the rules where you practise rather than assuming the English proposals apply.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not advice on your individual circumstances, and it does not guarantee that cover will be available or on what terms.