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Not just doing it: the government wants arranging it to be an offence too

Qurexa Editorial Team4 November 20266 min read 0 0
Not just doing it: the government wants arranging it to be an offence too

What happened

The Department of Health and Social Care (DHSC) is running a consultation on new rules for high-risk cosmetic and wellbeing procedures in England. It opened on 21 October 2026 and closes at 11:59pm on 13 January 2027. On 2 November 2026, DHSC updated part of that consultation. The change is small in wording but important in effect. The consultation includes a proposed criminal offence relating to high-risk procedures being performed on people under the age of 18. The update makes clear that the offence would also cover making arrangements for such a procedure, or allowing someone else to make arrangements for it. In other words, the proposal is not only aimed at the person holding the needle. It would also reach people who set the appointment up. DHSC has said the draft regulations themselves have not changed, and that because the question has not materially changed, answers submitted before 2 November 2026 will still count towards the government's response. The wider proposal is that high-risk cosmetic and wellbeing procedures, including cosmetic surgery and certain injectable and laser treatments, should only be carried out by specified, qualified healthcare professionals. Under the plans, these would be doctors, dentists and independent prescribing nurses.

Why this matters

At the moment, the rules around cosmetic procedures in England are patchy. Some treatments that sound medical are not restricted to medically trained people at all. Someone can complete a short course and start injecting members of the public. If something goes wrong, the person who had the treatment may have very little protection. That gap has produced a steady flow of harm stories: lumps, infections, scarring, blocked blood vessels, and in the worst cases damage to eyesight. When a procedure goes badly, it is often the NHS that picks up the repair work. The under-18 element matters for an extra reason. Young people are the group most exposed to online beauty pressure and the group least able to give properly informed consent about a permanent change to their face or body. An offence that only covered the person performing the procedure would have an obvious hole in it. A practitioner could claim they believed an adult had arranged everything. Extending the offence to arranging it, or allowing someone else to arrange it, closes that hole. There is also a practical reason to care about who holds the needle. Some of the substances used in these treatments are prescription-only medicines. Prescribing them properly means a qualified prescriber assessing the person first. That is exactly the standard the proposals are trying to lock in.

What the evidence actually says

It is worth being precise about the status of all this, because headlines often get it wrong. This is a consultation, not a law. Nothing has been banned yet. The government is asking for views, and it will publish a response afterwards. The draft regulations attached to the consultation could still change before anything reaches the statute book. It also applies to England. Health is devolved, so Scotland, Wales and Northern Ireland set their own approach. What the government is proposing is a restriction based on professional registration: that high-risk procedures should be performed only by doctors, dentists and independent prescribing nurses. That is a meaningful change from the current position, where many of these treatments sit largely outside clinical regulation. On the harms themselves, the evidence base is genuinely imperfect. There is no single national register that records every complication from a cosmetic injectable, which means nobody can give you a reliable national total. What exists instead is a large body of clinical case reports, professional body warnings, and NHS clinicians describing a pattern of avoidable injuries. That is strong enough to justify action, but it is not the same as a precise number, and anyone quoting one should be asked where it came from. The honest summary: the direction of travel is clear and well supported, the exact scope is still being settled, and the timetable means any new rules are some way off.

Practical advice

If you are thinking about a cosmetic procedure now, under the current rules, there are sensible checks you can make. Ask who is actually carrying out the treatment, and what their clinical registration is. A registered doctor, dentist or nurse can be looked up on a public register. If someone cannot tell you clearly what they are registered with, that is an answer in itself. Ask what the substance is and whether it is a prescription-only medicine. If it is, ask who prescribed it and whether that person assessed you personally. Ask what happens if something goes wrong. Who treats a complication? Is there insurance? Is there a number to ring out of hours? A good practitioner will have ready answers. Be wary of pressure. Time-limited discounts, group deals and treatments offered at parties all push people into decisions they have not thought through. Nothing about your face needs deciding this afternoon. If you are under 18, the clear professional advice is to wait. Your face is still changing, and the proposals in this consultation exist precisely because this is seen as the wrong age for permanent decisions. If you have had a procedure and something is wrong - swelling that is getting worse, skin turning white or grey, severe pain, or changes to your vision - treat it as urgent. Contact the clinic, and get medical help through NHS 111 or A&E. Do not wait it out. If you want to influence the rules themselves, the consultation is open until 13 January 2027 and anyone can respond.

What to know

DHSC is consulting on restricting high-risk cosmetic and wellbeing procedures in England to doctors, dentists and independent prescribing nurses. The consultation closes on 13 January 2027. On 2 November 2026, DHSC clarified that a proposed offence about performing high-risk procedures on under-18s would also cover arranging one, or allowing someone else to arrange it. The draft regulations have not changed, and responses submitted before that date still count. This is a proposal, not a law, and it applies to England only. Until rules change, check your practitioner's clinical registration, ask what is being injected and who prescribed it, and never let a discount set your timetable. Treat worsening swelling, severe pain, skin colour changes or vision changes after a procedure as an emergency. Sources: Department of Health and Social Care, "Restrictions on the performance of high-risk cosmetic and wellbeing procedures in England", consultation published 21 October 2026, last updated 2 November 2026, https://www.gov.uk/government/consultations/restrictions-on-the-performance-of-high-risk-cosmetic-and-wellbeing-procedures-in-england; GOV.UK, "Department of Health and Social Care - Activity on GOV.UK", accessed 4 November 2026, https://www.gov.uk/government/organisations/department-of-health-and-social-care This article is for general information and does not replace advice from a doctor, pharmacist or other qualified healthcare professional.

#cosmetic procedures#patient safety#consultation#DHSC#regulation#young people

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