Do you need a licence to give Botox injections?

Botox and lip fillers are no longer a treatment for the rich and famous. Over the years, injectables have become incredibly popular and widespread in the UK. Even people in their teens and 20s are choosing to pre-empt their wrinkles.

A permanently youthful look at little cost has been made achievable by modern cosmetology, and plenty are taking the opportunity. For many, popping in for an injectable is as normal as nipping to the hairdresser or nail bar.

Botox and dermal fillers are the most popular non-surgical treatments in the UK. And considering they mostly involve injecting substances into the face and neck area, you’d assume there’d be some sort of licence needed to give them. But in fact, there isn’t. Not yet anyway.

69% of all complaints received by the government-approved aesthetics registration board SaveFace last year were about botched dermal fillers. Botox injections followed closely behind. So, it’s hardly surprising the government are looking to make a change…

Giving the law a facelift

In 2022, an amendment was made to the Health and Care Bill. It allows the health secretary to introduce a licensing scheme for practitioners who carry out non-surgical procedures in England. The Scottish government has plans to do the same, and seems to be a little further along than their English counterparts.

So, a Botox licensing scheme is on its way. There’s no timeline in place just yet, but it’s a good idea to keep checking in, so you have time to prepare.

By introducing a licence to give Botox injections, the government and aesthetics industry together hope to raise standards where needed, protect the public, and create a more professional structure.

What will I need to get a licence for Botox injections?

The scheme will mean that all practitioners offering Botox, dermal fillers, and other non-surgical procedures that penetrate the skin beyond the dermis, will need a licence.

The UK Parliament’s Health and Social Care Committee released a report in 2022 and made several suggestions that are likely to form some of the rules for the new scheme.

The Scottish government also launched a public consultation in December 2024 and made their own suggestions for proposed regulation. Many of these are similar to England’s, but there are some differences.

Nothing’s set in stone yet, so we don’t know exactly what the criteria in the rest of the UK will be for obtaining a licence. But, at the very least, you’re likely to have to prove you have the following things:

• A recognised qualification (we still don’t know exactly what qualifications you’ll need)
• Appropriate premises
• Adequate insurance cover.

The Parliamentary report also suggested a two-part consent process for patients, giving them a 48-hour cooling-off period between consultation and treatment.

Scotland’s suggestions include a potential three-tier system, which would categorise procedures into different groups.

Depending on what you offer, you’d be required to have a license for both yourself and your clinic. It would also restrict the procedures you could do at your clinic, with some requiring them to be undertaken at a Healthcare Improvement Scotland (HIS)-regulated premises ie a hospital or other healthcare facility.

It's well worth reading what Scotland are proposing for non-surgical procedures. If your business is based there, it could have a big impact on you as early as 2025.

If they do end up bringing these rules into force, it could also be a signal of things to come for elsewhere in the UK.

When will the licence to give Botox be introduced?

In February 2023, the government rejected all calls from MPs asking for an immediate introduction of the licensing scheme.

The government insisted they were still committed to introducing the licence. But said that they wouldn’t be able to bring it in as quickly as was being called for, because of the amount of work involved.

In a detailed response to the Health and Social Care Committee’s report, the government said they’d have a plan together for the licensing scheme by July 2023.

Obviously, it’ll take some time for those plans to go through Parliament. So, we’re probably looking at 2024 or later before the licence is officially introduced.

Unfortunately, as of April 2025, there’s been no further progress from the government. This is probably due to the new Labour government wanting to review their position on non-surgical cosmetic procedures before moving forward.

More to the point…

You might not need a licence to give Botox or dermal filler injections yet, but that doesn’t mean there aren’t any regulations.

Botox is a prescription drug. So, it must be prescribed by a medical professional. If you’re a non-medic administering Botox, under General Medical Council, Nursing and Midwifery Council, and General Dental Council rules, you’ll need to have a doctor, dentist, pharmaceutical prescriber, or nurse prescriber present at every pre-consultation with your clients.

Although the medical professional prescribing it doesn’t have to give the injection themselves, they do hold a certain amount of responsibility. It’s down to them to decide whether the person administering it is qualified and experienced enough.

Unlike Botox, dermal fillers are a non-prescribed drug. So, there are fewer regulations. Currently, anyone can legally perform them.

It’s illegal to inject anyone under the age of 18 with Botox, or fillers of any kind. Remember too, that there are strict rules about advertising Botox injections.

How to be a smooth operator

Botox is pretty powerful stuff and adding it to your roster of treatments is a decision that shouldn’t be taken lightly.

So really, whether you need a licence to give Botox injections shouldn’t be the question you ask. What you really need to think about is - how can I offer Botox injections and lip fillers to clients safely?

The most important thing is that you put the physical and mental wellbeing of your clients first.

Would does that mean, exactly?

Here are a few tips on how to follow good practice and ensure your clients’ safety, as well as your own:

• Make sure you have the proper training and practical experience to offer these treatments
• Consent – make sure you give clients a detailed consent form that outlines all the specific risks
• Have a full consultation with your client and ask for a full medical history before the procedure
• Offer a cooling-off period
• Make sure the procedure room is clinical and maintains clients’ dignity and privacy
• Log detailed reports for each client
• Take pre and post photographs
• Offer a follow-up appointment.

There are plenty more detailed guidelines for administering Botox and dermal fillers in this Cosmetic Standards report.

Don’t raise any eyebrows

Getting medical malpractice insurance is an absolute must if you’re injecting Botox or dermal fillers. Because even the most qualified practitioners can find themselves under scrutiny. Besides which, it seems likely that once the licensing scheme is finally up and running, professional insurance will be a requirement.

Things can go wrong. And when they do, clients can be left physically and mentally scarred. From allergic reactions to muscle weakness, although rare, side effects from Botox injections and fillers can be serious. So, getting the right level of insurance is the responsible thing to do.

Find out more about Botox and dermal fillers insurance, or call 0345 222 5391 to speak to a friendly adviser.

Image used under licence from Shutterstock.