England's licensing scheme for non-surgical cosmetic procedures is built around three risk tiers: Red, Amber and Green. Red procedures are restricted to registered healthcare professionals in CQC-regulated premises. Amber procedures, including botulinum toxin and facial dermal fillers, require a local authority licence and oversight from a named healthcare professional. Green procedures, such as microneedling and chemical peels, require a local authority licence only. The Department of Health and Social Care confirmed this model in August 2025.
What the three-tier model is and where it comes from
The Department of Health and Social Care published its formal response to the licensing consultation on 7 August 2025, confirming a three-tier risk classification for non-surgical cosmetic procedures in England. The statutory basis is section 180 of the Health and Care Act 2022, which gave the Secretary of State powers to make regulations introducing a licensing regime. The House of Commons Library briefing on cosmetic procedure regulation traces the legislative history from the Keogh Review onward: the same period during which the sector operated with no minimum training requirements, no centralised registration, and no statutory oversight of who could pick up a syringe.
The three-tier model is how those regulations will be structured when the secondary legislation is made. The classification rests on clinical risk. What determines a procedure's tier is the level of harm that is possible when something goes wrong, not the practitioner's professional background. That matters because it changes the logic of the whole scheme. Tier is a property of the treatment, not of the person delivering it.
Red tier: highest-risk procedures and CQC regulation
Red-tier procedures carry the highest clinical risk. Under the confirmed framework, they will be restricted to regulated healthcare professionals and brought within Care Quality Commission (CQC) regulation, meaning they can only be delivered in CQC-registered premises.
The clearest example from the government's consultation response is the liquid Brazilian butt lift. Procedures involving dermal filler in the breasts or genitals fall into the same category. These are procedures where the risk of serious harm, including vascular events or embolism, is considered high enough that only practitioners regulated by a statutory body, with clinical oversight infrastructure in place, should be delivering them.
For practitioners working in mainstream facial aesthetics, Red-tier restrictions will not change day-to-day practice. The Red tier is not where the operational questions sit for most of the field.
Amber tier: botulinum toxin, dermal fillers and medium-risk treatments
Amber tier is where most of the practical questions concentrate, because botulinum toxin and facial dermal fillers sit here.
Under the August 2025 confirmation, Amber-tier procedures will require two things:
- A local authority licence for the practitioner or premises (the precise licensing unit is still being confirmed in secondary legislation)
- Oversight from a named regulated healthcare professional for non-healthcare practitioners
That second requirement is significant. A beauty therapist or non-medical aesthetic practitioner will not be able to administer botulinum toxin or facial dermal fillers independently under this scheme. They will need a named, registered healthcare professional providing clinical oversight. What that oversight entails in practice, how it is documented and audited, is subject to further detail in secondary legislation.
Regulated healthcare professionals, including nurses, doctors, dentists, and pharmacist prescribers, can deliver Amber-tier procedures independently, provided they hold the required local authority licence and meet the competency standards expected under the scheme.
Existing competency frameworks from the JCCP and the Cosmetic Practice Standards Authority have been cited by the government as reference points for the training and competency evidence practitioners will need to demonstrate when applying for an Amber-tier licence. Practitioners who already meet these standards will be better placed when the licensing infrastructure is in place.
It is also worth noting that Amber procedures do not change the medicine regulation picture. Botulinum toxin remains a prescription-only medicine regulated by the MHRA, and the prescribing rules, including the face-to-face assessment requirement introduced in June 2025, apply independently of the tier model.
Green tier: microneedling, chemical peels and lower-risk procedures
Green-tier procedures are those carrying lower clinical risk. Microneedling, chemical peels, and similar treatments fall into this category under the proposed classification.
Green-tier procedures will require a local authority licence, but not the named HCP oversight that Amber procedures require. Any practitioner who meets the agreed competency standards and holds the appropriate licence can deliver Green-tier treatments.
That said, the phrase "agreed standards" is doing real work here. One purpose of the licensing regime is to end the situation, documented in the House of Commons Library briefing, where there are no minimum competency requirements before a practitioner delivers cosmetic procedures. The Green tier is not an unregulated space. It is a regulated space with a lighter oversight model. Licensure still has to be obtained and standards still have to be met.
Where implementation stands now
The government confirmed the three-tier model in August 2025. As of mid-2026, no statutory instrument has been laid to bring the scheme into force. The DHSC has signalled a further consultation on the secondary legislation, covering the precise scope of each tier, which treatments fall into each, and the mechanics of local authority licensing.
The July 2026 overview published here sets out the wider staging context. July 2026 is a significant marker in the rollout, not a switch-on moment. Green and Amber licensing frameworks are expected to follow in 2027. Red-tier expansion of CQC regulation is on a similar timetable.
This is not an argument for inaction. Practitioners who wait for a statutory instrument before considering their training, insurance, oversight arrangements, and documentation standards will be behind when the licensing infrastructure arrives. The direction of travel has been set and confirmed. The detail is being finalised.
What this means for your practice now
Three things follow directly from the tier model for practitioners working in England.
Know which tier your treatments fall into. Botulinum toxin and facial dermal fillers are Amber. That means a local authority licence plus a named HCP arrangement for non-healthcare practitioners, or independent delivery if you are a registered healthcare professional. If you are a non-medical practitioner delivering these treatments, the question to answer now is: who is your named HCP, and what does that oversight relationship look like in practice?
Your registration status matters more under this scheme than it has before. NMC, GMC, GDC, and GPhC registrants face different requirements to non-registrants across both the Amber and Red tiers. Understanding where you sit is a precondition for working out what you need to do.
The tier model does not sit in isolation. It maps alongside MHRA medicine regulation, CQC registration thresholds, and the professional standards set by the JCCP and CPSA. These frameworks overlap. Getting one right while ignoring the others is not a compliant position.
The regulation page on this site sets out the full landscape, including where each regulatory body's remit begins and ends.
From Regulation to Reputation™ is £200 off until 20 July, at £299 instead of £499 with code REG299. The course is the structured programme built on Bernadette's book, Regulation to Reputation: mastering successful aesthetic practice, and takes practitioners through the compliance landscape in full before the licensing scheme tightens further.
FAQ
Which treatments are in the Amber tier?
Botulinum toxin injections and facial dermal fillers are confirmed Amber-tier procedures under the government's August 2025 consultation response. Other medium-risk injectable treatments are expected to fall into this tier as secondary legislation is finalised. The government has not yet published an exhaustive procedure list.
Can a beauty therapist still administer Botox and filler under the new scheme?
A non-healthcare practitioner can deliver Amber-tier procedures, but only with a local authority licence and oversight from a named regulated healthcare professional. Independent delivery by a non-registrant is not permitted under the confirmed model.
Is the licensing scheme in force now?
No statutory instrument has been laid to bring the scheme into force as of mid-2026. The government confirmed the three-tier model in August 2025 and has indicated further secondary legislation consultation during 2026. Green and Amber licensing frameworks are expected to come into force during 2027.
Do I need a licence for microneedling under the new scheme?
Microneedling is expected to fall into the Green tier, which will require a local authority licence. Named HCP oversight is not required for Green-tier procedures. Until the statutory instrument is made, the licensing scheme is not yet in force, but the direction is set.
Does this scheme apply outside England?
Section 180 of the Health and Care Act 2022 gives the Secretary of State for England the power to make regulations. Scotland, Wales, and Northern Ireland have separate devolved competences. Scotland is pursuing its own legislative route through the Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
What are the competency standards I need to meet?
The DHSC has cited the JCCP and CPSA frameworks as reference points. These cover training level, clinical competence, indemnity, and practitioner registration. The precise standards required for each licence tier will be confirmed in secondary legislation. Practitioners working toward JCCP registration and Level 7 qualification are positioning themselves well for the Amber tier.