352 Scottish aesthetics premises may need licensing or regulatory review under new cosmetic procedure rules

New analysis raises questions over whether Scotland is operationally ready to identify, classify and enforce against the full universe of premises likely to fall within the incoming regime

A new analysis has identified 352 premises in Scotland that may need to be assessed for licensing, registration or compliance action under Scotland’s incoming non-surgical procedures framework.

The finding raises a practical question for regulators and local authorities: is Scotland ready to identify, classify and enforce against the full universe of premises likely to fall within the new regime?

The Scottish Parliament has now passed the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill at Stage 3, while the Scottish Government has also laid the draft Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026. Together, these measures create a split framework in which some procedures will need to take place in licensed premises, while others will need to be delivered in registered healthcare settings.

That means the challenge is no longer only legislative. It is operational.

Authorities will need to:

identify the premises operating in their area
determine which providers fall into the licensing system and which fall into the healthcare-regulated system
detect operators advertising procedures online who may not be visible through traditional local intelligence
prioritise inspection and enforcement resources accordingly

Peter Langdon of TreatCompare said:
“The policy direction is now clear. The harder question is operational readiness. If hundreds of premises may need to be reviewed against Scotland’s new framework, regulators and local authorities will need far better licensing intelligence and local compliance detection than a static list or complaints-led model can provide.”

“This is not just about whether the law exists on paper. It is about whether Scotland can identify who is operating, where they are operating, and whether they fall into the licensed side of the framework or the healthcare-regulated side.”

The analysis suggests that the key pressure point may not be policy design, but market visibility and enforcement capacity.

Many providers promote treatments through websites and social platforms rather than through clearly categorised healthcare or beauty premises records, making the market harder to map in real time. That creates a risk that the new regime could be strong in principle but patchy in practice unless authorities have access to better local intelligence.

TreatCompare said the issue is not simply one of headline regulation, but whether Scotland has the practical infrastructure to support:

licensing intelligence
local compliance detection
provider discovery
inspection triage
targeted enforcement

Under the Scottish Government’s model, lower-risk procedures are expected to sit within a local authority licensing framework, while higher-risk procedures and settings fall within the Healthcare Improvement Scotland regulatory system.

ENDS

Notes to editors

TreatCompare analysis identified 352 premises in Scotland that may require review under the incoming non-surgical procedures framework.
This figure refers to premises that may need to be considered for licensing, registration, or compliance assessment under the new regime. It does not imply that each premises is currently acting unlawfully.
The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill completed Stage 3 on 17 March 2026.
The Scottish Government has said the draft Licensing of Non-surgical Procedures Order 2026 has been laid to complement the Bill by introducing a licensing scheme for procedures not regulated by the Bill.
The Scottish Government has also said the Bill will help ensure higher-risk procedures are carried out in appropriate registered settings and that Healthcare Improvement Scotland will be able to inspect premises where there are reasonable grounds to believe an offence is being committed.

Media contact:
Peter Langdon
TreatCompare
data@treatcompare.com