Non-Surgical Procedures Bill (Scotland)
Keeping the Community Updated on Developments in Skin Treatment Regulations
Things are slowly taking shape in Scotland on the new rules. This is a look at what is happening and what you should be thinking about as the deadline inches closer. (November 2026)
Local authorities will be releasing their applications in the new year to help with the anticipated high demand. Any provider who has successfully applied before September 6th 2027 will be able too continue working in the licensed areas while the local authority gets round to processing their application. If you haven't applied you will be operating illegally .
In order to apply you need to have possession (not pending) of the relevant certificates. You must also have relevant insurance for the treatments on offer as part of your application form. Only then can you submit to the council
[have VTCT Certificates in hand] --> [get specialist insurance] --> [Submit to council]
Phase 1: The Training Audit (Immediate Action)
Because the framework transitions from "CPD certificates" to "Ofqual-regulated qualification mapping," you must audit your team’s qualifications immediately.
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Step 1: Check the Core Anchor: Ensure the lead practitioner holds a multi-modality master qualification like the VTCT Level 4 Certificate in Advanced Aesthetic Therapies for Skin Rejuvenation (BT4C16). This single qualification covers the following:
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Unit 4 (Needling) covers your microneedling up to 1.5mm.
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Unit 5 (Peeling) covers your superficial chemical peels.
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Units 1–3 (Skin Science/Consultation) cover your advanced facials.
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Step 2: Identify the Exemptions: Standard non-invasive facials (such as basic steaming, hydration facials, and manual massage) do not pierce or destroy tissue. These require no extra licensing and can be assigned to Level 2 or 3 therapists.
Phase 2: Operational & Treatment Parameter Alignment
Align your everyday salon operations with the strict legal thresholds of the Group 1 category to avoid being pushed into higher clinical tiers.
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Step 1: Lock the Needle Depth: Audit your microneedling pens or rollers. Update your treatment protocols to ensure needles are strictly set to under 1.5mm. Going to 1.5mm or deeper reclassifies the treatment as a clinical procedure.
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Step 2: Audit Chemical Peel Stocks: Check the Material Safety Data Sheets (MSDS) for your peel brands. They must be strictly superficial (affecting only the epidermis). If you use clinical-grade peels that require prescription-strength neutralisers, remove them from your high-street menu.
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Step 3: Remove Prescription Numbing Creams: Ensure your salon only uses over-the-counter topical anaesthetics. If a treatment requires prescription numbing cream, it automatically defaults out of a Group 1 local authority licence.
Phase 3: Physical Premises Upgrades
Local authority environmental health teams from councils will inspect your physical space before granting your licence.
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Step 1: Clinical Waste Infrastructure: Secure a commercial contract with a licensed medical waste provider. You must have designated yellow sharps bins for your microneedling cartridges and separate hazardous waste bins for chemical peel neutralizing wipes.
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Step 2: Hand Hygiene Stations: Every room where needling or peeling takes place must have a dedicated hand-washing sink with non-touch taps, liquid antibacterial soap, and paper towel dispensers.
Phase 4: Administrative & Council Submission (Early to Mid-2027)
Prepare your application paperwork to secure your mandatory dual licences.
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Step 1: Draft the "Challenge 25" Policy: Draft a written age-verification policy. Group 1 treatments are strictly prohibited for anyone under 18. Your staff must be trained to log ID checks for anyone appearing under 25.
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Step 2: Apply for the Dual Licence: Submit two distinct applications to your local council:
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The Premises Licence: To certify the physical salon space is safe.
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The Practitioner Licence: A personal licence for each individual employee who will use a needling pen or chemical peel brush.
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Step 3: Present the Compliance Portfolio: Organize your application folder with your VTCT certificates, your commercial waste contract, your age-verification policy, and your treatment protocol logs neatly tabbed.
Phase 5: Enforcement Go-Live (6 September 2027)
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Final Step: Display your physical Local Authority Aesthetic Licences clearly in your salon reception window. Your insurance provider will require copies of these certificates to maintain your public and professional liability coverage.
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Of course councils are going to be well behind in processing applications so your will need to have your application in early to be allowed to continue working those treatments while the council deal with the backlog.
THE BILL
The Scottish Non-Surgical Procedures Bill has been passed (March 2026) and became an Act of Law on May 12th 2026. Business will have until 2027 to become licensed.
Group 1 covers treatments listed overleaf and will be administered by Local Authorities. Treatments will have to be undertaken by a licensed practitioner in licensed premises.
Authorities will consider applications based on 3 main criteria - Qualifications - does the practitioner have an Ofqual regulated certificate in the treatment
Insurance - does the business have professional Indemnity Insurance cover for the treatment concerned. To get insurance cover the practitioners will require to have Ofqual certification.
Premises & Person - Does the premises pass the required hygiene requirements. Is the equipment used CE compliant. Are the business owner and practitioners Fit & Proper.
*Ofqual regulate awards bodies such as VTCT, Qualifi and SQA to deliver appropriate courses through schools like Erasure Skin Academy in Glasgow
GROUP 1
The Government has determined that treatments which break the skin or impart energy via heat, cold, laser, electricity, sound, chemicals or medicines may fall under Group 1 restrictions.
These treatments are considered significantly risky and therefore can be in Group 1. They do NOT require a Health Improvement Scotland (HIS) regulation and/or medical supervision so are not in Group 2 or 3.
Treatments such as Massage, Make-up, nail treatments and hair treatments are low risk and do not require licensing. Microneedling up to 1.5mm depth will be within Group 1 with deeper treatments being in Groups 2 or 3. Similarly, Chemical Peels that penetrate deeper that the Epidermis will be in Group 2 or 3.
Lasers that are Ablative are outside Group1 but Laser hair removal and tattoo removal remain in Group 1.
The Scottish Government has applied these restrictions to improve client safety, reduce complications.
It is not currently clear why aromatherapy or hair dyes are not included in the chemicals category.
ARE YOU AFFECTED?
Anyone who delivers the Group 1 listed treatments will be required to conform to the regulations and get licensed, insured and checked. This means if you are working from a Salon, Hairdressers, Clinic, Barbers, Spa, work from home, Garden room or are mobile you will be need to follow the Group 1 treatments rules.
As mentioned the premises need to have the environmental health requirements, so having suitable hot water and washing facilities, fire safety features, COSHH, Health & Safety. In addition each practitioner who delivers a particular treatment needs to have their own practitioners license, one does not cover all.
For those who provide treatments in multiple locations, perhaps at different salons or are mobile, will need to have a full license for each local authority you work in.
WHAT SHOULD YOU DO?
1. PLAN - Check you qualifications; CPD, manufacturers training or unregulated qualifications should be upskilled to Ofqual regulated certification.
2. FIRST STEP - Limited regulated training organisations in Scotland is resulting in limited places available. Identify a suitable School/Academy and get enrolled on a progression route that suits your individual training requirements to meet your personal goals and current qualifications.
3. PREPARE TO APPLY SOON - Local Authorities will be under pressure to meet demands of new and existing businesses: answering enquiries, processing applications, reviewing appeals, carrying out premises reviews. We are now being told that councils will be opening their applications in early 2027, with some councils expecting it to take 12 months to process. This is due to the anticipated volume of applications however, you can only apply if you already have the qualifications and insurance. If you haven't applied by the deadline you will need to stop treating, but if your application is already in you can continue while it is being processed.
4. UPDATE YOUR PROCESSES - Insurance companies and regulatory bodies require documentation for treatment protocols, risk assessments, Client Consultations and PAT testing etc. Ensure yours are up to date.
5. TALK TO INSURANCE - Seek confirmation from your insurance company about what qualifications they require to maintain cover. They are largely English based and will default to English rules so should be reminded that you require coverage in Scotland, under Scottish regulations which are different from current English ones..
6. REVIEW - Equipment that has been purchased or acquired to deliver treatments must meet compliance, health & safety, environmental and other standards. This is signified with a CE mark on the device. A register should be maintained with images of serial numbers, CE marks and annual PAT testing compliance.
WHY COMPLY?
Local Authorities may see this as an opportunity to plug financial gaps and so will be motivated to ensure all businesses in their area conform. With the additional expense incurred to comply those doing things properly are more likely to whistleblow on those trying to evade regulation.
Local Authority Environmental Enforcement Officers have the authority to access premises to investigate issues like potential lapses or missing licenses. They can request to examine equipment and records and review hygiene standards and practices.
Failure to have the appropriate licenses or substandard hygiene can result in fines up to £5,000 for every issue, meaning providing say 3 treatments without the correct qualification could result in a £20,000 fine.
Equipment that doesn’t meet the required standards can be confiscated and in certain circumstances businesses can be closed down.