Inquiry Calls for Aesthetic Regulation of High-Risk Procedures Now

A government committee has heard calls to implement aesthetics regulation for high-risk non-surgical procedures now, with no additional consultation. Additionally, forming a dedicated regulatory task force has been floated.

In this article, we update you on the 9th September 2026 Women & Equalities Committee hearing related to the health impacts of liquid breast augmentations and other cosmetic procedures.

It covered a wide range of regulatory and patient safety topics, including:

• Proposals to have another public consultation on aesthetics legislation for red category (high risk) procedures
• Potential to implement a temporary ban on high-risk procedures during consultation
• UK complications rates from high-risk, non-surgical cosmetic treatments
• Non-medics and doctors with no surgical training carrying out plastic surgery
• Botulism outbreaks linked to injectable treatments and crackdowns on remote prescribing
• The need for all aesthetic practitioners to be able to plan for and manage complications
• Social media and AI’s role in promoting supply and demand for aesthetic treatments
• Cosmetic tourism and obtaining accurate data from the NHS.

Evidence was provided to the inquiry from Ashton Collins, Director at Save Face, and Nora Nugent, a Consultant Plastic Surgeon and President of the British Association of Aesthetic Plastic Surgeons (BAAPS). The hearing, which took place at the House of Commons, was chaired by Christine Jardine, MP for Edinburgh West (Liberal Democrat).

In this article, we’ll review the parts of the hearing specifically relating to:

• A public consultation on regulating high-risk aesthetic treatments
• Non-surgeons carrying out surgical-level procedures
• Call for a dedicated task force.

We’ll publish follow-up articles shortly to ensure you’re kept informed about each part of this inquiry. You’ll be able to find them in the Regulation section of our Aesthetics Articles homepage.

Read on to find out what was said, and to watch the full inquiry video.

Exploration of High-Risk Cosmetic Procedures and the Planned Consultation

The inquiry was kickstarted with a question from Kevin McKenna, the Labour Member of Parliament for Sittingbourne and Sheppey, a cross-party member of the committee. He wanted to know if there had been any improvements to patient safety for this cohort since Ashton Collins gave evidence to this committee last year.

She confirmed that no, they are definitely no safer, then noted that the ongoing delays to establishing and implementing regulation of cosmetic procedures had had "further unintended consequences".

The campaigner informed the committee that there are now even more liquid BBLs (Brazilian Butt Lifts) "being carried out on the High Street by unqualified practitioners". She highlighted how the risks she previously spoke about have now escalated exponentially.

She also shared that "we now have lay people performing surgical procedures involving scalpels and vast quantities of anaesthetic… without consequence". These were clarified as including:

• Facelifts
• Blepharoplasty
• Intimate procedures
• Liposuction.

Liquid breast augmentations were also mentioned later in the hearing. Both liquid breast augmentations and liquid BBLs involve the unlicensed injection of dermal fillers to add volume to the breasts or buttocks. This approach replaces traditional surgical implants or fat transfer procedures, and both the JCCP and BAAPS classify these as surgical-level.

Did the announcement of another aesthetics regulation consultation have any impact on patient safety?

McKenna asked if the government's announcement of the planned consultation into high-risk treatments had helped these practitioners to "buck up their ideas". This is the red category public consultation which was due to happen over the summer but has been postponed, with no information on when it may happen.

Nugent gave a measured response that gave credit for the announcement raising awareness of the issue, through the media and professional groups. However, she felt it didn't have enough of a preventative impact, saying, "The people who are not bothered about regulation are not bothered by the pace of action and also anticipate a slow pace of action… I think there are very few who have shut their doors".

Why are Non-Medics Performing Cosmetic Surgery in the UK?

The simple answer to why the issue of lay people - and medics who are not appropriately qualified - are performing cosmetic surgery was unsurprising. Money.

Collins felt that the amount of money they could make, plus the short amount of time it takes to learn how to do procedures, such as liquid BBLs, make it "appealing to unscrupulous people". She also acknowledged the part the issue around cosmetic surgery not being restricted to appropriately qualified and registered plastic surgeons, plays here.

Nugent added that by raising awareness of this issue, it's also made clear that "you can make a lot of money out of this without being regulated or facing any consequences."

Who Can Perform Cosmetic Surgery in the UK, Legally?

At present, any GMC-registered doctor can legally perform surgical cosmetic procedures in England. This is true even when they have not undertaken any specialist surgical training.

The Royal College of Surgeons (RCS England), a coalition of royal colleges, specialist surgical associations and patient safety bodies, including BAAPS and the JCCP, recently pushed for this loophole to be closed.

In August 2026, the group wrote an open letter to the Health Secretary calling on the government to publish its promised consultation on high-risk non-surgical cosmetic procedures, and strengthen protections for patients. This letter came one year after the government first announced it would legislate for this category of invasive aesthetic treatments.

Signatories argued that a proposed 'red list' of high-risk procedures won't protect patients unless those procedures can only be carried out by appropriately trained specialist surgeons on the GMC Specialist Register. They warned that regulatory failures can lead to serious injury, long-term physical and psychological harm, and, in some cases, death. The added pressure this is currently putting on NHS services was also noted.

Nora Nugent confirmed to the committee that this lack of clarity around who can actually be called a cosmetic surgeon "undermines public confidence and it confuses people".

Who Can Use the Title 'Plastic Surgeon' or 'Cosmetic Surgeon' in the UK?

Lay people with no medical training carrying out aesthetic procedures from botox to liquid BBLs is a known issue, and one that has received a fair amount of scrutiny. However, Nugent turned the spotlight to the current hot button issue as she explained how some doctors without the appropriate surgical background and registrations, are holding themselves up as aesthetic surgeons.

'Plastic surgeon' is a protected title but 'Cosmetic surgeon' is not

'Plastic surgeon' is a genuinely restricted title, as only doctors on the GMC's Specialist Register for Plastic Surgery, after at least six years of specialist surgical training, can lawfully use it. There is a loophole, however, in that 'Cosmetic surgeon' has no such protection. Neither does ‘Aesthetic surgeon’. Right now, any GMC-registered doctor can use these titles, regardless of their (lack of) surgical experience.

Why has this loophole not been addressed before now?

When asked, Nugent echoed a sentiment felt throughout much of the UK's aesthetic medicine sector. 

"The horse has bolted to some extent," she said. "It is always easier to stop something than to stop people who are already doing it and claw back where it should never have been allowed in the first place… We've allowed [the] status quo to continue and allowed more and more people to just continue. And I'm talking about doctors as well as non-surgical practitioners. We've allowed people to to start up and to continue doing procedures they're not qualified to undertake. And it's harder to claw back than it would be to have stopped it in the first place from happening."

Should the Government Hold Another Consultation on Regulating High-Risk Cosmetic Procedures?

The question we've all been waiting for was posed, and Nora Nugent answered clearly.

"I've got to be very frank. I think we've already had the consultation and I think we know the issues we have and it will delay the much needed regulation further by going through another consultation process."

If there was to be another consultation, she felt this needed to focus on the specifics of the proposed legislation.

Ashton Collins agreed. "There is no ambiguity or contentiousness around whether or not somebody that isn't a qualified, regulated specialist plastic surgeon should be able to pick up a scalpel and operate on somebody or perform a high-risk liquid BBL. The only people that would disagree with any sort of ban on these are the unscrupulous people that are currently capitalising on people's insecurities and are making a massive amount of money at the hands of unsuspecting members of the public."

Nugent added, "This is a very fast moving side of medicine. I'm calling it medicine deliberately because these are medical products with medical consequences. And if we are talking about regulation, there has also to be some sort of capacity to categorise new developments so that you don't bring out legislation and it's almost immediately out of date… We have to think about that aspect in terms of bringing in regulation as well. Not just what's out there now - what might come along and its level of invasiveness and risk and who should be doing it."

Temporary ban on high-risk cosmetic procedures during a consultation period

The committee asked its guests if they would welcome a temporary ban on the procedures under discussion during a public consultation.

Whilst Nora Nugent agreed, she caveated it saying, "there are people who are qualified to do these procedures, as in plastic surgeons, and there has to be a consequence to not being qualified to do something."

Call for a Dedicated Aesthetics Regulation Task Force

Ashton Collins reiterated something she's been calling for for the last 10 years: a dedicated aesthetics regulation task force.

"I've been begging for the establishment of a dedicated task force, because oftentimes complaints involving these types of procedures are complex and require input from a vast array of different regulatory authorities. Whether that be trading standards, the MHRA, the statutory regulators, the ASA - whoever it might be.

"Currently these people operate in silos and they don't take these complaints as seriously as they ought to which means that current legislation is under-policed and under-enforced… I would like there to be much more accountability around the regulators that are responsible for policing and enforcing this legislation."

Next Steps for Aesthetics Regulation in England

The meeting ended on the question of what would be the biggest concern if legislation was not introduced by the end of the current parliament. Nora Nugent had the answer. More deaths. "How many more do we need?"

Whilst no progress was made during this meeting, this was not its intention. It was simply an exercise in hearing expert opinions and evidence that can inform the next steps in aesthetics regulation for England. The rest of the UK is also waiting for England to implement specific legislation where a joined-up approach is required.

Now, we wait for details of whether there will be another public consultation on the high-risk cosmetic procedure category, or if steps recommended in this hearing can be implemented directly. What's for sure is that no one can be in any doubt as to the urgency required, here.

If you're a healthcare professional considering a career in aesthetic medicine but are unsure how incoming regulation might affect you, talk to our team. You can book a call to discuss what you're hoping your medical aesthetics career will look like, and they can advise you on the current best options for you in terms of reputable, structured and regulated aesthetics training courses, qualification routes, and more. They can also explain what the impact of regulation is expected to be, so you can prepare now.

All information correct at time of publication