Every few months a headline announces that aesthetics is about to be regulated, and every few months nothing visibly changes. It is worth separating what has actually been decided from what is still being consulted on, because the gap between the two is where people make expensive training mistakes.
What is decided
The Department of Health and Social Care published its response to the licensing consultation on 7 August 2025, after more than 11,800 people replied. It confirmed a three-tier risk model, red, amber and green, with botulinum toxin and dermal fillers sitting in the amber band. Both the practitioner and the premises will need their own licence. That much is settled policy.
What is not decided yet
The detail is not law. A further consultation on the specifics is expected during 2026, with a phased rollout anticipated from mid-2026 into 2027, and unlicensed practice becoming a criminal offence somewhere around 2027. Until the statutory instrument lands, nobody can tell you the exact qualification you will need to hold, though a Level 7 diploma is the widely expected benchmark for injectables.
Scotland has not waited
Scotland passed its own primary legislation on 18 March 2026. From September 2027 a defined list of procedures may only be carried out in permitted premises, such as clinics registered with Healthcare Improvement Scotland. Wales and Northern Ireland have announced nothing equivalent. So UK regulation is already four different timelines, and any course advert that flattens them into one is telling you something about how carefully it reads the news.
What this means if you are training now
Train to the standard the law is clearly heading towards, not the minimum a fast course can sell you. If Level 7 is going to be the benchmark, a Level 4 certificate bought this year may need topping up next year. We keep a dated record of every change on our licensing tracker, and the Level 7 guide explains why insurers are already asking for it. If you would rather talk it through against your own profession, the route finder is a faster way in.