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Cosmetic procedures – beware

All practitioners involved in the provision of cosmetic procedures must take note of new GMC guidance, which is coming into force in June 2016, and new guidance from the Royal College of Surgeons published in April 2016.

The guidance stems from a review of the Regulation of Cosmetic Interventions by a Committee chaired by Professor Sir Bruce Keogh, National Medical Director of NHS England. A copy of the final report published in April 2013 can be found here. The Committee determined that there was a need for better regulation of cosmetic procedures in order to align the treatment with comparable public health and consumer practice in the UK.

GMC guidance

The full GMC guidance can be read here. The following changes, which is not an exhaustive list, will have considerable impact on the day-to-day practical arrangements for patient care:

  • Patients must be given time for reflection before deciding whether or not to proceed with cosmetic treatment.
  • There is a personal obligation for the doctor performing the treatment to obtain patient consent themselves. This cannot be delegated to another healthcare professional or any other member of staff.
  •  Patients must be provided with full details on continuity of care and how their care will be managed in the event of any complications arising.

It is clear that Professor Sir Bruce Keogh’s intention is to “drive safer care, more ethical practice and, overall, a better experience for people undergoing cosmetic procedures.”

RCS guidance

Practitioners should also be aware that the Royal College of Surgeons has also published a set of professional standards in cosmetic surgery which is intended to supplement the GMC guidance. The full guidance can be read here.

The RCS also intends to launch a new certification scheme later this year to assist patients in identifying practitioners who have the skills and experience to match the cosmetic procedure they are considering. This parallels work the GMC is undertaking in respect of a more wide ranging certification scheme for all registrants.


As ever, there will continue to be patient complaints and fitness to practise investigations arising out of cosmetic procedures. However, practitioners working in this discipline should expect the level of red tape to continue to increase around the provision of all cosmetic procedures. Health Education England published two reports in January 2016 aimed at improving and standardising the training of practitioners carrying out non-surgical procedures (such as Botox and laser hair removal) and those who perform hair restoration surgery. There is widespread support for greater regulation in this field which will continue to develop over the coming years. Practitioners must ensure they keep up-to-date and familiarise themselves with all changes.

The GMC and RCS guidance will no doubt have wider influence in setting standards for the provision of cosmetic treatment by the registrants of other regulators, including the General Dental Council.

If you are in any doubt as to how the new GMC and RCS guidance will affect your practice please contact us for further advice:

Stewart Duffy

T. 020 7227 7418


This briefing is for guidance purposes only. RadcliffesLeBrasseur LLP accepts no responsibility or liability whatsoever for any action taken or not taken in relation to this note and recommends that appropriate legal advice be taken having regard to a client's own particular circumstances.

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