Understanding The New UK Guidance On Prescribing In Aesthetic Practice

The UK aesthetics industry has seen a surge in popularity over the last decade, but alongside this growth has come increasing concern over safety, regulation, and professional accountability—especially regarding the prescribing of prescription-only medicines (POMs) such as botulinum toxin (Botox). In response, new guidance from the Nursing and Midwifery Council (NMC) and industry bodies such as Save Face has been introduced to ensure prescribing in aesthetics is conducted safely, ethically, and in line with the Code of Professional Standards.

Why Is New Prescribing Guidance Necessary?

Medical aesthetics occupies a unique and sometimes controversial position in healthcare. While it often involves non-invasive treatments, the use of prescription medications such as botulinum toxin demands the same level of scrutiny and regulation as any other clinical intervention.

In recent years, several high-profile cases of poor practice—particularly involving remote prescribing or non-medical professionals—have highlighted the urgent need for clarity. The updated guidance aims to eliminate unsafe practices, protect patients, and ensure accountability across the prescribing chain.

Key Principles of the New Guidance

The NMC, which regulates nurses and midwives in the UK, sets clear expectations for safe and ethical prescribing in aesthetics. These are also echoed and expanded by Save Face, a government-recognised register of accredited aesthetic practitioners. Here are the most crucial elements of the guidance:

1. No Remote Prescribing of Botulinum Toxin

Perhaps the most notable update is the absolute prohibition of remote prescribing of botulinum toxin for aesthetic purposes. This means prescribers must conduct an in-person, face-to-face consultation with the patient before issuing a prescription.

According to the NMC’s latest position statement (2024):

“Nurses and midwives must not prescribe botulinum toxin or any other prescription-only medicine for use in aesthetic procedures unless they have personally carried out an in-person consultation and full clinical assessment of the patient.”
Read the full NMC guidance here

This aligns with guidance from the General Medical Council (GMC) and Care Quality Commission (CQC), reinforcing a unified approach across regulatory bodies.

2. The Prescriber Must Be Accountable for the Whole Patient Journey

Prescribers cannot merely assess and prescribe, then step away. The new guidance requires that prescribers take full responsibility for ensuring the product is administered safely, appropriately, and by a qualified professional.

If the prescriber is not the person administering the treatment, they must still:

Ensure the administering practitioner is competent and trained
Share clear aftercare and emergency protocols
Remain accessible for complications or adverse events

This accountability also includes appropriate record-keeping, consent documentation, and safeguarding awareness.

3. Prescribers Must Be Appropriately Qualified

The NMC and Save Face stress that aesthetic prescribers must be:

Registered professionals (e.g., nurses, doctors, dentists)
Qualified Independent Prescribers (V300)
Trained and experienced in the specific area of practice

This is essential for ensuring that patient assessments are clinically informed, and that treatment plans are based on sound medical judgment.

Being a qualified prescriber is not enough; clinicians must also understand the pharmacology, risks, contraindications, and clinical outcomes of the treatments they are prescribing. This forms part of their scope of practice, a central tenet of the NMC Code.

4. Delegation Is Not the Same as Abdication

The new guidance emphasises that delegating treatment does not absolve responsibility. A prescriber who issues a script for botulinum toxin, for instance, cannot claim ignorance if the product is then administered unsafely or by an unqualified person.

This has major implications for prescribers who work with beauty therapists or non-medical injectors. According to Save Face:

“The prescriber is responsible for the prescribing decision and must ensure the administration is carried out safely and competently.”
See Save Face guidance on prescribing

Prescribers should conduct due diligence before entering into working relationships, including checking qualifications, insurance, and the clinical governance protocols in place.

5. Patient Consent and Consultation Are Non-Negotiable

Every patient must receive:

A comprehensive in-person consultation
A full medical history and assessment
A discussion of risks, alternatives, and expected outcomes
Time to ask questions and give informed consent

This applies even if the patient is a regular or returning client. The consultation cannot be performed by a receptionist or assistant; it must be the prescriber or treating clinician.

Informed consent is not just a formality—it is a legal and ethical requirement under both the NMC Code and the GMC’s “Good Medical Practice” framework.

Implications for Aesthetic Nurses and Clinics

For nurses working in aesthetics, this guidance has several important implications:

You must be a qualified independent prescriber to prescribe POMs like botulinum toxin.
If you’re working under a prescriber, you must ensure they follow proper consultation protocols.
You cannot legally or ethically accept prescriptions for clients you have not assessed.
You must maintain up-to-date records, including batch numbers, dosage, expiry dates, and patient notes.

Clinics should also implement robust protocols, including:

Documented policies for prescribing and administration
Emergency procedures for adverse reactions
Comprehensive staff training
Clear referral pathways for complications

Failure to adhere to these standards may result in regulatory action, legal liability, or even being struck off the professional register.

A Welcome Step Toward Safer Practice

While the new guidance may feel restrictive to some practitioners, it is ultimately designed to protect patients and elevate the reputation of the aesthetics industry. It reinforces the idea that cosmetic procedures are medical interventions, not beauty treatments—and should be treated with the same rigour.

As the aesthetics sector continues to evolve, practitioners must stay informed, compliant, and committed to ethical care. By adhering to these updated guidelines, professionals can provide safe, effective, and trustworthy treatments that truly benefit their clients.