by Jolene Williams-Pears
Currently, we are navigating a largely unregulated aesthetics landscape. Patient safety varies from clinic to clinic and depends on individual practitioners making the right choices—but what are the ‘right choices’?
In the NHS or private practice, the CQC reigns supreme. Policies, procedures, and governance structures guide decision-making, and firm rules and frameworks are deeply embedded in practice. Aesthetics, however, doesn’t have this benefit, leaving many aesthetic practitioners to figure out compliance on their own.
Good compliance isn’t just for those in CQC-registered clinics. Whether you’re a doctor, nurse, physiotherapist, or any other allied health professional offering aesthetic treatments, you’re still held to professional standards by your regulatory body. Your duty of care, ethical obligations, and patient safety responsibilities remain the same as in any other healthcare setting.
Key Overlooked Areas of Compliance in Aesthetics
Many non-CQC-regulated practitioners believe that having consent forms and insurance is enough. However, compliance in aesthetics goes far beyond paperwork. Here are three key areas that are often overlooked but essential:
Ethical Patient Selection
A practitioner’s duty isn’t just to provide treatments—it’s also to refuse them when necessary. This is where mental health screening, robust consultations, and professional judgment come in. If a patient presents with body dysmorphia, unrealistic expectations, or coercion from a third party, how do you handle it? A strong compliance framework, including safeguarding policies, informed consent, cooling-off periods, and ongoing patient support, ensures that decisions are made ethically and in the patient’s best interest.
Record-Keeping & Accountability
Good documentation isn’t just a safety net—it’s legal protection. If a complaint or claim arises, poor record-keeping can leave you vulnerable. Detailed consultation notes, photographic evidence, and clear treatment justifications should be standard practice, not an afterthought. Have you recorded batch numbers for POMs? Ensured that consumables are sterile and infection prevention audits are up to date? Labelled and disposed of sharps bins correctly?
While these tasks may seem laborious, being able to back up your claims with hard evidence is critical in the event of issues such as infections.
Professional Boundaries & Communication
In aesthetics, where social media blurs the lines between personal and professional interactions, compliance extends beyond clinical governance to how you present yourself online. This includes how you communicate with potential and current patients, as well as the information you share publicly. Is your entire feed made up of before-and-after pictures? If so, how do patients learn about you, your services, and your safety protocols?
Adhering to the ASA and MHRA’s guidelines on advertising prescription-only medication is essential. Your social media marketing should be as professional as writing a journal entry or exhibiting your clinic at an aesthetics event.
When Do You Need CQC Registration?
One of the biggest compliance misconceptions in aesthetics is knowing when CQC registration is required. The CQC regulates specific treatments that fall under the category of ‘regulated activities,’ such as:
Surgical Procedures – Any treatment involving incision or suturing beyond standard injectables
Medical Treatments for Disease or Injury – Prescribing botulinum toxin for medical conditions (e.g., migraines, bruxism) or managing complications like vascular occlusions
Mental Health Assessments & Treatment – If you diagnose or treat mental health conditions as part of your aesthetic practice, this could trigger CQC oversight
If your practice falls into any of these categories, CQC registration is a legal requirement. Many practitioners unknowingly operate in a grey area, which is why understanding the distinction between regulated and non-regulated treatments is crucial. My upcoming CQC Registration Guide will break this down further and provide a clear roadmap for those who need to register.
Most aesthetics practitioners aren’t intentionally non-compliant—they simply haven’t had the right guidance or see others being non-compliant and assume their practice is safe. That’s why I’m passionate about creating a non-judgemental space for practitioners to come together and bridge the gap between regulated and non-regulated clinics.
This is the main reason I created the Aesthetic Compliance Guide, a resource designed to help non-CQC-regulated practitioners align with NMC and HCPC professional standards. It covers practical steps for ethical patient selection, robust record-keeping, and maintaining professional boundaries—all without the jargon or complexity of traditional regulations.
If you want to future-proof your practice and enhance patient safety, the guide launches on Friday 14th February 2025. And if you believe that CQC registration may apply to your practice, stay tuned—the CQC Registration Guide will be coming soon!
Learn more about Outstanding Compliance and get your copy of the Essential Compliance Guide for Aesthetic Clinics here.