Licensing of Non-Surgical Procedures under the Civic Government Act 1982 (Order 2026): implications for UK health and safety law and business compliance
What has changed
The Civic Government (Scotland) Act 1982 (Licensing of Non-surgical Procedures) Order 2026 introduces a licensing regime for operators delivering non-surgical cosmetic procedures in Scotland. The Order places licensing requirements on businesses that provide non surgical procedures, with conditions that must be met to obtain and renew a licence. Licensing decisions and enforcement will be administered by the relevant licensing authority. The change is intended to address safety risks associated with non surgical procedures by ensuring competent staff, appropriate facilities and clear governance processes.
Who is affected
Operators delivering non surgical procedures in Scotland, including clinics, beauty salons and aesthetic practices, will be subject to licensing. Contractors and staff providing these procedures should be aware of licensing conditions and the need for appropriate training and competency records. This is a Scotland wide obligation; organisations operating across the UK may face different regimes in other parts of the country.
Why this matters for UK health and safety law
For duty holders the change expands legal duties under UK health and safety law beyond traditional workplace safety. Compliance now includes customer safety during procedures, infection control where applicable, waste management, equipment maintenance and staff competence. Organisations must embed regulatory compliance into governance and management systems to meet licensing conditions and maintain ongoing oversight.
Key duties for duty holders
- Apply for and maintain a licence for non-surgical procedures.
- Prepare and keep up to date procedures and risk controls for each procedure.
- Ensure staff are competent and appropriately trained.
- Display licence details as required and cooperate with licensing authorities.
- Maintain records of equipment, waste management and incident reporting.
- Review contracts with suppliers and contractors to reflect licensing obligations.
Enforcement and sanctions
Licensing authorities may enforce licence conditions through inspections and enforcement actions for non compliance. Organisations should treat this as part of their regulatory compliance obligations and implement controls to demonstrate ongoing conformity with health and safety requirements under UK health and safety law.
Steps to achieve compliance
- Confirm whether your operation falls within the scope of the Order.
- Assess current policies, procedures and risk controls against licensing expectations.
- Submit licence applications and respond to licensing authorities in a timely way.
- Update risk assessments and method statements for each non surgical procedure.
- Enhance training and competence records for all practitioners and staff.
- Review and update supplier and contractor arrangements; ensure safe working practices.
- Integrate licensing obligations with your ISO 45001 health and safety management system or other governance framework.
To support ongoing regulatory compliance and systematic control of workplace risk, organisations may consider partnering with Synergos Consultancy. For example, guidance on health and safety risk assessments and competent person support can be accessed via health and safety risk assessments or Competent Person support. You can also explore ISO 45001 occupational health and safety management to align governance with external requirements.
Organisations should prioritise timely planning and robust governance to demonstrate regulatory compliance and strengthen their risk management framework. The update supports a proactive approach to health and safety responsibilities by ensuring leadership, workers and contractors collaborate to maintain safe operations in line with UK health and safety law.
In summary, the introduction of licensing for non-surgical procedures under the Civic Government Act 1982 represents a measurable shift in regulatory compliance for Scotland. Determining and implementing the necessary changes now will help organisations protect patients, support staff and sustain business operations in a changing enforcement landscape.
