DHSC licensing // free tool

Is your clinic ready for the new licensing scheme?.
Free. No signup.

The DHSC non-surgical cosmetic procedures licensing scheme is coming. Practitioners and premises both need to register. This checklist walks through insurance levels, JCCP registration, premises standards, consent forms, and record-keeping requirements, with a gap report at the end.

  • Walks through every DHSC requirement.
  • Insurance level + JCCP + premises standards.
  • Consent form + record-keeping templates.
  • Gap report you can share with the inspector.
01 // Run it
Readiness score
0
/ 100
Not license ready
0 / 13 answered

Material gaps across most pillars. Recommended to engage a clinical consultant before continuing operations under the new scheme.

01 · Premises
Are treatment rooms compliant with NHS standards (cleanable surfaces, hand-wash basin, separate clinical waste)?
Treatment rooms must have non-porous, wipe-clean surfaces; a dedicated hand-wash basin (not shared with toilet); and a clinical waste contract.
02 · Premises
Do you have a sharps disposal contract with a licensed provider?
Used needles, cannulas, and any sharp clinical waste must be disposed of via a licensed provider. Mandatory.
03 · Premises
Do you have anaphylaxis emergency kit and trained staff on site during treatments?
Adrenaline auto-injector, hyaluronidase for fillers, and at least one staff member trained in emergency response.
04 · Practitioner
Are all practitioners on JCCP Practitioner Register (or equivalent regulated body)?
The Joint Council for Cosmetic Practitioners (JCCP) register is the de-facto standard. CQC-regulated medical practitioners (doctors, dentists, registered nurses, pharmacists) can also practice but should join the register for public-facing credibility.
05 · Practitioner
Do all practitioners hold Level 7 (or higher) qualification for injectable procedures?
Level 7 (Master's-level) in Injectables is the DHSC-recommended minimum for botox and fillers. Level 6 may be acceptable for non-injectables.
06 · Practitioner
Do all practitioners maintain JCCP-aligned annual CPD records?
Continuing Professional Development: 20+ hours/year, documented. Required for JCCP renewal and as evidence under the new scheme.
07 · Insurance
Do you hold professional indemnity insurance at £6 million or above per claim?
DHSC consultation indicates £6m/claim minimum for aesthetics. Lower limits will not meet scheme requirements once enacted.
08 · Insurance
Do you hold public liability insurance at £2 million or above?
Slips, trips, third-party damage. Often bundled with the malpractice cover.
09 · Records
Do you keep complete patient records (consultation notes, photos, product batch numbers) for at least 8 years?
Medical record retention is 8 years minimum under NHS guidance; 10 years for paediatric. Must include before/after photos and exact product batch traceability.
10 · Records
Do you maintain an incident log for adverse events and complications?
Anaphylaxis, vascular occlusion, nodules, infections. Each incident logged with timestamp, response, outcome, and reported to MHRA where required.
11 · Consent
Do you use written, signed informed consent forms for every treatment?
Must cover: procedure description, alternatives, risks (including rare ones), aftercare, complications protocol, photo consent, marketing consent (if asked).
12 · Consent
Do you give a documented cooling-off period (typically 24-48h) between consultation and treatment?
DHSC consultation strongly recommends a cooling-off period to reduce regretted decisions. Some operators require it; the scheme may make it mandatory for some procedures.
13 · Consent
Do you have a policy refusing all injectable treatments to under-18s?
Already illegal under the 2021 Botulinum Toxin and Cosmetic Fillers (Children) Act. The scheme adds enforcement teeth.
02 // What the number means

What the DHSC scheme actually does

For the first time, non-surgical cosmetic procedures in England will require both a licensed practitioner and a licensed premises. This closes a long-standing gap: anyone can currently set up a clinic and inject botox without any clinical training, premises standards, or insurance verification. The scheme is widely overdue and has cross-party backing.

The rollout is tiered by procedure risk. Lower-risk procedures (chemical peels, microneedling) may be permitted under lighter regulation; higher-risk procedures (fillers in danger zones, fat dissolving, IPL) will require additional sign-off from a regulated healthcare professional.

The 13 requirements that matter most

The checklist above covers five pillars: premises (cleanability, sharps disposal, emergency preparedness), practitioner (qualifications, JCCP registration, CPD), insurance (professional indemnity at the new higher limit, public liability), records (patient records, incident logging, MHRA reporting), and consent (informed consent, cooling-off, under-18 protections).

Each requirement carries a weight reflecting its likely scrutiny under the new scheme. The premises cleanability, practitioner JCCP registration, professional indemnity at £6m, and emergency preparedness are the highest-weight items. A clinic failing any of these is at material licensing risk.

Cost of remediation, ballpark

  • Premises refit for a single treatment room: £2-8k depending on starting state.
  • JCCP registration: £100-150/year per practitioner.
  • Level 7 conversion: £4-8k, 6-12 months. The biggest single time/cost item.
  • Professional indemnity at £6m: £800-2,500/year per practitioner.
  • Emergency kit + BLS training: £400-700 one-off, £150-400/year refresh.
  • Patient records software: NuvenarHub or specialised tools at £60-200/mo.

What this checklist does not cover

  • Local authority licensing. Some local authorities already require Special Treatments Licensing (London especially). Check yours.
  • CQC interface. Some procedures (deep peels, certain IPL configurations) may fall under CQC regulation independent of the new scheme.
  • Building regs / planning. Change of use to clinical from retail/residential triggers planning permission.
  • VAT registration. Aesthetic treatments are usually standard-rated (not exempt like medical), so passing the £90k threshold triggers VAT.
03 // FAQ

When does the licensing scheme start?

Phased rollout across 2025-2027. The DHSC consultation closed in 2024; secondary legislation is being drafted. Practitioners and premises will both need to register, with a green / amber / red tiering by procedure risk.

Will this apply to my clinic?

If you perform non-surgical cosmetic procedures (botox, fillers, threads, chemical peels, microneedling, fat dissolving, IPL, laser) in England, yes. Scotland and Wales are running parallel consultations. Northern Ireland is separate.

I'm a registered nurse / doctor / dentist - am I exempt?

No. Medical registration covers your professional practice, not the premises or scheme-specific operational requirements. You will still need premises registration, scheme-specific records, and adherence to the new consent and cooling-off requirements.

What's the consequence of operating without a license once enforced?

Indictable offence. Fines up to £2,500 under summary conviction, unlimited fine on indictment, plus potential prison sentence for serious or repeat breaches. CQC and local authority enforcement.

Is the £6m indemnity figure final?

Indicative. The consultation suggested £6m per claim minimum for injectables. Final figure may move ±£2m. Insurers like Cosmetic Insure and Hamilton Fraser have already adjusted their products to this benchmark.

Where does NuvenarHub fit?

NuvenarHub Pro handles patient records (with 8-year retention), photo storage, consent form e-signing, appointment booking with mandatory cooling-off gap, and adverse event logging. It does not handle premises compliance or practitioner qualification.

Run a license-ready clinic on infrastructure built for it.

NuvenarHub Pro: 8-year patient record retention, photo storage, e-signed consent, appointment cooling-off enforcement, adverse event logging. £480/mo + VAT.

See NuvenarHub Pro