Introduction

Pharmacists who wish to expand their scope of practice to include aesthetic procedures must familiarise themselves with and adhere to relevant legislation and regulatory standards and follow good prescribing practice. Aesthetic practice must be underpinned by medicines safety and the principles of person-centred care. People accessing aesthetic procedures must be provided with all the information they need to understand the benefits and risks of any procedure to allow them to make an informed choice. In addition, people must be informed how to seek advice after a procedure.

This position statement has been developed to support pharmacists by ensuring they have clear direction around the legislation and guidelines they need to follow when practicing in aesthetics, alongside the professional responsibilities they must adhere to when delivering care.

Aesthetic medicine is defined by the British Association of Medical Aesthetic Nurses (BAMAN, formerly the British Association of Cosmetic Nurses) as a clinical speciality distinct from plastic surgery providing minimally invasive medical treatments carried out with the primary objective to enhance patients’ satisfaction with their physical appearance³.

The aesthetics industry has expanded rapidly in recent years; a 2025 survey found that 26% of women and 11% of men in the UK had had a cosmetic procedure⁴. Thus, showing that aesthetic practice is important for a significant population in the UK. The growth of this industry in recent years is also demonstrated in the annual report from the British Beauty Council, The Value of Beauty 2025⁵ states that the beauty industry contributed £30.4bn to the UK’s GDP in 2024 – an increase of 9% compared to 2023.

This indicates that the proportion of the population in the UK using beauty treatments continues to grow.

As this industry grows and demand from the public for aesthetic procedures increases it is anticipated that the number of pharmacists wishing to practice in this area will also increase. Pharmacists who practice in aesthetics can bring considerable medicines expertise to the field, but they must be able to assure the public that they have completed appropriate additional training and can demonstrate competence in the procedures that they offer. This position statement aims to support pharmacists to ensure any aesthetic services they provide are delivered in a safe and effective manner by setting out the standard of care their clients should expect to receive and the expectations placed on pharmacists delivering those services.

The Royal College of Pharmacy recently commissioned a survey of pharmacists across all sectors of pharmacy to better understand current awareness of legislation and standards in aesthetic practice and to gauge what support in terms of standards, guidance or education would best support pharmacists in aesthetic practice. Survey results showed that 49% of respondents did not feel that current professional guidance on training requirements in aesthetic practice for pharmacists was clear enough. When asked about how clear they felt regulatory requirements were, 55% of respondents indicated that they were not currently clear enough. When asked what the Royal College could do to support pharmacists in aesthetic practice, the top three cited responses were professional guidance, professional standards and competency frameworks.

Considerations for aesthetic practice and pharmacy

Government legislation

Legislation can vary across the four UK nations and pharmacists practicing in aesthetics must ensure their practice is in line with the legislation for the nation in which they are practicing.

The act regulating non-surgical cosmetic procedures in Scotland can be found here: Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026.

This act:

• Restricts non-surgical cosmetic procedures to a defined group of health professionals.
• Prevents those under the age of 18 years accessing non-surgical cosmetic procedures.
• Regulates the premises where non-surgical cosmetic procedures are carried out.

Details on the proposed review of legislation in England can be found here: UK government consultation on non-surgical procedures.

This consultation proposals include:

• Introduction of risk-based classification of procedures and corresponding restrictions on these.
• Licensing of practitioners and premises.
• Age restrictions on who can access non-surgical cosmetic procedures.
• Regulation of products and prescribing.
• Accreditation of education providers.

Aesthetic practice in Wales is not covered by either of these processes, but there is an expectation that Welsh-specific legislation on non-surgical procedures will be introduced in due course.

Regulatory and professional standards

The GPhC standards for pharmacy professionals include prescribing guidance¹ which is clear on the expectations of pharmacists prescribing non-surgical cosmetic products.

• Pharmacists must have appropriate training and experience in the non-surgical cosmetic procedures they are undertaking.
• Remote prescribing is not permitted, and pharmacists cannot prescribe for people that they have not clinically assessed in-person.
• The prescriber must have a face-to-face consultation with the person they are prescribing for and by prescribing takes responsibility for the safety of that person during the procedure and for any after care including complications. This means that the prescriber must be fully competent in the procedure they are prescribing for.
• If delegation of any part of the procedure is undertaken, then the delegation must be to a registered healthcare professional, and the prescriber remains responsible for ensuring the person’s treatment and aftercare are appropriate and safe.
• If delegating administration to another healthcare professional, then the prescriber must clearly document which procedure they intend the prescription to be used for.

As aesthetic practice involves clinical assessment, prescribing and treatment it is healthcare practice and a pharmacists professional responsibilities apply as with any other clinical speciality. Pharmacists prescribing in aesthetics must follow the RCPharm competency framework for all prescribers² as would be expected in other clinical areas. This competency framework supports prescribers in expanding their knowledge, skills, motives and personal traits, to continually improve their performance, and work safely and effectively.

The RCPharm competency framework can be accessed here: RCPharm: a competency framework for all prescribers.

Education and training

Pharmacists should be aware that the training currently available for aesthetic practice is not standardised. JCCP accredit training courses which are presented to them for assessment and align with the JCCP Competency Framework⁶. However, many courses are not presented to JCCP for assessment. RCPharm cannot recommend a specific training course which will meet the requirements of all pharmacists working in aesthetics. Pharmacists should use the JCCP Competency Framework as a reference point to plan their training needs. The framework can be accessed here: JCCP Competency Framework.

Save Face is an organisation registered with the Professional Standards Agency which offers accreditation to health professionals working in aesthetic practice and this accreditation can also be used as a basis for assessing and planning training needs. JCCP and Save Face offer different resources and pathways to accreditation. Pharmacists working in aesthetic practice should consider which organisation best supports their needs.

Risk assessment

Pharmacists providing aesthetic services should undertake and document a risk assessment for every procedure offered. This should confirm that the proposed treatment is appropriate for the individual client, that the pharmacist has the necessary knowledge, skills and competence to safely perform the procedure, and that an appropriate clinical environment, equipment and emergency arrangements are in place to support safe delivery of care.

This will include assessment of the following elements at a minimum.

• Clinical risk assessment including psychological safety assessment and capacity to consent. Pharmacists should assess whether treatment is appropriate, taking account of potential unrealistic body image expectations, psychological vulnerability and safeguarding concerns and be willing to advise against treatment if not appropriate.
• Complication risk assessment including expectation management and risks of complications with a plan for management.
• Environmental risk assessment including infection control, PPE and waste management.
• Assessment of the practitioner competence to carry out the procedure.
• Assessment of emergency procedures in place including preparedness for anaphylaxis and access to basic life support if required.

Complications management

Complications can occur in Aesthetics as they can with any clinical procedure, but complications management is not always covered in training for aesthetic practitioners. The Australian Health Practitioner Regulatory Authority’s (Ahpra) Guidelines for registered health practitioners who perform non-surgical cosmetic procedures⁷ clearly states that practitioners must be able to recognise and manage complications or emergencies arising from aesthetic practice. RCPharm similarly provides an explicit recommendation in this area as detailed in recommendation five of this position statement. This also aligns with the guidance in the RCPharm prescribing competency framework Section 4.1 which states pharmacists must understand the potential for adverse effects and takes steps to recognise and manage them while minimising risk⁵.

Currently there is disparity in the legislation around stockholding of prescription-only medicines between the four nations⁸.  Pharmacists working in aesthetic practice must understand and adhere to the current medicines legislation for the nation in which they are working. The Royal College of Pharmacy will work with relevant stakeholders to explore mechanisms that enable equitable access to emergency medicines, including adrenaline, to support the safe management of complications and improve safety in aesthetic practice. 

Standards for premises where aesthetic practice is undertaken

There are differences in how premises are regulated in England, Scotland and Wales. Where aesthetic practice is undertaken in a pharmacy the premises will be regulated by GPhC standards for pharmacy premises. However, where pharmacists are undertaking aesthetic practice in a premises such as a private clinic which is not a registered pharmacy this will be regulated differently. In Scotland the premises will be regulated by Healthcare Improvement Scotland; in England and Wales the legislation around private clinics is still under review. However, independent of practice location, pharmacists need to be aware that they must be working in line with the RCPharm competency framework for all prescribers² which states that the consultation should be undertaken in an appropriate setting and consider dignity, capacity, consent and confidentiality. Additionally, a pharmacist should be following the GPhC good prescribing guidelines¹ which states that they must make sure any procedures are carried out in an appropriate and professional way, and in an environment which is safe and appropriate for the procedures being carried out. Where there may be some legal ambiguity around the rules for premises used for aesthetic procedures the professional expectation for pharmacists is clear.

Responsible sourcing of products used in aesthetic practice

Pharmacists working in aesthetic practice are responsible for ensuring that the products they are using are sourced from a reputable supplier and that the required legal checks and medicine ordering rules are in place. If a product is being used off-licence, then the appropriate checks need to be put in place. The person being prescribed the product must be informed that the product is being used off-licence and risks of this discussed and documented along with informed consent. Pharmacists must be aware of the additional responsibilities associated with prescribing off-label medications⁹.

There are reports of products in aesthetics being used which are not regulated by the Medicines and Healthcare products Regulatory Agency (MHRA) as they are not being promoted as having medicinal value. The GPhC has detailed the risks and additional responsibilities of using these products to all pharmacists¹⁰. Pharmacists must consider their professional responsibilities in ensuring that the products they are using are safe for the people they are using them for and consider how they can ensure this if the product is not licensed or regulated by the MHRA.

Any adverse reactions to products used in aesthetic practice must be reported to the Yellow Card scheme¹¹.

Record-keeping

The RCPharm competency framework² clearly advises in Section 1 that during consultations a pharmacist must clearly document as described below:

Section 1.6
Take and document an appropriate medical, psychosocial and medication history including allergies and intolerances.

Section 1.7
Undertake and document an appropriate clinical assessment.

This applies to a consultation for aesthetic practice as it would in any other clinical setting.

As part of documented informed consent, pharmacists must clearly explain:

• Potential side effects
• Complications
• Alternatives to the requested procedure
• Policy on complaints and refunds

A record of the informed consent discussion must be kept as part of the clients record and it should be clear from the dates of discussion and date of procedure that there is evidence of a cooling-off period where there is time for the service user to consider the information given in the initial consultation before going ahead.

It is recommended that pharmacists offering aesthetic services have in place standard operating procedures (SOPs) for their service which would include at a minimum risk assessments and SOPs for conducting a consultation, adverse events, infection control and maintenance of equipment.

Insurance

Pharmacists working in aesthetic practice must ensure that they are adequately insured for the procedures that they are undertaking.

Conclusions

Pharmacists entering aesthetic practice must recognise that practicing and delivering services within this specialist field carries professional, legal and clinical responsibilities as with any other area of clinical care. This position statement emphasises that safe and ethical practice depends on a solid understanding of current legislation, adherence to prescribing standards, and a commitment to public safety.

To practise safely and effectively, pharmacists must undertake appropriate education and training, develop and maintain competence through supervised experience, and engage in ongoing continuing professional development. They must also ensure that the products they use and the environments in which they practise comply with all legal and professional requirements and provide the highest possible standards of safety for members of the public using their services.

A comprehensive risk assessment must underpin every aesthetic procedure, enabling practitioners to identify and mitigate potential risks of the procedures they are performing.

In conclusion, pharmacists can make a valuable contribution to aesthetic practice when they practice within their professional competencies and uphold the standards, principles and values of the pharmacy profession.

References

1. GPhC – In practice: Guidance for pharmacist prescribers. [accessed 12/4/26]
2. RCPharm – competency framework for all prescribers. [accessed 12/4/26]
3. BAMAN – definition of aesthetic practice. [accessed 12/4/26]
4. YouGov – Cosmetic treatments in Britain: From curiosity to confidence. [accessed 12/4/26]
5. British Beauty Council – The Value of Beauty report 2025. [accessed 12/4/26]
6. JCCP – Competency Framework. [accessed 12/04/26]
7. Ahpra – Performing non-surgical cosmetic procedures. [accessed 12/4/26]
8. JCCP Guidance Statement – Responsible Prescribing for Cosmetic Procedures. [accessed 13/08/26]
9. The Pharmaceutical Journal – Prescribing unlicensed and off-label medications – February 2026 – Lek et al. [accessed 14/4/26]
10. GPhC highlights concerns about unregulated products – GPhc email advice to all pharmacy staff. [accessed 17/7/26]
11. MHRA Yellow card scheme.