Adding microblading, piercing, laser or lip filler: what do I need before the first client?

Greymill AcademyUK7 min readReviewed Oct 202640 primary sourcesUS version

The short answer

Every salon has safety duties, and a treatment that breaks the skin, uses a laser or involves a prescription-only medicine adds licensing, age rules and insurance duties that differ in each of the four nations.

The takeaway. Before a new treatment's first booking, check your nation's licence or registration, the age rules, a prescriber for any prescription medicine, and that the insurer names it.

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Written for owners of hair salons, barbershops, beauty, nail, lash and brow businesses, spas and massage, tanning, tattoo and piercing studios and non-surgical aesthetics clinics in England, Wales, Scotland and Northern Ireland.

The short version

  1. Check licence, registration and age rules.They change by nation once a treatment breaks the skin, uses a laser or a prescription-only medicine. Some under-18 bans apply despite a parent's consent.
  2. Book a prescriber who meets clients in person.Botox is a prescription-only medicine. The prescriber must see each new client face to face before the first treatment. A video call does not count.
  3. Get the treatment on your insurance schedule.Insurers list each treatment and the qualification needed for it. Add the new one before its first booking.

In England, hair, barbering, nails, waxing, lashes and beauty need no national licence, though some London boroughs license treatments such as manicure and massage (below). Teeth whitening is not a beauty treatment: it is dentistry (Dentists Act 1984 s.37). The moment a treatment breaks the skin, uses a laser or IPL, or involves a prescription-only medicine, the rules change, and they change by nation. Work through this before the treatment goes on the menu, not after the first booking.

What every salon needs, licence or not

  • A COSHH assessment for every hazardous product (bleach, oxidising dyes, persulphates, acrylic monomers, acetone, peels, disinfectants), with gloves and ventilation (Control of Substances Hazardous to Health Regulations 2002 regs 6 and 7).
  • Monthly skin checks by a trained person, recorded, for hairdressers and nail technicians, who are a dermatitis risk group (reg 11).
  • Extraction at the desk for nail dust and monomer vapour.
  • An allergy alert test 48 hours before every PPD colour service, as the maker instructs, and no colour for a client with a black henna tattoo or a past reaction until cleared.
  • In England, a recorded fire risk assessment whatever your headcount (Regulatory Reform (Fire Safety) Order 2005 art 9).

Your council's environmental health officer enforces this, not the HSE.

Tattooing, piercing, microblading and electrolysis

  • England outside London: tattooing, semi-permanent skin-colouring such as microblading, cosmetic piercing and electrolysis need the person and the premises registered with the council. Registration is one-off, but a move or a new practitioner needs a new one, and working unregistered is an offence (Local Government (Miscellaneous Provisions) Act 1982 ss.14 to 16).
  • London: in boroughs that adopted the London Local Authorities Act 1991 Part II, premises offering massage, manicure, tattooing, cosmetic piercing, light and electric treatments need an annual special treatment licence. Laser and IPL are usually caught as light treatment.
  • Wales: each person doing acupuncture, body piercing, electrolysis or tattooing, including semi-permanent makeup and microblading, needs a personal special procedure licence unless a statutory exemption applies, and the procedure generally has to be done at approved premises or in an approved vehicle. The licence needs an infection control qualification and a hygiene check (Public Health (Wales) Act 2017 ss.58, 60 and 69). An old council registration alone no longer counts: anyone who did not apply under the new scheme by 28 February 2025 needs a licence before working.
  • Scotland: tattooing, piercing, electrolysis and semi-permanent makeup need a council skin piercing and tattooing licence (SSI 2006/43).
  • Northern Ireland: skin piercing, including tattooing and electrolysis, is registered with the district council.
The rule

Age rules a parent cannot consent around

Tattooing anyone under 18 is an offence in England, Wales and Scotland, even with a parent's consent; keep a record of the ID you saw. In Wales, intimate piercing, which includes the tongue and nipples, of anyone under 18 is an offence. In England, botulinum toxin or filler injections for a cosmetic purpose on anyone under 18 are offences, including arranging or booking them. Sunbeds may not be used by, or sold or hired to, anyone under 18. As of Oct 2026.

Tattooing of Minors Act 1969 s.1; Public Health (Wales) Act 2017 s.95; Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 ss.1 to 3; Sunbeds (Regulation) Act 2010; Public Health etc. (Scotland) Act 2008 Part 8; Sunbeds Act (Northern Ireland) 2011

Councils and insurers treat semi-permanent makeup as tattooing, so refuse under-18s for that too; that is practice, because whether the 1969 Act covers it is not settled. The 1969 Act does not extend to Northern Ireland: there, take the age rule from the council's conditions and your insurer.

Lasers and IPL

England has no national laser or IPL registration; London boroughs license them as a special treatment. Insurers expect a Laser Protection Adviser, written local rules, a named laser protection supervisor, operator training and eyewear. Wales is different: a setting using a Class 3B or 4 laser or an IPL must register with Healthcare Inspectorate Wales before first use (Care Standards Act 2000 s.11). In Northern Ireland, clinics using those lasers or IPL register with the RQIA.

Injectables

The rule

Botox needs a prescriber who has seen the client

Botulinum toxin is a prescription-only medicine: a non-prescriber may inject it only under the prescriber's directions for the named client. Doctors must see the patient in person before prescribing injectable cosmetic medicines, and nurse and midwife prescribers must consult face to face from 1 June 2025. Fillers are devices and need no prescription, but hyaluronidase, which dissolves filler in a complication, is prescription-only. As of Oct 2026.

Human Medicines Regulations 2012 reg 214; GMC cosmetic interventions guidance (2016); NMC

What regulators and insurers expect before the first injecting session

  • A written complications protocol for vascular occlusion, infection and anaphylaxis.
  • A prescriber reachable for every injecting session, with hyaluronidase prescribed for the named client or available through the prescriber.
  • Adrenaline 1 mg/ml on site, which anyone may give in an emergency (Human Medicines Regulations 2012 Sch 19).
  • Batch numbers recorded, and adverse incidents reported to the MHRA Yellow Card scheme.
AvoidUsing a nurse prescriber abroad who prescribes toxin after a video call.
Do this insteadBooking the prescriber in person for every new client before the first treatment.

A prescription after a video call, a form or photos breaches the prescriber's code and leaves you uninsured for that client.

In England, purely cosmetic non-surgical treatments are not a regulated activity, so a clinic offering only toxin, filler, peels and laser for appearance does not register with the CQC. It must register once a healthcare professional treats a condition, such as toxin for migraine, and running a regulated activity unregistered is an offence (Health and Social Care Act 2008 s.10).

In Scotland, an independent clinic where a doctor, dentist, nurse, midwife or dental care professional provides services registers with Healthcare Improvement Scotland. Other practitioners come under the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026, which is enacted but phased in: its council licence requirement does not apply before 6 September 2027. Check whether its under-18 offence is in force before treating anyone under 18. As of Oct 2026.

As of Oct 2026, England's licensing scheme for non-surgical cosmetic procedures is proposed, not law. Until one is made, the practical gate is your insurer: treatment risk cover lists named treatments and the qualification for each, and many insurers name an Ofqual-regulated Level 4 qualification for laser and IPL and Level 7 for injectables by non-healthcare practitioners. Add every new treatment and get it on the schedule before the first booking.

Asked in Greymill

Example question and answer from Rules & Licensing
You
Salon in Leeds. Want to add Botox next month. Found a nurse prescriber who does video consults for each new client, so they never have to come in. My senior therapist will do the injecting. What else do I need?
Rules & Licensing
Drop the video consults. The prescriber must meet each new client in person first.

Botox is a prescription-only medicine, and nurse prescribers must consult face to face (from 1 June 2025, As of Oct 2026). A prescription after a video call breaches their code and leaves you uninsured for that client.

Before the first booking:
Your therapist: injects only on the prescriber's directions for each named client.
Complications: a written protocol for a blocked blood vessel (vascular occlusion), infection and severe allergic reaction (anaphylaxis), with the prescriber reachable for every session.
Age: in England, cosmetic Botox on anyone under 18 is an offence, and so is booking it (As of Oct 2026).

Your insurer is the real gatekeeper. England's licensing scheme is proposed, not law (As of Oct 2026). Get Botox and your therapist's qualification on your schedule first. Many insurers name Level 7 for injectables by non-healthcare staff.

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Your question

I run a salon or beauty business in the UK. We are in [England, Wales, Scotland or Northern Ireland], in [town or London borough]. I want to add [treatment, for example microblading, IPL or lip filler], done by [who, and their qualification]. Tell me which council registration or licence, healthcare regulator registration, prescriber arrangement and age rules apply, what my insurer will need on the schedule, and give me a checklist in the order to do it before the first booking.

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Sources

The primary sources behind this lesson, checked Oct 2026.

  1. Local Government (Miscellaneous Provisions) Act 1982 ss.14 to 16 (Licensing and registration by nation)
  2. s.15 (no renewal provision); council practice (Licensing and registration by nation)
  3. London Local Authorities Act 1991 Part II, s.4 definition of special treatment (Licensing and registration by nation)
  4. Public Health (Wales) Act 2017 ss. 58 and 60: licensing rule and exempt individuals; s. 69: premises and vehicle rule and exceptions (Licensing and registration by nation)
  5. Welsh Government guidance, Transition period (Licensing and registration by nation)
  6. SSI 2006/43 (Licensing and registration by nation)
  7. Tattooing of Minors Act 1969 s. 1(1) to (3) (Age rules)
  8. Public Health (Wales) Act 2017 ss. 95 and 96(2); Public Health (Wales) Act 2017 (Commencement No. 2) Order 2018 art. 2 (Age rules)
  9. Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 ss.1 to 3 (Age rules)
  10. Tattooing of Minors Act 1969 s.3; no case or guidance located (Age rules)
  11. COSHH 2002 regs 6, 7 and 11 (Health and safety)
  12. HSE skin at work guidance for hairdressing (Health and safety)
  13. UK Cosmetics Regulation Annex III, p-phenylenediamine entry (Health and safety)
  14. RIDDOR 2013 regs 4, 5 and 8 (Health and safety)
  15. BSA 2022 s.156(1) to (3) commencement for Wales, SI 2023/914 reg 3 (Health and safety)
  16. Regulatory Reform (Fire Safety) Order 2005 art 9; Building Safety Act 2022 s.156; Fire (Scotland) Act 2005 Part 3 (Health and safety)
  17. Human Medicines Regulations 2012 reg 214 (Non-surgical aesthetics: medicines and prescribing)
  18. HMR 2012; MHRA classification (Non-surgical aesthetics: medicines and prescribing)
  19. GMC cosmetic-interventions guidance para. 11: physical examination before prescribing injectable cosmetic medicines (Non-surgical aesthetics: medicines and prescribing)
  20. HMR 2012 reg 284; CAP Code rule 12.12 (Non-surgical aesthetics: medicines and prescribing)
  21. CAP Code rules 12.1 and 12.12 (Non-surgical aesthetics: medicines and prescribing)
  22. HMR 2012 Sch 19 (Non-surgical aesthetics: medicines and prescribing)
  23. Regulated Activities Regulations 2014 Sch 1 (treatment of disease, disorder or injury; surgical procedures) (AESTHETICS regulation: CQC, lasers and IPL by nation)
  24. Health and Social Care Act 2008 s.10 (AESTHETICS regulation: CQC, lasers and IPL by nation)
  25. NHS (Scotland) Act 1978 s.10F (AESTHETICS regulation: CQC, lasers and IPL by nation)
  26. HPSS (Quality, Improvement and Regulation) (NI) Order 2003 (AESTHETICS regulation: CQC, lasers and IPL by nation)
  27. Government response: tiering, amber supervision and next steps passages (Aesthetics LAW reform watch)
  28. Health and Care Act 2022 s. 180 is an enabling power (Aesthetics LAW reform watch)
  29. Introductory text: 2026 asp 13 and Royal Assent on 12 May 2026 (Aesthetics LAW reform watch)
  30. SSI 2026/206 reg 2 and Schedule (Commencement No. 1 and Saving Provision) (Aesthetics LAW reform watch)
  31. Act s. 24(2) and (4): s. 3 remains to be commenced and no appointed day may be earlier than 6 September 2027 (Aesthetics LAW reform watch)
  32. asp 13 ss.3, 4, 24(4), Sch 1 paras 4 and 12; SSI 2026/87 Sch 1 (AESTHETICS hard cases)
  33. Care Standards Act 2000 s.11 (AESTHETICS hard cases)
  34. ELCI Act 1969; ELCI Regulations 1998 regs 3 and 5 (Insurance and claims)
  35. Employers' Liability (Compulsory Insurance) Act 1969 s.2(1) (employee: contract of service or apprenticeship) (Insurance and claims)
  36. Dentists Act 1984 ss.37 and 38 (Pitfalls that embarrass the product)
  37. NMC remote prescribing position for non-surgical cosmetic medicines (Pitfalls that embarrass the product)
  38. VATA 1994 Sch. 9 Group 1 item 1(ma); VATLP19810, 1 October 2012 legislative change; VATLP19820, chair, room or space and related services (Pitfalls that embarrass the product)
  39. Employment (Allocation of Tips) Act 2023 (Pitfalls that embarrass the product)
  40. Employers Liability (Compulsory Insurance) Act 1969 s.1 (Pitfalls that embarrass the product)

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