Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill

Closes 14 Nov 2025

Opened 10 Oct 2025

Contact

Health, Social Care and Sport Committee

hscs.committee@parliament.scot

Overview

The Health, Social Care and Sport Committee is seeking views on the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill.
 
The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill was introduced to the Scottish Parliament by the Scottish Government on 8 October 2025. The Bill comprises two parts: 

  • Part 1 of the Bill is intended to regulate the provision of certain non-surgical procedures. 
     
  • Part 2 of the Bill is unrelated to Part 1 and proposes minor changes to the death certificate regime in Scotland.

Read more background information

How to contribute 

Please answer the call for views by completing the submission form below.  

You can respond to the questions on Part 1 of the Bill only, the questions on Part 2 of the Bill only, or both.

If you are having difficulties completing the online form, please contact the Committee at hscs.committee@parliament.scot.

We welcome written views in English, Gaelic, Scots or any other language.  

You can also give your views to the Committee in a BSL video. If you send a video, we will arrange for a translation and pay for this. You can send a video through a file transfer service such as WeTransfer, or upload to YouTube and share it as a private link with us by email.  

Watch our BSL users guide

About this call for views

Part 1: Regulation of non-surgical procedures

The main purpose of Part 1 of the Bill is to regulate the non-surgical cosmetic procedures industry. 

The Bill proposes that certain defined non-surgical procedures should only be permitted to be carried out in a registered healthcare setting. 

The Bill would also prohibit under-18s from receiving these procedures.  

The Bill also gives the Scottish Government powers, through regulations, to make other future changes to the regulation of non-surgical procedures. 

Your views will inform the Committee’s scrutiny. 

The call for views and analysis: 

  • aim to help the Committee understand the reasons people have for either supporting or opposing the Bill
     
  • aim to help the Committee understand how people would like to see the Bill amended
     
  • will not establish whether more people support or oppose the Bill 

Part 1 of the Bill seeks to regulate certain non-surgical procedures (procedures that pierce or penetrate the skin). Procedures covered by the Bill include:  

  1. Ablative laser treatment e.g. laser skin resurfacing 

  1. Cellulite subcision e.g. cellulite dimple removal or Cellfina® 

  1. Chemical peel e.g. skin peel or facial peel 

  1. Dermal microcoring e.g. Ellacor® Treatment, removal of tiny cores of skin using hollow needles.  

  1. Injectable procedure e.g. Botox® injections, dermal fillers (including non-surgical Brazilian Butt Lift) 

  1. Intravenous procedure e.g. IV drip therapy, beauty IV drips 

  1. Microneedling e.g. skin needling, Dermapen® microneedling 

  1. Thread Lift e.g. PDO (Polydioxanone), PLLA (Poly-L-Lactic Acid), cat or fox eye thread lift 

The Bill stipulates that these procedures can only legally be provided in “permitted premises” which are defined as follows: 

  • an independent hospital that is registered with Health Improvement Scotland (HIS), or 

  • an independent clinic that is registered with HIS and where services are provided or managed by a registered medical or dental practitioner, a registered nurse or midwife who is an independent prescriber or a pharmacist independent prescriber, or 

  • GP and dental practices which provide NHS services and registered pharmacies, which are exempt from the requirement to register with HIS under the 1978 Act and are often already regulated by the NHS and/or professional regulatory bodies. 

The Bill also makes it a criminal offence: 

  1. For a person to provide any of these procedures outwith a “permitted premises”; and 

  1. For a person to provide any of these procedures to someone under the age of 18. 

The Bill also allows for additional regulation of non-surgical procedures. This includes changing the list of procedures covered by the Bill, who can provide these procedures, training and qualification requirements, and the creation of additional offences.  

Separate from this Bill, the Scottish Government proposes to introduce a licensing scheme for non-surgical procedures that are defined as “lower risk” than those procedures listed in the Bill, via an order under the Civic Government (Scotland) Act 1982. 

Who we would like to hear from

We welcome responses from a wide range of individuals and organisations, including: 

  • Those who use these treatments, whether they have had a positive or negative experience, and about how the proposed changes could impact them. 

  • Business owners and those who administer non-surgical cosmetic procedures.  

  • Health organisations and health professionals about the proposals in the Bill. 

Questions about Part 1 of the Bill

Part 1 of the Bill: Non-surgical procedures 

1. In your view, what impact will the Bill have on: 

  1. People wishing to access non-surgical procedures detailed in Schedule 1?
  2. The level of risk to people who wish to access these procedures? 
  3. Local businesses and individual practitioners? 
  4. Organisations and staff who currently operate within a premises that meets the definition of permitted premises? 

2. What are your views on inspection, offences and enforcement powers set out in the Bill? For example, do you think they are fair and appropriate?  

3. Do you have any further comments about Part 1 of the Bill?

Part 2: Functions of Medical Reviewers

The purpose of Part 2 is to change the circumstances in which a review of a death certificate can be requested, and the reasons such a request can be rejected. It also does away with the need for additional checks by a medical reviewer in Scotland where someone has died elsewhere in the UK and is to be cremated in Scotland.  

The Bill will amend the Certification of Death (Scotland) Act 2011—  

  • to extend the circumstances in which an interested person can request a review of a Medical Certificate of Cause of Death (MCCD) and to extend the power of medical reviewers to reject an application, and
       
  • to remove the requirement for a medical reviewer to authorise cremation of a person’s body in Scotland where that person has died outwith Scotland but within the United Kingdom.

Who we would like to hear from

We welcome responses from individuals and organisations who may be affected by these changes. 

Questions about Part 2 of the Bill

Part 2 of the Bill: Certification of death and authorisation of cremation 

1. What are your views on the Bill’s amendments to the two following aspects of the Certification of Death (Scotland) Act 2011: 

  1. To extend the circumstances in which an interested person can request a review of a Medical Certificate of Cause of Death (MCCD) and to extend the power of medical reviewers to reject an application. 
  2. To remove the requirement for a medical reviewer to authorise cremation of a person’s body in Scotland where that person has died outwith Scotland but within the United Kingdom. 

2. Do you have any further comments about Part 2 of the Bill?

Analysis 

The Scottish Parliament Information Centre (SPICe) will prepare a summary and analysis of responses. 

If we receive a very high volume of submissions, this may need to be prepared based on a sample of submissions.

Confidentiality and publication of responses 

Please let us know if you wish your response to remain confidential. You can also ask for your submission to be anonymised. 

We aim to publish all the submissions we receive. The only exceptions are where submissions are made on a “confidential” or “not for publication” basis.  

If we receive a very high volume of submissions, we may not have the resources to process and publish them all.

The call for views closes on 14 November 2025

Submit your views

Complete the submission form

Interests

  • HSCS