UK RAG Risk-Based Licensing: What It Means for Aesthetic Practitioners
Overview of how the proposed UK Red–Amber–Green (RAG) licensing system would affect different practitioner roles.
At-a-Glance Comparison
This side-by-side table summarises how the proposed RAG framework would apply to an Aesthetic Nurse Prescriber, a Non-Prescribing Nurse, and a Doctor.
| Risk Category | Example Procedures | Aesthetic Nurse Prescriber (regulated, can prescribe) |
Non-Prescribing Nurse (regulated, can’t prescribe) |
Doctor (regulated, can prescribe) |
|---|---|---|---|---|
| RED (High Risk) | Thread lifting, hair restoration surgery, IV injectables/infusions, high-risk filler areas, liquid BBL | ✅ Can perform if in a CQC-registered setting and meets training/insurance requirements. Can prescribe any required meds themselves. | ❌ Cannot perform independently unless under a prescriber’s direct clinical oversight and within a CQC-registered setting. Cannot prescribe—would need doctor or nurse prescriber on site. | ✅ Can perform if in CQC-registered setting and meets standards. Can prescribe all required meds themselves. |
| AMBER (Medium Risk) | Botox, dermal fillers, weight-loss injections | ✅ Can perform independently if trained/licensed. Can assess, prescribe, and treat without another clinician present. | ⚠️ Can perform but only under a prescriber’s oversight—needs prescriptions and protocols signed by a doctor or nurse prescriber. | ✅ Can perform independently; can prescribe directly. |
| GREEN (Low Risk) | Microneedling, superficial chemical peels, “no-needle” fillers, semi-permanent makeup | ✅ Can perform independently with practitioner & premises licence. | ✅ Can perform independently with practitioner & premises licence (no prescribing needed). | ✅ Can perform independently with practitioner & premises licence. |
Key Takeaways
- Prescribing power is the main differentiator for RED & AMBER categories.
- Non-prescribing nurses will need a formal prescribing partner (doctor or nurse prescriber) for any treatment requiring POMs or advanced protocols.
- Doctors and nurse prescribers can work more autonomously in both RED and AMBER categories, provided they meet CQC and licensing requirements.
- GREEN procedures are open to all three groups, but still require local authority practitioner and premises licences.
Aesthetic Practice Compliance Checklist by Practitioner Type
| Role | Red (High Risk) | Amber (Medium Risk) | Green (Low Risk) |
|---|---|---|---|
| Aesthetic Nurse Prescriber | • Must operate within CQC-registered premises. • Allowed to perform procedures. • Must meet training, indemnity, hygiene, and licensing standards. |
• Can perform independently if fully licensed and qualified. • Must meet local authority practitioner and premises licensing. |
• Can perform independently with practitioner & premises licences. |
| Non-Prescribing Nurse | • Cannot perform independently. • Must work under direct clinical oversight of a qualified prescriber within a CQC-registered setting. • Cannot prescribe. |
• Can perform but only under oversight of a prescriber (doctor or nurse prescriber). • Needs a practitioner licence and premises licence too. |
• Can perform independently with practitioner & premises licences, since no prescribing needed. |
| Doctor | • Must operate within CQC-registered premises. • Can perform procedures with appropriate training and licensing. |
• Can perform independently with proper practitioner and premises licences. | • Can perform independently with practitioner & premises licences. |
Additional Mandatory Requirements for All Roles (where applicable)
- Face-to-face consultations required for prescribing: Nurse (and midwife) prescribers must see patients in person and document a proper clinical assessment before prescribing for cosmetic procedures.
- High-risk procedures restricted to healthcare professionals: Only regulated professionals may perform Red-category treatments—and these must be delivered in CQC-regulated environments.
- Licensing for lower-risk procedures: Amber and Green procedures fall under local authority licensing, requiring both practitioner and premises licences.
- Age restrictions for under-18s: Red procedures cannot be performed on minors (under 18) unless approved by a GMC-registered doctor; similar restrictions are expected for Amber/Green.
Summary: What You Need to Focus On
- Non-prescribing nurses: always work under oversight for anything involving POMs or high-risk procedures.
- Nurse prescribers & doctors: greater autonomy, but ensure practice and premises are appropriately licensed and CQC-compliant.
- All practitioners: prepare for local authority licensing, ensure face-to-face consultations where required, and maintain high standards of training, indemnity, and hygiene.
If you’d like, we can also map out a role-specific compliance checklist with step-by-step actions to get fully prepared for the new framework.
