A leading plastic surgeon has warned that Scotland's new laws on botox and Brazilian butt lifts could fall short of protecting patients. The warning comes following the introduction of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026, which received Royal Assent in May after being passed by MSPs.
New Restrictions on Cosmetic Treatments
The legislation will introduce new restrictions on where a number of popular cosmetic treatments can be performed, alongside protections preventing under-18s from undergoing covered procedures. Under the new law, it will be an offence to deliver treatments to someone under the age of 18, or to perform them outwith a permitted premises, with a maximum fine of £20,000.
Non-surgical cosmetic procedures will only be allowed in NHS GP practices, dentists and pharmacies, as well as private hospitals and clinics if they are registered with Healthcare Improvement Scotland.
Expert Concerns Over Patient Safety
Dr Omar Tillo, Medical Director and Plastic Surgeon at CREO Clinic on London's Harley Street, said: "Scotland's new legislation is a welcome development, but there is still work to be done to ensure patients are properly protected. The real challenge is turning these new rules into meaningful protections for patients, rather than simply creating another layer of regulation."
Dr Tillo highlighted the risks associated with liquid Brazilian butt lifts (BBLs), which involve injecting substantial amounts of filler into the buttocks. He noted that these procedures require working around complex anatomy and major blood vessels, where mistakes can have devastating consequences.
Training and Competency Standards
Currently, there is no requirement for people to complete training before delivering non-surgical procedures, with the Scottish government estimating that there could be up to 1,500 businesses carrying out unregulated procedures in Scotland. Dr Tillo emphasised the need for procedure-specific training and competency standards rather than relying solely on general professional qualifications or the setting in which treatments are performed.
Advice Direct Scotland recently warned that children as young as 15 were seeking help following botched botox treatments and dermal fillers. Dr Tillo added: "Young people should not be encouraged to make decisions about invasive procedures based on unrealistic expectations or online trends. Patients also have a responsibility to ask questions, but the industry needs to make it easier for them to make informed choices."
The Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill was passed with 124 MSPs in favour and none against in a vote at Holyrood.
