Since 1 June 2025, all prescribers must conduct a face-to-face consultation before prescribing Botox and anti-wrinkle injectables. Remote prescribing for these treatments is a regulatory breach. If your clinic uses a prescribing partner, this affects you directly.
What changed
This is not an upcoming change. It is already in force and has been since 1 June 2025. From that date, all nursing and midwifery prescribers must conduct an in-person consultation before prescribing non-surgical cosmetic medicines — including botulinum toxin (anti-wrinkle injections) and related aesthetic injectables. The widespread practice of remote prescribing, where a prescribing partner reviewed photographs or questionnaires online and issued a prescription without seeing the patient, is now a regulatory breach under the Nursing and Midwifery Council Code.
This requirement applies at every prescribing event — not just at an initial consultation. Each time a prescription for these treatments is issued, the prescriber must have physically seen and assessed the patient. There is no exception for existing clients.
For aesthetics practitioners who do not personally hold prescribing qualifications, the business model depends on a compliant prescribing partner. It is your responsibility to satisfy yourself that they are following this rule. A prescription issued in breach of the NMC requirement is not a valid prescription. A treatment carried out under an invalid prescription creates professional and insurance liability that travels to every party in the chain — the prescriber, the clinic, and the practitioner who administered the treatment.
The safest arrangement is a written protocol with your prescribing partner confirming that in-person consultation is completed and documented before every prescribing event, with those records kept as part of the client file alongside consent forms. If you are considering internalising the prescribing step by obtaining your own qualifications, the forthcoming licensing framework makes this an increasingly sound commercial and compliance investment.
Who this affects
Aesthetics practitioners, prescribing partners
Regulatory body: MHRA / Nursing and Midwifery Council
What businesses should review
- In force: 1 June 2025. Already law.
- Action now: Obtain written confirmation from your prescribing partner that they are conducting in-person consultations. Make this protocol part of your standard clinic operating procedure. Keep prescribing consultation records for every client alongside their consent documentation.
- Consequence: An NMC-registered prescriber in breach faces investigation, conditions on practice, suspension, or striking off. The clinic and practitioner using the prescription face insurance liability and potential regulatory action when the licensing scheme comes into force.