Freedom of Information – Healthcare Improvement Scotland capacity to regulate aesthetics services and cosmetic treatments: September 2026
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Request
Freedom of Information (Scotland) Act 2002
In your email of 17 August 2026, you asked a range of questions related to HIS’s operational capacity to implement the proposed expansion of regulation of non-surgical cosmetic procedures.
Response
Healthcare Improvement Scotland (HIS) have considered your request and are pleased to provide you the following information:
1. The estimated number of additional services, businesses or premises expected to require HIS registration as a result of the proposed regulatory arrangements.
Response: No recorded information held.
As stated in the attached disclosure “Non-Surgical Procedures Bill, IHC [Independent Healthcare] Considerations” (Appendix 1), Healthcare Improvement Scotland does not currently have a reliable means of determining the size, scale or distribution of aesthetic and other non-surgical service providers who may seek to register as independent healthcare services.
2. Any estimates or forecasts of the number of new registration applications expected, broken down by year or implementation period where held.
Response: No recorded information held.
As stated in the same disclosure, there is currently an intelligence and evidence gap regarding the size of the future regulated population and it notes that further scoping work is required before workforce modelling and cost estimation can be undertaken.
3. The current number of staff responsible for processing registrations and inspecting relevant independent healthcare services.
Response: Healthcare Improvement Scotland regulates independent healthcare services as defined in legislation. Staffing within the Independent Healthcare Team is not allocated separately to registration, inspection or other regulatory activities. Staff undertake a range of regulatory responsibilities across the regulation of independent healthcare services as required.
The current staffing establishment at the time of this response is:
| Role | Headcount | WTE |
|---|---|---|
| Chief Inspector | 1 | 1 |
| Head of Regulation | 1 | 1 |
| Senior Inspector | 4 | 3.3 |
| Programme Manager | 3 | 3.0 |
| Inspector | 15 | 14.4 |
| Project Officer | 2 | 2.0 |
| Administrative Officer | 3 | 2.5 |
4. Any workforce planning identifying additional registration, inspection, administrative or other staff required to implement the proposed arrangements.
Response: Recorded information is held.
Please see the attached disclosure Non-Surgical Procedures Bill – IHC Considerations” (Appendix 1) and information below from section 5.1 of the May 2026 QARD [Quality Assurance and Regulation Directorate] Directorate Management Team minutes which contain information regarding workforce planning, resource requirements and the development of business cases associated with implementation of the Non-Surgical Procedures and Functions of Medical Reviewers (Scotland) Act 2026.
5.1 Non-Surgical Procedures Digital Scoping Business Case
The first of two draft business cases Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Act was brought to DMT for approval to then proceed to ET.
HIS does not currently have a credible or defensible evidence base to estimate the size, scale, distribution or operating models of non-surgical procedure services that may fall within scope of Part 1 of the Bill. Therefore, Scottish Government policy team has requested an initial business case to be considered in advance of the next quarterly sponsor meeting. This first business case is to request resources for scoping and planning work required for the new regulatory responsibilities and includes one programme manager to support the work. The scoping work will then inform the second business case which will focus on enforcement and associated resources, this is likely to be developed Autumn. DMT confirmed the business case is fully supported and can now proceed to ET on 2 June.
5. Any assessment or modelling of the additional inspection workload arising from the proposed arrangements.
Response: No recorded information held.
As noted in Appendix 1, Healthcare Improvement Scotland does not currently have a reliable means of determining the size, scale or distribution of providers who may fall within scope of the legislation and that further scoping work is required to support implementation planning and workforce modelling.
6. Any estimates of expected registration processing times following implementation.
Response: No recorded information held.
No estimates of future registration processing times following implementation were identified in the records held.
7. Records of any current registration backlog and any assessment of how the proposed expansion may affect existing processing times.
Response: Healthcare Improvement Scotland does not hold recorded information assessing how the proposed expansion may affect existing registration processing times.
As at the date of this response, 18 registration applications which are ready for allocation are awaiting assignment to an inspector. We consider this our current backlog of registrations.
No recorded modelling or assessment has been identified regarding the impact of the proposed expansion on existing processing times.
8. Any budget, financial estimate or resource assessment relating to the additional regulatory functions.
Response: Please see attached Appendix 1, the extract from the May DMT minutes above in our response to Q4 and an extract from the April QARD Directorate Management Team minutes below.
5.2 Non-Surgical Procedures Bill – IHC Considerations
Paper circulated with agenda to provide an update to DMT on the implications of Part 1 of the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill (NSP Bill) for Independent Healthcare (IHC), to discuss the potential implications and to seek agreement to develop a business case for submission to the Scottish Government to secure appropriate funding to support HIS’ new and extended responsibilities arising from the Bill.
DMT were asked to:
• Note the implications of Part 1 of the NSP Bill for the IHC function and discuss what wider organisational or external support is sought to scope the impact, this will likely result in an initial business case request to SG to commence NSP scoping.
• Agree that a future business case is developed for submission to the Scottish Government, setting out the resource, workforce, and associated costs required to enable HIS to deliver its new and extended regulatory and enforcement responsibilities under the Bill.
• Immediate need for communications support, aligned to SG guidance for business, to address current registered services and messaging for applications of independent clinics who seek to provide NSPs following the pre-election period.
• Acknowledge this work is likely to being taken forward as part of wider implementation and financial planning for 2027/28, including alignment with enforcement capability development and fee setting considerations.
DMT noted the above and confirmed that content with the two-pronged business case approach.
9. Any risk register, risk assessment or equivalent record identifying capacity, staffing, recruitment, registration-delay or inspection risks associated with implementation.
Response: Please see response to previous question above and Healthcare Improvement Scotland has recorded a relevant risk on the QARD risk register. Please see Appendix 2.
10. Any contingency planning for circumstances in which the number of applications exceeds HIS’s available registration or inspection capacity.
Response: No recorded information held.
11. Any assessment of whether insufficient HIS capacity could delay businesses obtaining registration or prevent affected businesses from continuing to provide procedures during implementation.
Response: No recorded information held.
12. Any recorded assessment of whether HIS presently has sufficient staffing, resources and operational capacity to implement the proposed regulatory arrangements within the intended timetable.
Response: Please see Appendix 1 and the extracted information contained within our response.
Applied exemptions
The following exemptions have been applied to this response. If you wish to learn more about the relevant exemptions please visit the Scottish Information Commissioners website using the links below. You will leave the HIS website: FOISA exemptions
Section 17 – Information not held Information not held – Exemption 17(1)
Reviews and Appeals
For more information on our reviews and appeals, please visit: Freedom of information reviews and appeals – Healthcare Improvement Scotland