Your tattooist needs a licence. The person injecting your face doesn't.

If you walk into a studio in Cardiff for a tattoo, a cosmetic piercing, semi-permanent make-up or electrolysis, the person treating you must hold a licence issued by the local authority. Their premises must be approved. Working without one is an offence.

If you walk into the unit next door for botulinum toxin or dermal filler, none of that applies.

That is not an oversight anyone is hiding. It is the settled legal position in Wales, and on 15 October 2026 the Senedd's own research service set it out plainly in a briefing on whether current arrangements remain fit for purpose. Scotland passed its legislation in March 2026. England has committed to a licensing scheme and is still working out how it will run. Wales and Northern Ireland have announced nothing equivalent.

We have written before about illegal toxin and the regulation gap, and about what happens when the industry looks the other way. This is the specifically Welsh version of that problem, and it is worth understanding before you book anything with anyone.

Is Botox regulated in Wales?

Only partly, and less than most patients assume. Botulinum toxin is a prescription-only medicine UK-wide, so it must be prescribed by a prescriber who has personally assessed you — that requirement is real and enforceable. But Wales has no licensing scheme covering injectables. Part 4 of the Public Health (Wales) Act 2017 came into force on 29 November 2024 and licenses exactly four special procedures: acupuncture, body piercing, electrolysis and tattooing including semi-permanent make-up. Injectables are not on that list, so no premises approval or practitioner licence is required to inject a face in Wales. Dermal filler is a device, not a medicine, and carries no prescription requirement at all. Check your injector's GMC or NMC registration number and the licensed brand in the vial before treatment; our team is happy to answer both at consultation.

What Wales actually licenses

The Public Health (Wales) Act 2017 created a mandatory licensing scheme for what the legislation calls "special procedures": acupuncture, body piercing, electrolysis, and tattooing including semi-permanent make-up. Practitioners must be licensed. Premises must be approved. Local authorities enforce it.

Injectable cosmetic treatments are not on that list.

The Act does contain the power to add further procedures to the scheme where it is necessary to protect public health. That power has not been used for injectables. In its 2026 Wales manifesto, the Professional Standards Authority called for the scheme to be extended to cover non-surgical cosmetic procedures. As things stand, it has not been.

So in Wales today, the legal threshold for microblading someone's eyebrows is higher than the legal threshold for injecting a prescription medicine into their face.

The argument that Wales cannot act

There is a genuine constitutional complication here, and it deserves stating fairly rather than being used as a shield.

The Welsh Government cannot regulate medicines. It cannot approve medical devices. It cannot regulate doctors, nurses or dentists. Botulinum toxin's status as a prescription-only medicine, the licensing of dermal fillers as devices, and the professional registers themselves are all reserved to the UK Government and UK-wide regulators.

But premises standards, practitioner competence requirements and local authority enforcement are devolved. That is precisely the ground the special procedures scheme already occupies. The power to extend it exists in an Act that has been on the statute book since 2017. The limitation is real, but it is narrower than "Wales has to wait for Westminster."

This is not a new problem

The Keogh review examined the regulation of cosmetic interventions in 2013. It found practitioners could carry out dermal filler treatments with no requirement for training, qualifications or prior experience, and described the dermal filler market as a crisis waiting to happen.

That was thirteen years ago. The requirement is still absent.

In 2026 the UK Parliament's Women and Equalities Committee returned to the subject and described parts of the sector as a "wild west", citing evidence of procedures carried out in Airbnbs, hotel rooms, garden sheds and public toilets, with people seriously harmed as a result. Its follow-up report in September 2026 asked the UK Government to restrict the highest-risk procedures immediately and to publish a timetable for wider reform.

Meanwhile the market keeps growing, and the data on how many procedures are performed, how often they go wrong, and what the NHS spends repairing them remains thin to the point of absence.

Where the line actually falls

It helps to be precise about what is and is not controlled, because the two injectables most people ask about sit on opposite sides of the line.

Botulinum toxin is a prescription-only medicine. It must be prescribed by a prescriber who has assessed the patient. That is a real legal requirement with real teeth, and it is the single most commonly broken rule in this industry. A prescription written for someone the prescriber has never assessed is not a safeguard, it is paperwork.

Dermal filler is not a medicine. It is a device. There is no prescription requirement, no mandatory training standard, and nothing in law preventing someone with no clinical background from buying it and injecting it into a face. This is why filler complications are the ones that produce the worst outcomes and the hardest rescues.

Which means the question "is it regulated?" has two different answers depending on what is in the syringe, and neither answer is the one most patients assume.

Why the product in the vial matters more than the price on the sign

The regulation gap is not an abstraction. In summer 2025 it produced a public health incident.

Between 4 June and 6 August 2025, UKHSA confirmed 41 cases of iatrogenic botulism across five English regions: the North East, East Midlands, East of England, North West, and Yorkshire and Humber.

Most of those affected had received products not licensed for use in the UK. A separate investigation into 25 cases in the North East found a strong association with one unlicensed product, and when seized vials were tested, they measured 370 units against a label stating 200.

Read that figure again. Patients received close to double the dose they and their injector believed was being given. Botulism is not a bruise or a dropped brow. It can affect swallowing and breathing, symptoms can be delayed, and it is a medical emergency.

In July 2026 the MHRA strengthened the safety warnings across every licensed botulinum toxin product in the UK, and issued a separate alert about the substantially greater risks of counterfeit and unauthorised products. Its Criminal Enforcement Unit has opened multiple investigations into the illegal sale and supply of unlicensed toxin.

The point the MHRA made, and the one worth holding onto, is that the danger was not botulinum toxin. Licensed toxin has decades of evidence behind it. The danger was a supply chain that nobody was checking.

What we do, and why we publish it

We work only with UK-licensed pharmacies and official distributors. The toxins we use are MHRA-licensed: Azzalureand Alluzience. We are a Galderma partner clinic. Every injectable treatment is carried out by GMC or NMC-registered medical professionals holding Level 7 in Aesthetic Medicine, with 24 years of healthcare experience including emergency medicine and over a decade in full-time medical aesthetics.

We also decline products. We explained why we are not offering Relfydess despite it being a licensed product from a manufacturer we work with closely. A clinic that has never turned anything down is telling you something.

None of that is a legal requirement in Wales. That is exactly why we put it in writing.

What to ask before anyone injects you

You are currently the regulator. Until that changes, these are the questions that do the work.

What is your registration number, and which register? GMC and NMC registers are public and searchable in under a minute. Not "medically trained", not "clinically qualified" — a number, on a register you can check yourself.

What product are you using, and is it licensed for use in the UK? You are entitled to the brand name. If the answer is vague, or the product is one you cannot find on the MHRA's register, stop there.

Who prescribed it, and did they assess me? For toxin, the prescriber must have assessed you. If you have never met or spoken to the person who wrote the prescription, something has gone wrong.

What happens if there is a complication? A vascular occlusion with filler is a time-critical emergency. The clinic should be able to tell you what they hold on site, who manages it, and how quickly you would be seen.

Where is the treatment taking place? A clinical room, not a kitchen table, a hotel room or the back of a salon.

A clinic that finds these questions irritating has answered them.

The bit that will not fix itself

Regulation in Wales will change eventually. Scotland has moved, England is moving, the pressure from the Professional Standards Authority and from Westminster committees is consistent, and the power to extend the Welsh scheme already exists. But "eventually" is doing a lot of work in that sentence, and nobody has published a date.

Until then, the gap between what the law requires and what good practice requires is wide, and you are the one standing in it. The clinics worth your money are the ones closing that gap voluntarily, and saying out loud what they use and where it comes from.

You can see our full treatment list and prices, read more about the clinic and our standards, or book an appointment. If you would rather ask a question first, contact us.