The Nursing and Midwifery Council (NMC), has introduced new guidance that will promote safer prescribing practice for aesthetics practitioners within the UK. Starting from 1 June 2025, all independent nurse or midwife prescribers will be required to have an in-person consultation with the patient before prescribing any Botox treatments marking the end of remote prescribing.

What is Botox?

Botox, or Botulinum toxin, is a neurotoxin that functions by blocking nerve signals to muscles, resulting in temporary muscle paralysis or relaxation. It is mainly used for cosmetic purposes to reduce or prevent wrinkles but can be used medically to treat excessive sweating, migraines, and bladder conditions.

Who is authorised to prescribe Botox?

Botox is a ‘Prescription-Only Medication’ (POM) that must be prescribed solely by a suitably qualified prescriber. The new prescribing standards are intended to eliminate remote prescribing practices that lead to prescriptions being issued without proper assessment of the/a patient’s skin, facial expressions, or medical background. During a consultation, Prescribers should:

• Review the patient’s medical history and current health status;
• Perform a physical examination of the treatment areas;
• Discuss the patient’s aesthetic aspirations and set realistic expectations;
• Provide comprehensive information regarding potential risks, benefits, and aftercare instructions.

Who can administer Botox? 

• A Prescriber
• A qualified medical professional acting under a Prescriber’s supervision
• A non-medical professional working under a Prescriber’s guidance

The new standards aim to enhance safety standards across the aesthetics industry as well to hold those who do continue to prescribe remotely accountable. Despite the new guidelines the administration of Botox can still be performed by individuals regardless of their professional background or experience. Ultimately, it is the Prescriber's responsibility to ensure safe administration of Botox, whether they personally deliver the treatment or delegate it to another practitioner. This arrangement relies heavily on trust, as in cases of adverse outcomes or patient dissatisfaction, the Prescriber bears the liability, a concern for many injectors. Concerns have been raised as to whether these stricter regulations will lead to an increase in black-market products being administered to patients as an attempt bypass the need for a face-to-face consultation, keeping costs low and allowing a quicker turnaround time for injectors.

What actions should be taken if regulations are breached?

If it is suspected that Botox has been administered without a face-to-face consultation with a suitably qualified Prescriber, or if a Prescriber has issued a prescription without assessing the patient in person, the NMC may open an investigation. Should breaches of the new standards be identified then this could lead to fitness to practise proceedings that could lead to a loss of professional registration as well as significant reputational damage.