Introduction
Since 1 June 2025, the Nursing and Midwifery Council (NMC) has enforced a binding professional standard requiring every independent nurse and midwife prescriber to see patients in person before issuing prescriptions for elective, non-surgical cosmetic injectables1. Although remote prescribing remains legally permissible under the Human Medicines Regulations, the NMC’s position makes clear that any breach (however well-intentioned) can prompt a “Fitness to Practise” investigation and even result in being struck off the register, effectively ending one’s career2. This article, explores the background, rationale, and scope of the change, distinguishes legal permissibility from professional obligation, examines its impact on all clinical roles, and offers practical guidance to safeguard your registration.
From Advisory Guidance to Mandatory Standard
For several years, both the NMC and the JCCP have recommended that face-to-face consultations represent best practice when prescribing any high-risk medicine, particularly cosmetic injectables. As early as June 2022, the guidance was unequivocal: prescribers should not issue injectable prescription-only medicines (POM) to patients they have not personally examined1. Despite these strong recommendations, remote prescribing continued to gain traction. While high-profile “Fitness to Practise” cases, most notably that of Heather Hazzard, whose striking-off highlighted risks of remote prescribing, improper delegation and inadequate patient assessment, ultimately catalysed a shift from advisory guidance to a mandatory NMC requirement2.
Why the NMC Took This Step
In 2024, the NMC commissioned independent public-facing research by the agency Thinks, engaging both people who had experienced non-surgical cosmetic procedures and those who had not. The findings showed overwhelming public support for strengthening face-to-face requirements to protect safety and a clear lack of confidence that purely remote assessments could capture the clinical nuances of dynamic muscle movement and vascular anatomy3. A subsequent stakeholder roundtable, with representation from prescribers, aesthetic practitioners, industry bodies and regulatory experts concluded unanimously that only a hands-on assessment could reliably mitigate complications such as vascular occlusion or infection. As one NMC representative stated, “Face-to-face consultations will further improve prescribers’ ability to assess people holistically and ensure non-surgical cosmetic medicines are prescribed as safely and appropriately”4.
Scope of the NMC’s New Position
The NMC’s position statement, effective 1 June 2025, applies specifically to all elective, non-surgical cosmetic injectables applying to prescriptions for5:
• Botulinum toxin injections
• Local anaesthetics (injected or topical)
• Topical adrenaline
• Kenalog (for hay fever or dermatological use)
• Emergency aesthetic medications such as Hyalase
What was previously a strong recommendation has become an explicit embargo on any remote prescribing for these treatments. That is whether via telephone, video call, email or third-party platforms, where it now covers every stage of care, from the initial consultation through to follow-up prescriptions5.
Each prescribing episode must now be preceded by a documented, face-to-face assessment in which the prescriber examines facial anatomy, assesses skin integrity, reviews medical history and secures fully informed consent. Aftercare arrangements must be laid out and further in-person reviews conducted as clinically necessary6. By specifying every element, the NMC has removed ambiguity, ensuring consistent application across the profession.
Legal Permissibility Versus Regulatory Obligation:
It is crucial to recognise that the NMC’s embargo does not equate to a legal prohibition. Remote prescribing of POMs outside the cosmetic sphere remains lawful under UK medicines legislation. What has changed is the NMC’s stance: continuing to prescribe cosmetic injectables remotely is now deemed professional misconduct, carrying the risk of disciplinary proceedings, public censure, conditions being placed on one’s practice or removal from the register. In effect, while you would not face criminal charges, you would face the most serious threat to your professional life2.
In short consequences may include:
Any clinician who dispenses or injects based on a prescription issued remotely also jeopardises patient safety and risks disciplinary action that could damage their professional reputation. Moreover, most indemnity policies stipulate full adherence to regulatory and legal prescribing standards. Should a claim arise and it’s shown that face-to-face protocols weren’t followed, an insurer may deny cover, leaving the practitioner personally responsible for all associated costs6.
Practical Implications for Clinical Roles:
Independent nurse and midwife prescribers bear the ultimate responsibility for safe prescribing. Under the new standard, any delegation to non-prescribing colleagues requires clear supervision, documented competency checks and oversight at every stage7. For clinics that employ non-prescribers to administer injectables, this means restructuring booking processes so that every patient has an in-person appointment with a qualified prescriber before treatment. Prescribers must issue patient-specific directions only after that consultation. This operational shift affects appointment flows and record-keeping processes, ensuring that no patient arrives for treatment without a compliant, documented face-to-face assessment.
Safeguarding Your PIN: Five Key Actions
To remain fully compliant and protect your PIN under the NMC’s face-to-face mandate, focus on these five critical areas:
- Audit & Update Protocols
- Team Training & Role Clarification
- Structured Documentation
- Ensure Standards of Delegation8,9
- Leverage NMC and JCCP Resources
These steps will help you embed the face-to-face requirement seamlessly into your clinic’s routine, ensuring patient safety, regulatory compliance, and the continued security of your registration.
Continuous Professional Development and Competency
As you adapt to this new standard, consider enhancing your own qualifications. Non-prescribing nurses may find real value in enrolling on an independent prescribing course, which not only streamlines patient pathways and bolsters professional autonomy, but also profoundly deepens clinical understanding. I completed mine 15 years ago and know firsthand how daunting such a rigorous course can feel; yet the stretch-learning it provided was transformative for my practice. It challenged me to refine my decision-making, exposed me to new pharmacological insights, and ultimately reinforced that with dedication, anything is possible.
Beyond formal qualifications, incorporate regular OSCE-style assessments into your CPD plan. Focus on facial anatomy, aseptic technique and emergency complication management to ensure hands-on competence. Finally, use each face-to-face prescribing consultation as reflective material for your revalidation portfolio: document the challenges you encountered, the solutions you implemented and the patient outcomes achieved. This structured reflection will not only meet NMC requirements but also drive continuous improvement in your practice.
Building Patient Trust Through Engagement:
Patients appreciate transparency. From the very first inquiry, explain that the NMC now requires an in-person consultation to ensure their safety and the best possible aesthetic outcome. Emphasise that this step is not a barrier to care, but an essential safeguard: only by examining facial dynamics, skin health and medical history in person can a prescriber deliver a treatment plan tailored to each individual. Providing digital information packs in advance and offering flexible appointment times helps mitigate any inconvenience, reinforcing that their well-being is your highest priority.
Frequently Asked Questions:
Is this a total ban on remote prescribing?
No. The embargo applies exclusively to elective, non-surgical cosmetic injectables. All other therapeutic areas, such as chronic disease management, acute infections or mental health prescribing continue under the existing legal framework for safe remote consultations8,9.
Can emergency medical treatments still be prescribed remotely?
Yes. This change does not affect the legal frameworks governing true medical emergencies, which remain subject to established clinical governance protocols8,9.
How will the NMC verify compliance?
Through routine revalidation audits, random record inspections and, when concerns are raised, formal Fitness to Practise investigations. Rigorous documentation, including complete, clear, and contemporaneous is your primary safeguard8,9.
Are multi-disciplinary teams exempt?
No. Even within teams, independent prescribers remain personally accountable for any delegation. Non-prescribers may only administer injectables under a documented, patient-specific direction issued after face-to-face assessment8,9.
Does this change my professional indemnity premium?
Possibly. Many indemnity insurers have already signalled that failure to follow the NMC’s face-to-face mandate could invalidate cover. It’s worth discussing with your provider whether premiums or policy terms have been updated in light of the 1 June 2025 requirement.
Where must the face-to-face consultation take place?
Ensure that consultations, prescribing and treatments occur in premises that meets the NMC criteria for suitable premises in accordance with the NMC’s code of practice standards 4.
Are non-injectable cosmetic medicines (e.g. topical anaesthetics) included?
Yes. The embargo extends beyond injectables to any POM used for non-surgical cosmetic purposes, including topical anaesthetics, adrenaline for emergency use and similar items. All such prescriptions require a prior, documented in-person assessment8,9
Do I need a new face-to-face consultation for a 3-month retreatment?
Yes. Under the NMC’s position, every new prescribing episode requires its own in-person assessment. Even if you’re simply re-treating the same patient three months later, you must:
Is a new face-to-face consultation always needed at the 2-week follow-up?
Not necessarily. If your original supply and directions fully cover an uncomplicated adjustment at the two-week review, you may proceed without a second in-person consult, provided:
However, if at that 2-week review:
You must conduct a new face-to-face assessment and issue a fresh prescription before proceeding10.
My takeaways
Having shifted from “best practice” advice to a binding requirement, I see this as a positive evolution for the nursing profession. While it undoubtedly adds administrative layers, and perhaps marginal costs. This new requirement standardises patient safeguarding that many of us have already practised instinctively: there is simply no substitute for seeing a patient’s anatomy, assessing skin health in real time, and building rapport face-to-face.
This change:
My advice to colleagues is to embrace the mandate as an opportunity to: refine your standard operating procedures, invest in training, and use the extra touchpoint to deepen your patient relationships. In the long run, these consultations will distinguish truly patient-centred clinics from the commoditised fringe. Let’s lead by example, showing that excellence in non-surgical aesthetics lies in the hands-on, human connection we bring to every interaction.
Biography:
Julie Scott is an independent nurse prescriber, Level 7 qualified aesthetic injector and trainer
with more than 30 years of experience in the field of plastics and skin rejuvenation. She is an
aesthetic mentor and international speaker, who has won the Aesthetics Awards ‘Aesthetic
Nurse Practitioner of the Year’ in both 2022 & 2024, and ‘Best Clinic South of England’ 2023
awards. She also sits on the Aesthetics Reviewing Panel for the Aesthetics Journal, is a Board
member for DANAI, a Faculty Member of Allergan Medical Institute and an Ambassador and
KOL for the JCCP and several leading aesthetic brands.
References:
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