As the aesthetic sector evolves under increasing regulatory scrutiny, Care Quality Commission (CQC) registration is no longer a niche concern.

In this article, Cosmetic Insure collaborated with DKJ, leading CQC consultants, to demystify this topic – and highlight what clinics need to know to stay insured, compliant and competitive.

What is the CQC – and Who Needs to Register?

The Care Quality Commission (CQC) is the independent regulator of health and social care services in England. Any clinic or practitioner carrying out a regulated activity under the Health and Social Care Act 2008 must be registered – regardless of professional title, business model, or treatment setting.

While many aesthetic treatments fall outside CQC’s scope, certain activities do require registration, particularly where medical care or prescribing is involved.

Examples of Aesthetic Treatments That May Require CQC Registration

You’re likely to need CQC registration if you’re offering treatments that fall under one of the following categories:

Treatment of Disease, Disorder or Injury (TDDI)

This includes:

• Botulinum toxin for medical indications, such as:
• Migraines
• Hyperhidrosis
• Bruxism (depending on clinical rationale)
• Dermal fillers for asymmetry or facial palsy correction
• Platelet-rich plasma (PRP) for hair loss or medical skin conditions
• IV therapy where administered to treat or prevent illness

Surgical Procedures

Includes:

• Thread lifts
• Skin lesion removal
• Liposuction (including injectable fat dissolvers with aspiration techniques)

Prescribing and Delegation

If you:

• Conduct consultations
• Diagnose
• Prescribe and delegate administration to others

…you may need to be registered, particularly if treatment is framed or coded as a medical intervention. This is where many aesthetic businesses inadvertently cross the line – especially as services become more holistic, wellness-based or health-driven.

When Insurers Expect CQC Registration

At Cosmetic Insure, we carry out a comprehensive review of the treatments and services provided by each practitioner or clinic when arranging cover. Where a business model involves regulated activity, insurers would reasonably expect the appropriate registrations – such as CQC registration – to be in place.

Failure to hold the necessary registrations may have implications for insurance coverage, particularly in the event of a claim. Common examples include:

• Prescribing without a registered service framework
• Administering IV treatments or medical botulinum for therapeutic purpose
• Operating across multiple sites or within group structures without clear governance

These considerations apply not only to new applications but can also affect existing policies and claims outcomes.

How Lack of CQC Registration Can Affect a Claim

In the event of a complaint or malpractice claim, insurers will examine:

• Whether the treatment was carried out within scope
• Whether the practitioner or business met all regulatory requirements
• Whether clients were treated in a safe and suitable environment

If the treatment in question should have been carried out under CQC registration, and wasn’t, it could affect:

• The validity of your policy
• The outcome of a claim
• Your ability to secure future insurance

We’ve seen claims involving medical botulinum prescribed for hyperhidrosis where the practitioner had no CQC registration, despite marketing the treatment as therapeutic. In several cases, the lack of registration complicated the insurer’s defence – especially where the prescribing model was unclear or consultation notes were incomplete.

The Registration Process – What’s Involved?

If CQC registration is required, be prepared for a rigorous but manageable process:

1. Application & Structure

You’ll need to register the legal entity (e.g. limited company) and nominate a Registered Manager with relevant clinical and leadership experience.

2. Premises Suitability

You must demonstrate that your clinic or treatment space meets safety, hygiene, safeguarding, and infection control standards.

3. Policies & Procedures

Expect to provide:
• Consent forms (with clinical rationale)
• Risk assessments
• Complaints handling processes
• Safeguarding, privacy, data protection, and equality policies

4. Training & Documentation

All practitioners must have:
•  Up-to-date training in resuscitation, safeguarding, and infection control
• Clear documentation of CPD
• Clinical supervision (if applicable)

5. Inspection & Oversight

The CQC will assess your service against five key areas: Safe, Effective, Caring, Responsive, and Well-Led. Following inspection, you’ll receive a rating and regular reviews.

Best Practice: What Insurers Like Us Look For

Even if you don’t yet require CQC registration, your risk profile is improved when you apply CQC-level standards to your aesthetic practice.

Here’s what we like to see in a well-governed clinic:

Clear Clinical Oversight – Designated clinical leads or supervisors, even in small teams.

Robust Record-Keeping – Full patient records, consultation notes, rationale for treatment, signed consent.

Prescribing Protocols – Safe and traceable prescribing, especially when delegating administration.

Complaints Procedures – A documented, fair and prompt complaints process – which shows in how you handle pre-claims.

Ongoing Training & Reflection – Evidence of regular CPD, reflective learning, peer reviews.

In short: whether you’re regulated or not, your ability to defend a claim improves when your internal systems meet CQC-level expectations.

CQC registration isn’t just about legal compliance – it’s about aligning your clinic with professional standards that protect your clients, your team, and your business.

At Cosmetic Insure, we’ve seen first-hand how proper governance can reduce risk and strengthen insurance outcomes. If your clinic is expanding, offering medical treatments, or considering delegation or prescribing models – it’s time to reassess your position.

If you’re not sure whether your activities require CQC registration, speak to us. We’re happy to guide you through the implications – and help ensure your insurance reflects the true nature of your practice.

Need a confidential insurance review? Contact Cosmetic Insure to assess your cover in light of current regulatory expectations.

Contact us today to learn more about how we can help your clinic thrive, no matter what challenges come your way.

Cosmetic Insure Disclaimer

All the information provided in our Cosmetic Insure Treatment Guides and blog articles serves as a valuable reference and informational resource. Our intention is to offer insights that assist you in making informed choices when exploring the extensive array of non-surgical aesthetic treatments available.

Please note that this information does not constitute medical advice. Any reliance you place on the content found within the Cosmetic Insure Treatment Guides, Cosmetic Insure blog articles, or on any part of cosmeticinsure.com is done so entirely at your own discretion.

Prior to considering any non-surgical cosmetic treatment mentioned anywhere on cosmeticinsure.com, we strongly recommend that you engage in thorough consultation with a duly qualified and accredited practitioner who possesses the proper training and comprehensive insurance coverage for the specific treatment you are interested in. Neither the author of the guides or blog articles, nor the practitioner who has verified these guides, nor Cosmetic Insure, can be held responsible or liable for any loss or claims resulting from the use or misuse of cosmeticinsure.com’s content. Your safety and well-being are our utmost concern.

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