The MYRO Briefing
Independent Healthcare Intelligence
Scotland Passes Landmark Law to Regulate Non-Surgical Cosmetic Procedures
The Scottish Parliament has unanimously passed the Non-surgical Procedures and Functions of Medical Reviewers (Scotland) Bill, introducing the first statutory regulation of higher-risk cosmetic procedures in Scotland. The legislation, passed 124–0 on 17 March 2026, requires procedures such as Botox, dermal fillers, chemical peels and microneedling to be performed by or alongside a qualified healthcare professional in a registered setting. Non-surgical cosmetic procedures on under-18s are banned outright.
Healthcare Improvement Scotland will gain inspection powers to enter premises where there are reasonable grounds to believe an offence is being committed. Non-compliance carries a maximum fine of £20,000. The Scottish Government has confirmed that the offence provisions will not come into force before September 2027, giving businesses at least 18 months to adapt.
For designated bodies with cosmetic and aesthetic connections in Scotland, this is a fundamental shift. Clinics that currently operate without healthcare professional oversight will need to restructure their staffing and governance arrangements. Responsible officers should review which of their connected doctors practise in Scottish settings and ensure those doctors understand the new requirements. The legislation also has implications for appraisal discussions — compliance with the new regulatory framework will become a relevant element of practice assessment for doctors working in the Scottish cosmetic sector.
Appraisal & Revalidation
Policy & Guidance Updates
Doctor Confidence in the GMC Rising — But Trainees Remain Sceptical
Forty-four per cent of doctors now say they are confident in GMC regulation of the profession — up from 40% last year and 33% in 2022. But the headline figure masks a significant divide: doctors in training remain the least confident group at just 31%, while locally employed and SAS doctors are markedly more positive (59% and 55% respectively). The interim perception survey, conducted by Shift Insight and published on 10 March 2026, also captures PA and AA views for the first time, with 74% expressing confidence in the GMC’s regulation of their roles. Patient and public confidence stands at 83%. Designated bodies should note the persistent gap between trainee and non-trainee perceptions — this may be relevant to appraisal conversations about professional wellbeing and regulatory engagement.
Read more →Court of Appeal Dismisses BMA Challenge to GMC
The Court of Appeal has dismissed in its entirety the BMA’s challenge to the GMC’s use of the term “medical professionals” in its core professional guidance, Good medical practice. The judgment, handed down on 20 February 2026, upheld the High Court’s earlier finding and confirms that the GMC is entitled to use language that encompasses doctors, physician associates and anaesthesia associates within the same framework. The ruling settles a dispute that had cast uncertainty over the GMC’s multiprofessional regulatory approach. Designated bodies can take reassurance that the guidance framework under which they operate remains legally robust.
Read more →GMC Consults on Personal Beliefs Guidance — First Update Since 2013
The GMC has launched a three-month consultation on a fundamental revision of its Personal beliefs and medical practice guidance — the first significant update since 2013. The revised guidance will apply to doctors, physician associates and anaesthesia associates, covering conscientious objection, patient beliefs and workplace interactions. Responsible officers should consider responding before the consultation closes in June 2026.
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GMC Watch
Regulatory Updates
Weston General Hospital Exits Enhanced Monitoring
The GMC has lifted enhanced monitoring of the medicine departments at Weston General Hospital, part of University Hospitals Bristol and Weston NHS Foundation Trust, after the trust demonstrated sustained improvements in postgraduate medical education and patient safety. Enhanced monitoring was imposed after serious concerns were identified about the quality of training. The decision to remove it signals that the GMC is satisfied with the remediation. While this is an NHS case, the principle is instructive for designated bodies: the GMC will intervene where education and training standards fall short, and the route out requires demonstrable, sustained improvement — not simply a plan.
Read more →Former Responsible Officer Appointed to GMC Council
Dr Lucinda Etheridge, a consultant paediatrician and Site Chief Medical Officer at St George’s Epsom and St Helier University Hospitals, has been appointed to the GMC Council — replacing Dr Alison Wright, who stepped down after becoming President of the Royal College of Obstetricians and Gynaecologists. Notably, Dr Etheridge brings direct RO experience: she has served as a Responsible Officer for an acute trust, and has worked with the GMC since 2007 in fitness to practise assessments and performance assessment training. Her appointment strengthens the Council’s understanding of how regulation operates at designated body level — something that should be welcomed by the RO community.
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MPTS Cases — Cautions & Warnings
Fitness to Practise Outcomes
Dr Khush Bakhat Muhammad Zeeshan — Suspended for 12 Months
Outcome: 12-MONTH SUSPENSION
Dr Zeeshan, a doctor practising in the Wigan area, was suspended from the medical register for 12 months following a misconduct hearing that ran from 9 February to 3 March 2026. The full decision is published on the MPTS website. Designated bodies should review the determination for any governance lessons relevant to their connected doctors’ practice settings.
Read the full decision →Mr Jonathan Brooks ERASURE
Erased from the medical register on 17 March 2026 following a conviction/caution case heard in Nottingham. The full decision is pending publication.
Read full determination →Industry Intelligence
Independent Healthcare Sector
Six Requirements for Glasgow Aesthetic Clinic as HIS Publishes Five Reports
Luxe Skin by Doctor Q in Glasgow received six requirements and eight recommendations following a January 2026 inspection — the highest enforcement load in a single HIS inspection cycle this quarter. Four other independent clinics were also inspected, with requirements ranging from one to six per service. Aesthetic providers in Scotland should review these reports for common compliance themes.
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England’s Cosmetic Procedures Licensing Regime Takes Shape
The DHSC has confirmed a spring 2026 consultation on licensing non-surgical cosmetic procedures, with the highest-risk procedures — including BBL — restricted to qualified, regulated healthcare professionals only. Procedures will be categorised into red, amber and green risk tiers, with local authority licensing for practitioners and premises. Every cosmetic and aesthetic clinic in England will be affected.
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CQC Rebuilds Oversight with Intelligence-Led Prioritisation
The CQC has shifted to a risk-based, intelligence-led assessment model, prioritising services with safeguarding risks, providers flagged as higher risk, and those registered for over a year but never inspected. Over 50% more inspections took place in November 2025 than the same month in 2024. A new assessment framework is due in summer 2026. Independent healthcare providers should expect increased inspection activity.
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Fertility Clinic Comparison Tool Now Covers 2022–2024
The HFEA has updated its Choose a Fertility Clinic tool to include full data on treatments, pregnancies and births from January 2022 to December 2024. It remains the only place patients can compare verified, standardised success rates across all licensed UK clinics — alongside inspection reports, patient ratings and services offered. Fertility sector designated bodies should ensure their connected clinics are aware of how their data appears.
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