White Paper · Policy Submission

Regulating Aesthetic Medicine in Pakistan: A proposition for an inclusive, tiered practitioner framework

Association of Aesthetic Physicians of Pakistan (AAPP) · contributing practitioners · June 2026

Executive Summary

Aesthetic medicine is one of the fastest-growing medical sectors in the world. Globally, the non-surgical cosmetic procedures market was valued at approximately USD 35.99 billion in 2025 and is projected to reach USD 64.07 billion by 2033. Pakistan, with a population exceeding 240 million, a rapidly expanding urban middle class, and a growing appetite for minimally invasive cosmetic procedures, is positioned to benefit enormously from this global trend — provided it establishes a sound, evidence-based regulatory framework.

At present, Pakistan’s aesthetic medicine sector operates in a state of regulatory ambiguity. The Pakistan Medical Commission (PMC), and subsequently the Pakistan Medical and Dental Council (PM&DC), have made commendable initial efforts to define credentialing pathways, but these have been inconsistently implemented, frequently revised, and have failed to address the full spectrum of practitioners and procedures involved in the field. The result is a fragmented industry in which turf wars between specialties, unaccredited short-course proliferation, and the exclusion of competent allied health professionals have all undermined both patient safety and professional development.

This white paper draws upon the experience of the United Kingdom — particularly the frameworks developed by the Joint Council for Cosmetic Practitioners (JCCP) and the Save Face accreditation scheme — as well as regulatory models from the United States, Australia, and Canada, to propose a comprehensive, tiered, and inclusive regulatory framework for aesthetic medicine in Pakistan. The central argument of this paper is that aesthetic medicine should not be the exclusive domain of any single medical specialty. Rather, it must be governed by a competency-based, risk-stratified model that allows all appropriately trained healthcare professionals — including MBBS doctors, dentists, nurses, physiotherapists, and pharmacists — to participate at the level appropriate to their training and the risk profile of the procedure.

1. Introduction: The State of Aesthetic Medicine in Pakistan

1.1 A growing industry without a governing framework

The demand for minimally invasive cosmetic procedures (MICPs) in Pakistan has grown substantially over the past decade. Procedures such as botulinum toxin (Botox) injections, hyaluronic acid dermal fillers, chemical peels, laser hair removal, platelet-rich plasma (PRP) therapy, and microneedling are now widely available in urban centres across the country — offered in a diverse range of settings from hospital-based clinics to standalone beauty salons.

Despite this growth, Pakistan lacks a comprehensive, enforceable regulatory framework governing who may perform these procedures, under what conditions, and with what level of training. A patient may receive the same procedure from a board-certified dermatologist, a newly graduated MBBS doctor with a weekend certificate, or a beauty therapist with no medical training whatsoever — with no reliable mechanism for the patient to distinguish between them.

The PMC, in 2022, took a landmark step by developing the Credentialing Pathways for Aesthetic Medicine Practice in Pakistan, which classified aesthetic procedures into non-invasive, minimally invasive, and invasive categories, and established distinct registers for Aesthetic Physicians and Aesthetic Surgeons. With the transition to PM&DC, implementation stalled. A December 2024 PM&DC directive recognised Aesthetic Medicine as a specialty requiring structured postgraduate training of at least two years and expressed concern about short-term online certifications. While this addresses the problem of unqualified practitioners, it risks overcorrecting by creating barriers so high that the vast majority of competent, experienced practitioners are excluded.

1.2 The specialty monopoly problem

A recurring feature of the Pakistani aesthetic medicine debate is the attempt by certain specialties — primarily dermatology and plastic surgery — to claim exclusive authority over aesthetic procedures. Dermatologists and plastic surgeons are trained to diagnose and treat skin diseases and to perform reconstructive surgery, respectively. Aesthetic medicine — the non-pathological enhancement of appearance through minimally invasive procedures — is not a core component of either residency curriculum in Pakistan, or indeed in most countries. In the United Kingdom, even dermatologists and plastic surgeons are required to complete the same aesthetic medicine training courses as general practitioners to obtain insurance for these procedures.

The consequence of allowing specialty monopolies to dominate this field is threefold. First, it creates an artificial scarcity of qualified practitioners. Second, it stifles the development of a broader, multidisciplinary aesthetic workforce. Third, it does not, in practice, improve patient safety — because the specialists who claim exclusivity are often too few, too expensive, and too geographically concentrated to serve the population’s needs.

1.3 The exclusion of dentists — an unjustified anomaly

Of all the anomalies in Pakistan’s current approach, the marginalisation of dentists is perhaps the most difficult to justify. Dentists possess a level of anatomical knowledge of the head, neck, and face that is arguably superior to that of any other medical professional. Their undergraduate training involves extensive study of the skull, mandible, temporomandibular joint, infratemporal fossa, nasal cavity, oral cavity, and orbital structures. They perform multiple distinct facial injection and nerve block techniques daily as a routine part of their clinical practice.

A 2025 peer-reviewed review in the Journal of Pharmacy & Bioallied Sciences confirmed that dentists are uniquely positioned to practise facial aesthetics. The UK’s General Dental Council permits registered dentists to practise aesthetic medicine, and the Save Face register accepts dentists alongside doctors and nurses. In the United States, dentists administer Botox and dermal fillers in many states after appropriate training. The scrutiny dentists face in Pakistan is not grounded in evidence of patient harm; it reflects a territorial instinct. This white paper firmly advocates for the full and equal inclusion of dentists in Pakistan’s aesthetic medicine framework.

1.4 The untapped potential of allied healthcare professionals

In the UK and US, a significant proportion of aesthetic procedures are performed by nurses — aesthetic nurses or nurse injectors — who operate either independently or under the oversight of a prescribing physician. This model has proven safe, effective, and scalable. In Pakistan, the potential of allied healthcare professionals has been almost entirely overlooked. A well-trained nurse or physiotherapist is far better qualified to perform laser hair removal or superficial microneedling than an untrained beauty therapist, and restricting these procedures to doctors is an inefficient use of scarce medical resources.

2. International Frameworks: Lessons from the UK and Beyond

2.1 United Kingdom — voluntary standards and emerging legislation

The 2013 Keogh Review of the Regulation of Cosmetic Interventions found that the cosmetic sector was poorly regulated and that training standards were inconsistent. The Joint Council for Cosmetic Practitioners (JCCP) was established in response and operates a voluntary register open to all healthcare professionals — doctors, nurses, dentists, and pharmacists — who meet its competency standards. The JCCP’s Competency Framework for Cosmetic Practice (2018) emphasises competency level rather than professional role, and uses an “observe and perform” model (a minimum of ten observations and ten supervised performances per modality).

Save Face is a UK government-approved, independent accreditation scheme accredited by the Professional Standards Authority. It assesses practitioners and clinics against a rigorous 116-point standard. Crucially, Save Face is open to doctors, nurses, and dentists alike, on universal standards of safety and competence.

In 2022 the UK’s Health and Care Act gave the Secretary of State power to introduce a licensing regime for non-surgical cosmetic procedures. The 2025 government response proposed a risk-stratified scheme:

• Green (Low Risk): procedures that may be carried out by any licensed practitioner meeting agreed standards.
• Amber (Medium Risk): non-healthcare practitioners may perform only under the oversight of a named regulated healthcare professional; qualified healthcare professionals may perform independently.
• Red (High Risk): restricted to suitably qualified and regulated healthcare professionals, subject to CQC regulation.

2.2 United States — state-level regulation and the nurse injector model

Botulinum toxin is a prescription-only medicine in the US, but in many states administration can be delegated to registered nurses and, in some cases, licensed practical nurses operating under physician oversight. Nurse practitioners can often practise independently in states with full practice authority. The American experience demonstrates that the nurse injector model is safe, effective, and scalable when scope-of-practice definitions are clear.

2.3 Australia and Canada

In 2025 Australia’s Ahpra introduced new guidelines for registered health practitioners performing and advertising non-surgical cosmetic procedures, emphasising informed consent, psychological assessment, and post-procedure follow-up. In Canada, aesthetic medicine regulation varies by province, but doctors, nurse practitioners, and registered nurses can perform aesthetic procedures within their scope of practice — a model that highlights both the opportunities and challenges of decentralised regulation.

3. The Case for an Inclusive, Competency-Based Framework

3.1 Aesthetic medicine is not a single specialty

A fundamental premise of this paper is that aesthetic medicine is not the exclusive preserve of any single medical specialty. It is an interdisciplinary field drawing on dermatology, plastic surgery, oral and maxillofacial surgery, pharmacology, anatomy, and patient psychology. No single specialty encompasses all of these domains in its training curriculum. The PMC’s 2022 credentialing framework acknowledged this by recognising both “Core Specialists” and “Non-Core Specialists” as eligible for the Aesthetic Physicians Register, provided they met the relevant training and experience requirements. This inclusive approach was well-conceived and should be reinstated and expanded.

3.2 The dentist’s unique qualification

Dentists routinely perform at least ten distinct injection and nerve block techniques as part of daily clinical practice, including inferior alveolar, infraorbital, and mental nerve blocks. The dental undergraduate curriculum places the strongest emphasis of any healthcare training programme on head and neck anatomy. For facial aesthetic procedures — which are by definition confined to the face, head, and neck — dentists may reasonably be considered among the most anatomically prepared practitioners in the healthcare system.

3.3 The allied healthcare professional workforce

The global aesthetic medicine industry depends on a tiered workforce. At the base of the pyramid are technicians and allied health professionals who perform lower-risk procedures. In the middle are trained practitioners — doctors, nurses, dentists — who perform injectable and energy-based treatments. At the apex are advanced practitioners and specialists who manage complex cases. In Pakistan, the middle and lower tiers of this workforce are almost entirely absent from the regulatory conversation.

3.4 The training gap and the private sector

Proper training in aesthetic medicine is not an accredited residency pathway in any country in the world. It is delivered primarily through postgraduate diplomas, certificate courses, and hands-on training programmes in the private sector. This is not a failing of the system; it reflects the nature of aesthetic medicine as a field that evolves rapidly, relies on proprietary products and devices, and requires practical, hands-on skill development. Pakistan needs a set of nationally recognised training standards that private training providers must meet to have their programmes accredited.

4. Proposed Tiered Regulatory Framework for Pakistan

4.1 Tier 1: Low-Risk Procedures (Green Category)

Definition: non-invasive and minimally invasive procedures that target the epidermis only, or that involve superficial penetration of the integument with minimal risk of serious complications.

Example procedures: laser hair removal (all body areas); IPL; superficial chemical peels (glycolic up to 20%, salicylic up to 15%); basic microneedling to superficial dermal depth; non-ablative radiofrequency or ultrasound for superficial skin tightening; HydraFacial-type device treatments; microdermabrasion.

Authorised practitioners: allied healthcare professionals (registered nurses, physiotherapists, pharmacists) with a recognised Tier 1 certificate; MBBS doctors; BDS dentists; aesthetic technicians with a nationally accredited Level 3 or Level 4 qualification.

Training: a nationally accredited certificate of minimum 40 hours; minimum of five supervised procedures per modality; 8 hours annual CPD. Allied practitioners and technicians must operate under the general governance of a registered medical director (MBBS or BDS).

4.2 Tier 2: Medium-Risk Procedures (Amber Category)

Definition: minimally invasive procedures involving injection of prescription-only medicines or placement of materials into the dermis or subcutaneous tissue, with a moderate risk of vascular compromise, infection, or asymmetry.

Example procedures: botulinum toxin injections (all facial and neck areas); hyaluronic acid dermal fillers (superficial to mid-dermal placement); PRP injections (face and scalp); medium-depth chemical peels (TCA up to 20%); advanced microneedling with PRP or growth factors; superficial sclerotherapy; skin booster injections (Profhilo, Restylane Skinboosters).

Authorised practitioners: MBBS doctors (post-house job) and BDS dentists with a Tier 2 diploma or certificate; registered nurses with a Tier 2 diploma operating under a valid prescribing arrangement.

Training: a nationally accredited diploma of minimum 80 hours; minimum of ten observed and ten supervised procedures per modality (JCCP “observe and perform”); competency assessment by an approved assessor; 16 hours annual CPD including at least four hours of complication management. All practitioners must hold appropriate indemnity insurance.

4.3 Tier 3: High-Risk Procedures (Red Category)

Definition: procedures with significant risk of serious complications, including deep-tissue injection, combination treatments, and procedures performed in sensitive anatomical regions where vascular occlusion or visual compromise is possible.

Example procedures: deep dermal and supraperiosteal dermal filler placement (e.g. cheek, chin, nose, jawline augmentation); non-surgical rhinoplasty; tear-trough filler; PDO/PLLA thread lifts; deep chemical peels (phenol, >35% TCA); ablative laser resurfacing; biostimulator injections (Sculptra-type PLLA, Radiesse-type CaHA); cannula-based filler in high-risk zones.

Authorised practitioners: MBBS doctors and BDS dentists who have completed a recognised Tier 3 diploma and a minimum of 12 months supervised practice in Tier 2 procedures.

Training: a structured Tier 3 programme of minimum 150 hours, an exit examination or competency assessment, and 24 hours annual CPD. All Tier 3 procedures must be performed in a registered, fully equipped clinical facility with emergency protocols, resuscitation equipment, and access to a hospital with vascular surgery capability.

5. Governance and Accreditation

5.1 The National Aesthetic Medicine Council (NAMC)

We propose the establishment of a multidisciplinary National Aesthetic Medicine Council (NAMC) under the PM&DC, with representation from dermatology, plastic surgery, oral and maxillofacial surgery, general practice, nursing, dentistry, physiotherapy, pharmacy, training providers, and patient advocacy. The NAMC would own the tiered framework, accredit training providers, maintain the practitioner register, and arbitrate inter-specialty disputes.

5.2 A public National Aesthetic Practitioner Register

The PM&DC should maintain a publicly searchable register listing every practitioner authorised at each tier. Entry should be open to all licensed healthcare professionals — MBBS, BDS, RN, physiotherapist, pharmacist — who have completed the relevant accredited training programme.

5.3 Accreditation of training providers

The NAMC should accredit training providers against criteria including: curriculum alignment with national competency frameworks; qualified trainers with at least three years of clinical experience in the relevant modalities; access to appropriate clinical facilities; documented assessment processes; and transparent records of pass rates and complication outcomes.

6. Transitional Arrangements

6.1 Grandfather clause

Many practitioners currently practising aesthetic medicine in Pakistan have years of clinical experience but may not hold formally accredited qualifications. A grandfather clause should allow practitioners with documented evidence of at least three years of aesthetic practice prior to implementation to apply for registration on the basis of their experience, subject to a competency assessment — consistent with the PMC’s 2022 framework which recognised practitioners with more than five years of experience.

6.2 Continuing professional development

All registered aesthetic practitioners should complete a minimum number of CPD hours per year, as specified for each tier. CPD activities should include attendance at conferences, online or in-person training modules, peer review, and case-based learning.

7. Patient Safety and Consumer Protection

The framework must be supported by enforceable rules on informed consent (including cooling-off periods for Tier 2 and 3 procedures), complication management and reporting, facility standards, and advertising. Advertising of aesthetic procedures in Pakistan is currently unregulated; the NAMC should prohibit misleading claims and require all advertising to include the practitioner’s qualifications and registration status.

8. Action Plan for the Government of Pakistan

Immediate (0–6 months): establish the NAMC under the PM&DC with multidisciplinary representation; issue a moratorium on enforcement actions against fully licensed MBBS and BDS practitioners performing Tier 1 and Tier 2 procedures pending the new framework; publish the draft tiered framework for public consultation.

Short term (6–18 months): finalise the framework following consultation; accredit the first cohort of training providers; open the National Aesthetic Practitioner Register; implement the grandfather clause.

Medium term (18–36 months): phased enforcement of facility standards and advertising rules; integration of aesthetic medicine modules into MBBS and BDS undergraduate electives; first published annual safety and outcomes report.

9. Conclusion

Aesthetic medicine in Pakistan stands at a crossroads. The path of exclusion — restricting practice to a small handful of specialties — will not protect patients; it will only push them into the hands of untrained practitioners operating outside the regulatory system. The path of inclusion — a tiered, competency-based framework that recognises every appropriately trained healthcare professional — protects patients, empowers practitioners, and aligns Pakistan with international best practice.

By implementing this framework, Pakistan can protect its patients, empower its practitioners, grow its aesthetic medicine industry, and position itself as a regional leader in safe, high-quality aesthetic care.