Scenario Five: 224,000 Reasons for Regulation*

It Starts with Skin—And Why It’s Not in Health Messaging

Walk through any public health campaign—on sleep, weight, exercise, pollution, or mental wellbeing—and you will see long lists of benefits. Lower blood pressure. Stronger heart. Better mood.

Skin, however, is rarely named. Not as a barometer. Not as a benefit. Not as something worth preserving—until it goes wrong.

Some guidance does exist. A quiet line in NHS England’s referral optimisation framework acknowledges the importance of skin barrier care.

But it’s not part of public messaging. It’s not visible. And that silence shapes everything that follows.

Prevention Without Skin

The NHS is actively shifting toward prevention over treatment. But skin—despite being the largest, most visible, and most emotionally impactful organ—remains absent from that model. This is despite growing evidence that a wide range of lifestyle and environmental factors affect skin integrity. Campaigns like Better Health and NHS Live Well include no mention of skin—other than in the context of sun safety and skin cancer prevention.

This exclusion creates a ripple effect. If skin is not seen as part of prevention, then those who care for it are not seen as part of the solution.

The Training Exists—The Role Does Not

The VTCT Level 2 Award in Facial Massage and Skincare, and the corresponding unit (UV20398) within the VTCT Level 2 Beauty Therapy Diploma, both cover skin analysis, product selection, and barrier-supportive care. In particular, they are designed to develop the knowledge and skills required to improve and maintain facial skin condition. By level 3, this training extends to improving the condition of the skin across the whole body. Evivalent qualifications from awarding bodies such as CIBTAC, ITEC, and others offering Ofqual-recognised skin therapy training follow similar standards, as they are based on the same National Occupational Standards.

These are Ofqual-regulated, nationally assessed, professional qualifications. Yet those who complete them have no recognised title beyond “beauty therapist.”

They may specialise in skin. They may offer only skincare. They may go on to gain advanced qualifications in microneedling or laser. But there is no pathway to a destination. No protected title. No public acknowledgement of their role in supporting skin.

Yes, You Can Call Yourself a Skin Therapist

There is no legal requirement to call yourself a beauty therapist. If you hold an Ofqual recognised qualification in skincare—such as the VTCT Level 2 Award in Facial Massage and Skincare—you may accurately use the title skin therapist, skincare practitioner, or facialist. Just as someone who has completed a full beauty therapy qualification, may refer to themselves as a waxing specialist or nail technician, depending on the units completed.
All of these involve skin. And all include advice—on skincare, environmental factors such as sun avoidance, lifestyle such as diet, and what to watch for.
These are not invented titles. They reflect real training and real areas of competence.
The public should be helped to understand this—not left in confusion.

Microneedling: A Case Study in Quiet Contradictions

Microneedling is taught at Level 4. It is widely insured and classed as an advanced treatment. Many skin therapists perform it professionally every day. Yet the NHS does not routinely list it as a treatment option for acne scarring or fine lines—although some NHS trusts do offer it in extreme cases, typically where psychological distress is a factor and under specialist medical consultation.

This mismatch between what is taught, practiced, and publicly recognised has already been noticed. Moves are now underway to regulate advanced skin treatments—such as microneedling and laser—in response to growing concerns about safety, oversight, and public trust.

But this raises a wider question: If regulation is coming for advanced procedures, where is the corresponding recognition for those already qualified to deliver them? There is no national register. No unified oversight. No public explanation of who is trained—and in what.

That leaves the public unsure, and the practitioners invisible.

Unless there is clear, consistent guidance on what regulation includes—and what it does not—the public will assume it covers everything. And if someone is regulated to perform one treatment, it’s natural to believe that their other services and treatments, even at a lower level, are regulated too. But that may not be the case.

Without national recognition of the foundational work in skin therapy, the profession remains fragmented. And public safety is left to assumption, not structure.

And even if a national register is introduced, it must reflect the reality of the sector. Not all qualified practitioners hold neat Ofqual certificates. Some have trained through older pathways. Others have lost formal documentation. Any future framework must find a way to honour skill, verify competence, and bring good practitioners in—not shut them out.

You Cannot Regulate Half a Liver

The Skin Well™ welcomes regulation at Level 4. It fully supports the principle that anyone offering advanced skin treatments must understand risk, scope, and informed consent.

But regulation must be joined-up. Therapists working within Level 2 and 3 qualifications continue to work with the skin—the body’s largest and most exposed organ. In the wrong hands, even routine advice or over-the-counter products can cause distress or damage. Yet there is currently no public framework for recognising who is trained, and in what. So the public is left to guess. And those without qualifications can present themselves as equals to those who are professionally trained.

You can not regulate half a liver. If safety and trust matter, they must matter for all 224,000 people working with skin—regardless of level or modality.

This gap raises a simple question: why are beauty professionals being trained and insured to offer treatments that remain unacknowledged in national skin health guidance—or as potential providers? This leaves therapists vulnerable and the public uninformed.

The likely response to this omission is that these treatments are considered cosmetic—even though our training involves improving and maintaining skin condition.

This raises a deeper question: Who decided that skin-related concerns affecting self-esteem, barrier function, or environmental resilience are merely cosmetic?

The NHS cannot treat every non-medical concern, but it does give advice on sleep, diet, movement, and mental wellbeing—whether a person is ill or not.

Skin, the body’s largest organ, deserves to also be named—as both a benefit and a symptom.

A Title Is Not Mandated—But the Work Is Real

There is no mandate requiring therapists to use the title “beauty therapist.” If trained in skincare they can identify as skin therapists. Yet despite this, titles like skin therapist do not appear in NHS guidance, national health directories, or public advice pages. The result? The people delivering frontline skin support are invisible to the people who need them.

Why Is This Missing from NHS Advice?

Nowhere in NHS guidance does it say: “If you want help improving the condition of your skin, you may wish to seek advice from a qualified skin therapist.” There are no public-facing questions like: What level of training do they hold? How long have they practiced? Do they refer when necessary? Do they understand your diagnosis? What currently happens is that people are often directed to the pharmacy—not only for treatment, but also for general advice —no tailored understanding. Nowhere to go if things don’t improve—except back to the GP, and the circle starts again. It’s no wonder people turn to Google.

Meanwhile, trained professionals are not mentioned at all. This leaves a gap in the public’s understanding of who to turn to for everyday skin care support—especially when a diagnosis has already been made, or isn’t needed.

Skin therapists are trained to support people with product selection, barrier-friendly care, and personalised guidance. But they do so without a national mandate—no official standing in NHS guidance, no public referral framework, no formal role in prevention. It’s as if the system doesn’t know what we really do—or who we really are.

Even lifestyle and environmental factors—now central to public health messaging—rarely include skin. And so, the professionals who care for it are left out of those conversations too.

Final Reflection

The Skin Well™ believes better, clearer access to qualified skin therapists is possible—if we begin by recognising those already delivering it.

Qualified therapists are not trying to take over. We are trying to be let in.

And so, The Skin Well™ quietly asks:

Why is skin—and skin therapy—still left out of national public information?

*The British Beauty Council’s 2023 Value of Beauty Report found that the hair and beauty industry accounts for around 224,000 people employed across cities, rural, and deprived areas.

📬 Related Open Letter(s):

• Open Letter 2: Have We Privatised Skin?

• Open Letter 4: When Skin Therapists Are Left Out

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Back To: Scenarios Overview

May 2025