Scenario Four: A Quiet Case for Full Statutory Oversight in the Beauty Industry

What if the Beauty Industry Curriculum Was Guided by Public Health?

If we educate therapists with public health in mind—not just cosmetic outcomes, we educate the nation by extension. But right now, our training is built around appearance, not anatomy. That’s the missing link.

“I’m a therapist. I’ve never felt fully comfortable with aspects of my beauty therapy training; some of the content felt outdated based on what we now know about skin in the 21st century. For instance, when I questioned, ‘Why are we still removing the outer layer of skin—the skin barrier?’ the tutors said, ‘Well, this is the curriculum we’re told to deliver - so that’s what we teach until someone tells us otherwise.’”

But who is that ‘someone’?

Current Structure of Beauty Education in the UK

Beauty therapy education across the UK is delivered through vocational frameworks. While some common elements exist - such as the use of industry standards and awarding bodies—each nation regulates its own qualifications independently.

• England
  Regulated by Ofqual (Office of Qualifications and Examinations Regulation).
  Overseen by the Department for Education (DfE).

• Wales
  Regulated by Qualifications Wales.
  Works within the Welsh Government’s own education framework.

• Northern Ireland
  Regulated by CCEA Regulation (Council for the Curriculum, Examinations & Assessment).

• Scotland
  Qualifications are developed and regulated by the Scottish Qualifications Authority (SQA).

Shared Elements Across the UK

Despite different regulators, certain components are present in most or all nations:

• HABIA (Hair and Beauty Industry Authority)
  A UK-wide standards-setting body that develops National Occupational Standards (NOS). These serve as reference points for curriculum content but do not carry statutory power.

• Awarding Bodies (e.g., VTCT, City & Guilds, CIBTAC)
  Design and assess qualifications. Many operate UK-wide, but must align with each nation’s specific regulatory requirements.

• Training Centres
  Deliver the qualifications. Quality assurance depends on the awarding body and national regulator.

Focus of This Scenario

This Quiet Case focuses specifically on England, where:

• Department for Education (England)
  Oversees the vocational education system in England.

• Ofqual (England)
  Regulates qualifications to ensure they meet educational standards in England.

• HABIA (Hair and Beauty Industry Authority)
  These guide the content that awarding bodies include in qualifications. HABIA operates UK-wide but is most closely aligned with the English framework.

• Awarding Bodies (e.g., VTCT, CIBTAC, City & Guilds)
  Design and assess qualifications based on the NOS.

• Vocational Training Centres
  Deliver those qualifications to learners.

What’s Missing?

Department of Health and Social Care

There is currently no statutory input from England’s Department of Health and Social Care (DHSC), nor from NHS England or NICE, into the foundational training of skin therapists - even though these professionals work directly with a vital organ.

In short: there is no public health oversight of the skin care curriculum.

No national guidance on:

• What constitutes skin health

• When and how to refer to a medical professional

• How to teach barrier care or identify skin conditions

• The influence of lifestyle and environmental factors on the skin

What About the Courses That Fall Outside Regulation?

Beyond formal qualifications, many training providers now sell courses - often online or weekend-based - that are not regulated or overseen by any awarding body or national education authority.

They may be advertised as “certified” or “CPD approved,” but these terms carry no legal meaning. There is no requirement for such courses to align with HABIA standards or reflect current health understanding.

This leaves a gap where therapists may be unknowingly trained with outdated or unsafe content - putting both professionals and the public at risk.

Even the Regulated Courses Are Missing Something Vital

Courses regulated by Ofqual and delivered by reputable awarding bodies still aren’t required to consult public health guidance on skin.

While HABIA sets occupational standards, and awarding bodies build qualifications from those, there is:

• No statutory requirement to consult NHS or DHSC guidelines

• No national health framework for skin that feeds into the curriculum

In effect, we have two systems:

• One that governs educational quality

• Another that governs health and safety
  → And skin education sits fully in neither.

This is explored further in:
“Why is there no oversight in beauty therapy education? A therapist’s view: Regulating from the top without reviewing the base.”

We Regulate Mechanics. We Regulate Childcare. We Regulate Food Handling. But Not Skin?

In the UK, you can’t simply write and sell a mechanics, food safety, or childcare course without meeting strict national standards. These sectors are treated as public safety concerns.

Yet in beauty therapy, it is still legal to sell a skin treatment course - with no HABIA alignment, no awarding body involvement, and no guidance from any public health authority.

That we allow this for the body’s largest organ, one that reflects disease, holds emotional weight, and reacts to mistreatment, is frankly remarkable.

Conclusion

To date, the beauty curriculum in England has been shaped through educational and industry channels, but not public health.

• HABIA plays a vital role in setting standards.

• Awarding bodies build qualifications from these.

• But without input from the Department of Health and Social Care in England, even well-designed qualifications lack a shared national health framework.

So The Skin Well™ gently asks:

If skin is a vital organ, one that beauty and skin professionals work with every day - shouldn’t its care be guided by national health oversight?

📬 Related Open Letter(s):

• Open Letter 1: Who’s Guiding Skin Health in Beauty Training?

• Open Letter 4: When Skin Therapists Are Left Out

Updated 25/05/25
Focus: England, where the Department for Education and DHSC operate. The model may differ in devolved nations.

Back to The Skin Well Home Page

Back to Scenario Overview