A National Licensing Audit: What Do Councils Really Regulate?
England has 317 local authorities — each interpreting and applying licensing law in their own way. Some require licences for massage and LED therapy. Others don’t. Some inspect every year. Others, never. There is currently no national map of which treatments are licensed, under which Act, at what cost, or with what level of oversight.
To build a better system, we first need to understand the one we have.
This proposed standardised data capture form offers a simple, practical way to gather and compare council-by-council information — helping to expose gaps, duplication, and postcode-based inconsistencies in skin and personal care regulation.
Council Licensing Audit – Standardised Data Capture Form
A. Council Information
Council Name: __________________________
Region: __________________________
Point of Contact / Department: __________________________
Email Address for Follow-up: __________________________
B. Legal Framework
| Legislation Adopted | Yes / No |
|---|---|
| Local Government (Miscellaneous Provisions) Act 1982, Part VIII | ☐ Yes ☐ No |
| Schedule 3 (Massage and Special Treatments) | ☐ Yes ☐ No |
| Local Government Act 2003 (Section 120 / Schedule 6 update) | ☐ Yes ☐ No |
| London Local Authorities Act 1991 (London boroughs only) | ☐ Yes ☐ No |
C. Treatments Licensed
Please tick all treatments you currently license, indicate the legal basis, licence cost, and renewal frequency.
| Treatment Type | Licensed? | Under which Act / by-law? | Licence Fee | Renewal Frequency |
|---|---|---|---|---|
| Massage | ☐ Yes ☐ No | £____ | ☐ Annual ☐ Biennial ☐ Other | |
| Manicures / Pedicures | ☐ Yes ☐ No | |||
| Tattooing | ☐ Yes ☐ No | |||
| Cosmetic Piercing | ☐ Yes ☐ No | |||
| Semi-permanent Skin Colouring | ☐ Yes ☐ No | |||
| Acupuncture | ☐ Yes ☐ No | |||
| Electrolysis | ☐ Yes ☐ No | |||
| Microneedling (manual/device) | ☐ Yes ☐ No | |||
| LED Therapy | ☐ Yes ☐ No | |||
| Buccal / Intraoral Massage | ☐ Yes ☐ No | |||
| Chemical Peels | ☐ Yes ☐ No | |||
| Radiofrequency Skin Treatment | ☐ Yes ☐ No | |||
| Cryotherapy | ☐ Yes ☐ No | |||
| Laser / IPL | ☐ Yes ☐ No |
D. Other Treatments Not Listed Above
Please specify:
E. Premises vs Practitioner
Do you license:
- ☐ Premises only
- ☐ Practitioner only
- ☐ Both
F. Inspection & Compliance
Are inspections carried out? ☐ Yes ☐ No
Inspection frequency: ☐ Annual ☐ Biennial ☐ Ad hoc ☐ Complaint-based only
Who performs inspections? ☐ Environmental Health ☐ Licensing Officer ☐ Other
Do you check practitioner qualifications before issuing licences? ☐ Yes ☐ No
Do you maintain a public register of licensed premises? ☐ Yes ☐ No
Part 2. What Happens Once We Capture the Data?
The standardised audit form is a vital first step. But it's what happens next that will make the real difference:
We analyse the data
Map out what is currently licensed across the 317 councils.
Identify:
Which treatments are universally licensed, inconsistently licensed, or not licensed at all.
Which treatments fall into ambiguous or overlapping categories.
Where significant regional discrepancies, duplications, or omissions exist.
We define what should be regulated
Begin building a national baseline of treatments and procedures that merit oversight.
Each treatment or category will include a clear description to reduce misinterpretation.
The aim is not to regulate everything, but to regulate consistently — based on evidence, risk, and public clarity.
We align with national legislation
The 2022 licensing proposals may cover some of these gaps — but they do not include all skin-facing treatments.
A national register of treatments should exist outside of individual Acts — so that:
New treatments can be added centrally (not locally interpreted).
Councils are notified automatically when updates occur.
The public has access to a clear, centralised list.
We future-proof the system
This isn’t about listing every possible future treatment — but creating a category-based system.
For example:
Any new treatment that involves puncturing the skin = “Skin-penetrative interventions.”
Any electrical treatment delivered to the skin = “Electrotherapies.”
New treatments can be added into categories at a national level — without rewriting the law.
We make the system visible
The national register of licensed treatment categories (with examples) should:
Be listed on all council websites.
Be available to practitioners and the public alike.
Include a public alert system when new treatments are added or regulations change.
The Skin Well®
A grassroots, evidence-aware initiative supporting public skin education.
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Disclaimer
A Clear Case for National Skin Health is part of an independent advocacy series by The Skin Well®. These pieces are written from lived professional experience and personal reflection. They are intended to raise questions, highlight gaps, and explore opportunities for public health improvement.
They do not replace professional medical advice, and they do not represent the views of the NHS or any governmental body.
It should not be used as a substitute for professional medical advice, diagnosis, or treatment. If you have concerns about your skin or health, please speak with your GP or a qualified healthcare provider.
I welcome constructive feedback. If you notice any information that may be inaccurate or outdated, please let me know so I can review and improve.
© 2025 Jacqui de Jager | The Skin Well® & The Happy Skin Clinic®
All rights reserved. This leaflet is for personal use and education only. It may not be reproduced, distributed, or adapted without written permission.