As the Government gears up to consult on firmer rules around cosmetic treatments, one writer investigates the safety of London clinics
Writer Sophie Wilkinson went undercover, posing as a needle-phobic, to see which London clinics are safe
“Lift up your fringe. OK, it’s just three injections for the crow’s feet, then max five around the frown line.”
I’m in a glossy, spacious treatment room in London’s Hampstead village, next door to bijou cafés and designer boutiques. Soft music plays as a woman with plump cupid’s bow lips offers to inject my first ever shots of Botox. “It’s just one mini medical form and that’s it,” she cajoles, before assuring me that, “because we’re CQC-regulated, doctors can keep Botox in the fridge without you needing a prescription. The prescriber will sign off on the form, you don’t have to see him.”
But this clinic has never been inspected by the CQC. If investigators turned up they’d find a classily-lit emporium offering elite skincare, a fully-stocked pharmacy and clean, spacious treatment rooms. They would also discover that the clinic is breaking the law and putting their customers’ health on the line.
In 2025, consumers treat Botox as casually as an eyelash tint, more laissez-faire than a salon dye-job. Clinics and beauticians offering Botox line our high streets. But do those booking in for this normalised procedure know what they’re getting themselves in for? The Government has said it’s going to crack down on cowboy clinics, so to understand the risk the practitioners present, I spent a few days visiting and calling clinics, posing as a needle-phobic, would-be Botox patient with a few questions. What I discovered has genuinely terrified me:
- 16 practitioners were willing to give me illegally prescribed Botox
- 40 companies are illegally advertising Botox on Instagram
- One practitioner is using an unlicensed Iranian alternative to Botox
Botox, the brand name of botulinum toxin, freezes muscles and reduces the appearance of wrinkles. It is the most popular non-surgical cosmetic treatment, available on our high streets for around £180 for three areas on the face. The UK market was worth £115m in 2024, a figure projected to rise to £295m by 2031.
Walk up any high street and you’ll see clinics offering it, or even doing deals. One clinic I stroll past has a huge multicoloured wheel in its window. With one spin, the lucky winner could be in for free lip filler, 20 per cent off a treatment or 100ml of free “bum filler”. This refers to a BBL, or a Brazilian butt lift, which can be fatal. In 2024, British mother 33-year-old Alice Webb died from complications following this kind of treatment.
And Botox, though far more commonly undertaken, carries its own risks, too. Ashton Collins, the chief executive of Save Face, an organisation championing better industry standards and advocating patient safety, says: “80 per cent of complaints made to Save Face wouldn’t have come in if the regulation on Botox was actually enforced.”
Administered poorly or to the wrong candidate, Botox can cause drooping facial muscles, difficulty talking, eating or opening eyes, permanent scarring and anaphylactic shock. And cheap counterfeit versions of the toxin are rife. Earlier this year, at least 28 people were hospitalised with symptoms of botulism poisoning including difficulty swallowing, slurred speech and breathing difficulties requiring respiratory support after being injected with fake Botox.
Going under cover
As a 37-year-old ginger who’s had more than enough sunburn, my smiles, frowns, grimaces and cackles are drawn across my face. My solutions, so far, have been to drink lots of water and use SPF, but plenty of my friends get Botox. A 28-year-old tells me: “I look at the women around me with perfect, completely unwrinkled faces and, in all honesty, felt pressure.” A 38-year-old pal adds: “I have a fear of death and if I look old it will remind me that I’m going to die.”
But how many Botox injectors are following the law? Health Secretary Wes Streeting has criticised the “cosmetic cowboys” who are “causing serious catastrophic damage” and the Government has announced plans to better regulate the UK non-surgical cosmetics industry. However, campaigners like Collins are concerned that not only is change too slow, but the enforcement of current rules is too weak – laws around Botox already exist, but as The Telegraph’s investigation shows, plenty are being broken.
Botox is a prescription-only medicine, and can only be signed off for use by medical doctors, dentists, nurses and pharmacists who have trained up to prescribe. Previously, these prescribers could work at arm’s length, never setting eyes on the patient, but under new regulations launched in January this year, they’re obliged to physically assess patients and suggest alternative options before signing off the prescription.
This unified guidance from the General Pharmaceutical Council (GPhC), General Medical Council (GMC) and the Nursing and Midwifery Council (NMC), gave until June 1 for practitioners to comply. Now, any prescriber found to be breaking the rules faces being struck off.
To find out if clinics are breaking the law, I compile a list of those not on Save Face’s government-approved practitioner register and prepare my act: I want Botox, but, being afraid of needles, I have questions.
The first two clinics I visit are a three-minute walk from one another in two Victorian terraces in leafy north London. Both are tiny, with marble-effect flooring and tasteful lighting.
In clinic one, I can see into a glass-walled treatment room where two women take turns to inject another, overseen by a fourth, murmuring guidance in brown scrubs. This place isn’t just a clinic for punters, but a training academy charging would-be Botox injectors £1,500 to learn the ropes.
The woman in scrubs asks what I’m after. I give her the needle-phobe spiel and she glances up from the model lying on her chair to explain that, after using numbing cream, “it takes five minutes to do the Botox”. I counter, “I don’t need to get a prescription?” and she smiles. “No, the doctor’s sorted everything out ahead.” She adds: “You will love Botox. You won’t get addicted, it won’t make things worse, you’ll just close your eyes and I’ll get on with the job.” They can squeeze me in after the fillers course.
Wilkinson deals with fine lines, but has never considered Botox before Credit: Rii Schroer
Collins later tells me that several people have complained to Save Face about this particular clinic, with one course attendee reporting: “The doctor in charge was not GMC registered… and injected one model who was high on cannabis and caused another to have a visual impairment.”
Illegal Botox is ruining people’s lives
Down the road, through a narrow doorway, a green-eyed beautician is in her treatment room, vaping and scrolling on her mobile phone on a fleece-lined dentist’s chair. She invites me to take her seat. The cramped room is stocked with IV drips, skin boosters, a mini fridge and framed certificates for Botox, IV drip and dermal filler courses. “It’s a very short, small needle,” Marya explains, taking one from a drawer stacked full of them. She re-lids it before popping it back.
In her soft, Eastern European accent, she tells me that for £140 I can have three areas of my face needled: “It will very well do the lifting, because I see it looks a bit like you’re tired, like your eyebrows are pushing down. This will make you look fresher.”
She uses her phone to show me her work on Instagram and says that instead of Botox, she uses Masport, “It’s working very well. It’s great quality.” Later, I search Masport on Google and discover it’s an Iranian version of Botox, costing around $20 a vial and unlicensed here. Under the Human Medicines Regulations Act 2012, it is unlawful to sell or supply any unlicensed medicine. Collins warns that the Masport this clinician has bought could be counterfeit, because it hasn’t gone through the same efficacy and safety trials as licensed botulinum toxin. “We’ve seen women present with horrendous lumps at each injection site that just won’t go. Medical professionals don’t know what they are made of, so don’t always know how to get rid of them.” Save Face has been supporting a woman who needed “nearly a third of her face surgically removed because these lumps became infected and necrotic.
“Illegal Botox causes us the most concern, because it’s ruining people’s lives, and it’s very difficult for them to get any sort of recourse.”
Of the five clinics I visited that day, three were willing to break the law. To see if Botox clinics further afield would do the same, I went back to my list of non-Save Face registered clinics, with their smart Instagram pages and five-star Google Reviews. Surely they’ll follow the rules?
While two say I’d need to speak to a prescriber on a call or FaceTime, they’re still breaking the law, meaning that 13 of the 30 clinics I call are injecting illegally. Most simply ask me to fill in a medical form for a nameless prescriber to sign off. Two said they’ll just inject on the day, no prescriber mentioned.
One injector tells me: “At the minute there is talk of the whole prescribing thing but none of that’s come into effect just yet… they look to come into effect in February-March.” This is false. Collins confirms that any nurse injecting illegally prescribed Botox is breaching their own code of practice.
Dr Sophie Shotter, president of the British College of Aesthetic Medicine (BCAM), says that this investigation’s findings “highlight one of the potential fallacies of the new legislation coming. It’s only as good as the enforcement”.
There are good reasons to gatekeep Botox, she adds: “Botulinum toxin can be used as a weapon of mass destruction, it is potentially that harmful. As a prescriber administering Botox, I know that I’m assessing the patient’s history, their suitability for the treatment and whether they’re a good candidate. I’m taking medical responsibility for the treatment’s outcomes, too.”
Dodgy adverts, dubious clinics
Within a couple of hours of researching clinics’ Instagram pages, my algorithm began to spew up advert after advert for cosmetic procedures, including adverts for Botox, which are illegal owing to it being a prescription-only medication. In the space of a month I’m shown adverts from at least 40 companies pushing “anti-wrinkle injections”, “Bot*x” , “Botox models needed”, “Bot@x”, a Halloween promotion for £99 “Boo-tox” and just pure and simple “Botox”. I also discovered that the training academy I visited offers Botox for as little as £15 a pop to “models”.
When I share screenshots of all of these ads with the Advertising Standards Authority, a spokesperson says: “Both our rules and the law make clear that Botox is a prescription-only medicine [POM], so it can’t be advertised to the public. We won’t hesitate to take action where we do see breaches of these rules.”
The body removes 600 ads per week, using an AI-based monitoring system to “proactively identify illegal POMs ads” and also “invest significant resources into education and support, providing advice and training to help practitioners advertise responsibly”.
Trying to name names
Now, as part of due diligence for this investigation, I report all of those practising illegally to Save Face. It’s far harder to report the prescribers who are breaking the law to their regulatory bodies, though, because clinics don’t always publicise their names. “So many clinics have spurious business names, operate only on social media and with no fixed address,” says Collins. “So how do you go about even trying to enforce against them? It’s very easy to operate in the shadows and make a lot of money at the cost of people they are ultimately responsible for.”
Collins adds that there’s a “lottery” of regulatory bodies taking complaints seriously: “A lot of them perceive these complaints as [coming from] silly women making choices driven by vanity. If it’s gone wrong, it’s their fault.”
An NHS surgeon I know of does Botox on the side, injecting friends from her home since 2021. She tells me she has done a one-day course in Botox: “For me, [this] was enough because I’m so familiar with using needles, mixing drugs, injecting and the anatomy of the face. But for someone with no prior experience, it’s very short. The idea that you’re allowed to be out there injecting is scary.”
Dr Shotter adds: “These courses don’t necessarily mean good quality training. There are online courses that last a couple of hours and involve no hands-on training.”
Deeply concerning findings
The situation is urgent. Dr Shotter is keen for more legislation, but “it needs to be done properly”. She says: “If we introduce new legislation and don’t have a structure to enforce it, which needs funding and training, then it’s just another bit of paper.”
Collins, meanwhile, is anxious for those in power to move faster: “We’ve constantly told the government about this for 10 years and asked them to make sure that these rules are properly policed and enforced. That just hasn’t happened, and it’s escalating every year.”
Bradley Thomas, Conservative MP for Bromsgrove and the Villages, has been campaigning for better cosmetics regulation alongside an aesthetician in his constituency who operates a CQC-regulated medical clinic. He says our findings are “deeply concerning” but that “given there’s been a wild west culture in this industry for some time, the findings from The Telegraph’s undercover reporting don’t surprise me.
“With the Government promising new regulations for non-surgical aesthetic treatments, something I’ve been campaigning for, we must also see greater enforcement of [current] regulations.
“Every day of delay is another life put at risk, and we cannot allow that to continue. We need urgency. We need clarity. We need a firm timeline and greater enforcement.”
A spokesperson from the Department of Health and Social Care told The Telegraph: “These findings are deeply concerning. This government is taking action to crack down on cosmetic cowboys and root out dangerous treatments. Our tough new measures will ensure only qualified healthcare professionals will be able to perform the highest-risk procedures.
“In the meantime, we are working closely with regulators to clamp down on bad practice, and we urge anyone aware of organisations or individuals acting unsafely to report them to the regulator.
“For anyone considering a cosmetic procedure, please check the provider’s qualifications and insurance – and avoid treatments that appear suspiciously cheap.”
Collins says: “If a doctor was prescribing fentanyl, Tramadol or any other potent painkiller, without seeing or speaking to patients, they would be dealt with by police. This should be treated in the same way; these victims have been assaulted and some have nearly lost their lives as a result.”
How to get Botox done safely
How can you tell which clinics are working legally? Ashton Collins, CEO of Save Face, which runs a government-approved register of cosmetic practitioners, says: “We put them through an 116-point checklist to ensure they are trained, insured and have the necessary paperwork to make sure you’re safe.
“We also send a nurse’s assessor to inspect every clinic and make sure they use licensed products sourced from legitimate pharmacies.”