Regulating Aesthetic Medicine in Pakistan
A proposition for an inclusive, tiered practitioner framework — submitted to the Government of Pakistan, PM&DC and the Provincial Healthcare Commissions.
Prepared with the Association of Aesthetic Physicians of Pakistan (AAPP) and contributing practitioners.
A market of $611M by 2036 — governed by competency, not turf.
The global non-surgical cosmetic market was valued at USD 35.99 billion in 2025 and is projected to reach USD 64.07 billion by 2033. Pakistan — 240 million people, a rapidly urbanising middle class, and rising demand for minimally invasive procedures — sits directly in that trajectory.
Yet Pakistan operates in regulatory ambiguity. This paper draws on the UK\u2019s JCCP and Save Face schemes, and models from the USA, Australia and Canada, to propose a tiered, competency-based framework that includes MBBS doctors, dentists, nurses, physiotherapists and pharmacists — each at the level appropriate to their training and the risk of the procedure.
Ten chapters. One argument.
A growing industry without a governing framework, and why the dermatology monopoly argument does not withstand scrutiny.
The most anatomically qualified group of facial injectors — and the most neglected by current policy.
What the UK (JCCP, Save Face, the 2025 licensing scheme), USA, Australia and Canada teach Pakistan.
Demand forecasts through 2036 and the arithmetic that ends the specialty-monopoly argument.
A three-tier, risk-stratified, competency-based model adapted for Pakistan.
The proposed National Aesthetic Medicine Council (NAMC), National Register, training accreditation and a Save Face model for clinics.
Informed consent, psychological assessment, complication management and advertising standards.
A concrete 0–36+ month legislative and institutional roadmap for PM&DC and Provincial Healthcare Commissions.
Pakistan has 0.34 dermatologists per 100,000 — one-ninth of the international benchmark. A specialty already unable to meet its core medical mission cannot credibly monopolise aesthetics.
BDS training is the most face-focused medical education in the healthcare system. Dentists inject the face daily. In the UK and US they are recognised on equal terms with doctors.
Nurses, physiotherapists and pharmacists are entirely absent from the current conversation. Tier 1 procedures do not require a medical degree — they require training, protocols and accountability.
The demand curve is not debatable.
Base-case forecasts model patient volume tripling and market value nearly quadrupling in the next five years. Even a full-capacity dermatology workforce cannot serve it.
| Year | Conservative | Base Case | Optimistic | Patients (Base) |
|---|---|---|---|---|
| 2026 | $18M | $31M | $49M | 256,000 |
| 2031 | $59M | $117M | $196M | 733,000 |
| 2036 | $153M | $336M | $611M | ~1.6M |
Dermatologists per 100,000 population
Source: Pakistan Association of Dermatologists; WHO EMHJ 2025; Canadian Dermatology Association benchmark (3.0 per 100,000).
A three-tier, risk-stratified, inclusive model.
- Laser hair removal
- IPL
- Superficial peels
- Basic microneedling
- HydraFacial
- Microdermabrasion
Allied HCPs (nurses, physios, pharmacists), MBBS, BDS, accredited technicians
40-hour accredited certificate · 5 supervised cases per modality · 8h annual CPD
- Botulinum toxin
- Hyaluronic acid fillers
- PRP (face & scalp)
- Medium-depth peels
- Skin boosters
- Advanced microneedling
MBBS, BDS (facial region), Registered Nurses with prescribing arrangement
80-hour accredited diploma · 10 observed + 10 supervised per modality · 16h annual CPD
- Deep peels
- Ablative laser resurfacing
- Thread lifts
- Hair transplantation
- Fat transfer
- Liposuction / body contouring
Aesthetic Physicians/Surgeons with advanced fellowship, Dermatologists & Plastic Surgeons with aesthetic training, BDS with advanced head/neck training
6-month+ fellowship · 25 supervised cases per modality · exit exam · 24h annual CPD
A National Aesthetic Medicine Council
Established under PM&DC, with representation from PM&DC (Chair), Provincial Healthcare Commissions, AAPP, PMA, PDA, PNC, CPSP, and consumer representatives.
Responsible for national competency frameworks, training-provider accreditation, and maintaining a publicly searchable National Aesthetic Practitioner Register.
Provincial Healthcare Commissions should run a clinic accreditation scheme modelled on the UK\u2019s Save Face — 116-point assessment, publicly listed clinics, enforcement against those who fail to meet standards.
A 36-month roadmap for government.
| Timeline | Action | Lead |
|---|---|---|
| 0–3 months | Establish the National Aesthetic Medicine Council (NAMC) with multidisciplinary representation | PM&DC |
| 0–1 month | Moratorium on enforcement against licensed MBBS/BDS performing Tier 1 & 2 procedures pending framework | PM&DC |
| 6–12 months | Publish national competency frameworks for Tiers 1, 2, 3 | NAMC |
| 12–18 months | Launch the National Aesthetic Practitioner Register | PM&DC / NAMC |
| 18–24 months | Launch clinic accreditation scheme (Save Face model) | Provincial Healthcare Commissions |
| 36+ months | Mandatory practitioner registration and clinic licensing | PM&DC / PHCs |