How Does the Ministry of Health’s Communication Affect the Beauty Industry?

In recent weeks, the beauty industry has been faced with significant turmoil. This is all due to a communication from the Ministry of Health dated January 23, 2026 (ref. RKLU.81223.2.2026.BB), which has become a flashpoint for a heated debate between doctors and cosmetologists. Many commentators have perceived it as an explicit ban on non-physicians performing certain aesthetic medicine procedures, such as fillers or botulinum toxin. But are we truly dealing with a legal revolution?

What Does the Ministry of Health Actually Say?

According to the Ministry’s communication, aesthetic-reparative medicine procedures may be performed exclusively by specialist physicians in dermatology, venereology, and plastic surgery, as well as other physicians and dentists holding an indefinite license to practice who have completed additional training and obtained certificates in aesthetic-reparative medicine procedures.

The Ministry of Health has recognized aesthetic-reparative medicine as a certified medical skill (code 028). The specific procedures subject to physician certification are defined in a document approved by the Minister of Health titled “Minimum Standard for Conducting Certification of Aesthetic-Reparative Medicine Professional Skills by Certification Organizers” and include the following:

a) Botulinum toxin treatments;

b) Cross-linked hyaluronic acid treatments (volumetry, lifting, modeling);

c) Poly-L-lactic acid treatments;

d) Calcium hydroxylapatite treatments;

e) Polycaprolactone treatments;

f) Mesotherapy using non-cross-linked hyaluronic acid, amino acids, vitamins, polynucleotides, collagen, micro- and macro-elements, peptides, enzymes, coenzymes, and medications for treatment, reconstruction, revitalization, and anti-aging prophylaxis;

g) Platelet-rich plasma (PRP) and fibrin treatments;

h) Use of medical devices based on various technologies with medical certification, including: high-energy lasers (fractional ablative and non-ablative, CO2, Pico- and Nanosecond, Thulium, KTP, pulsed dye, Nd:YAG, Q-switch, Er:YAG, Er:glass, Alexandrite, diode, Excimer), IPL (including broadband light), mono- and bi-polar radiofrequency, ultrasound, HI-FU, cryotherapy, plasma, electrosurgery, carboxytherapy, LED lamps, and shockwave therapy;

i) Medium-deep and deep medical peels based on approved chemical substances;

j) All injection procedures related to drug administration: hyaluronidase, glucocorticosteroids, phosphatidylcholine;

k) Procedures related to reparative medicine: treatments restoring appearance and function after injuries, diseases, or surgeries, including the treatment of post-treatment complications and their effects;

l) Medical procedures using medical threads, sclerotherapy, lipotransfer (autologous fat grafting), and injection lipolysis.

In the view of the Ministry, any person without the professional qualifications of a physician is unauthorized to perform these procedures. Therefore, employees of other medical professions, cosmetologists, beauticians, and other individuals are deemed unauthorized, even if they hold training certificates for specific aesthetic procedures. Such certificates obtained by unauthorized persons merely prove completion of a course but do not grant the legal right to perform the procedures.

Exceptions are limited to low-risk treatments, such as microneedling (micromesotherapy) or operating devices that the manufacturer has cleared for use by non-physicians, as these procedures are considered safe and do not require medical intervention.

Does the Communication Legally Prohibit Cosmetologists from Performing Treatments?

The Ministry of Health’s communication is not a normative act and is not a source of generally binding law. This is crucial because, under Article 87 of the Constitution of the Republic of Poland, the catalog of such sources is closed and includes only: the Constitution, statutes (acts), ratified international agreements, and regulations. Ministerial communications are not included in this list, meaning they cannot independently shape the rights or obligations of citizens.

The Ministry’s communication is informational in nature. It serves as an interpretation of existing legal provisions regarding the skills necessary for a physician or dentist to obtain a certificate in aesthetic-reparative medicine.

From a systemic perspective, this act does not create a ban on specific activities for non-physicians; rather, it confirms that a physician holding such a certificate has acquired specific competencies during postgraduate education.

The scope of the regulation is limited to the practice of the medical profession and does not constitute an independent basis for restricting the activities of, for example, cosmetologists. The communication does not affect entities to which it is not addressed, which is explicitly confirmed by one of the final sentences: “The Ministry emphasizes that it regulates provisions regarding medical professions and curative activities, but does not regulate non-medical professions, including, among others, the profession of a cosmetologist.”

Given the above, the Ministry’s communication cannot serve as a basis for administrative or judicial decisions, as administrative bodies and courts are not bound by its content.

Summary

Despite the media buzz, the Ministry’s communication does not resolve the long-standing dispute over competencies in the aesthetic industry. Polish law still lacks a single, rigid definition of an “aesthetic medicine procedure,” leaving room for interpretation by both sides of the conflict. There is no doubt that this issue requires statutory regulation. Solving competency disputes in the industry also requires the introduction of clear statutory regulations for the profession of a cosmetologist and the specification of the qualifications necessary to perform aesthetic treatments.