Do I Need a Local Authority Special Treatment Licence?

Whether you need a special treatment licence depends entirely on where you practise, not on what you are qualified to do, and since 29 November 2024 practising without one in Wales can be a criminal offence.

That is the uncomfortable part of this topic. A physiotherapist doing dry needling is the same practitioner with the same qualification and the same needle in Cardiff, London and Glasgow. In Cardiff she needs a licence and approved premises. In London and Glasgow she is exempt. The regime follows the postcode, not the profession.

There is no single UK law here. There is one Welsh statute, one London statute, one Scottish order, and a scattering of private local Acts across England that apply in some council areas and not others. Practitioners usually find this out late, when a licensing officer emails them or an insurer asks for a licence number.

Which law applies where you practise?

Fees are the least predictable part of this. There is no national fee scale, and the comparisons that circulate in trade press are hard to verify because many councils do not publish a readable schedule. Ealing's £499 comes with a £93.11 charge to vary an existing licence. Bromley's £306 renewal sits alongside a £706 fee for a new tattooing, piercing or laser licence. Treat every figure you read, including these, as the starting point for a phone call rather than a budget line.

Why is Wales now the urgent case?

Part 4 of the Public Health (Wales) Act 2017 came into force on 29 November 2024. It creates a mandatory licensing scheme for four "special procedures": acupuncture, body piercing, electrolysis and tattooing. Performing one of those procedures in Wales without a licence is a criminal offence, not a civil breach.

The detail that catches clinical practitioners is the definition. Acupuncture, for the purposes of the Act, expressly includes dry needling. If you use dry needling on a patient in Wales, the Act sees an acupuncture procedure regardless of what your professional body calls it or which training route you took.

The scheme has two limbs, and you need both:

1. A practitioner licence, issued to you personally by the local authority for the area where you work.
2. Approved premises, meaning the place where the procedure happens has been separately approved.

A practitioner licence on its own does not let you work anywhere you like. Approved premises without a licensed practitioner does not help either.

Does the health professional exemption cover me in Wales?

Almost certainly not, if you work in private practice.

The Act contains an exemption for regulated health professionals, and most practitioners read that line and assume it covers them. It is far narrower than it looks. The General Chiropractic Council sought written confirmation from Welsh Government on exactly this point and published the answer: the exemption applies only where the practitioner is practising in the NHS, or on premises that are registered and inspected by Healthcare Inspectorate Wales.

The GCC then asked HIW whether it registers or inspects chiropractic clinics. HIW confirmed that it neither inspects nor offers registration to them.

Follow that through. A private chiropractor, osteopath or physiotherapist using dry needling in a high street clinic in Cardiff is not in the NHS and is not on HIW-registered premises. The exemption does not reach them. They need a practitioner licence and premises approval like anyone else offering acupuncture.

This is one of the most misread compliance points in UK allied health right now, and it carries criminal liability. If you needle patients in Wales and have not contacted your local authority, that is this week's job.

Who is exempt in London?

The London Local Authorities Act 1991 makes it an offence to provide or advertise special treatments in a London borough without a licence. The advertising limb matters: a website listing sports massage at an unlicensed address is capable of being an offence before anyone has booked.

Two exemption routes exist.

HCPC registrants are exempt. Physiotherapists, chiropodists, podiatrists and other HCPC-registered professions fall outside the licensing requirement for treatment within their scope.

CNHC registrants hold exempt-body status through the London Special Treatment Group, covering aromatherapy, the Bowen technique, massage (including sports massage), microsystems acupuncture, reflexology and shiatsu.

There is an important nuance in the CNHC route that is easy to miss. The exemption attaches to the premises, not to the individual therapist, and individual boroughs may still require a licence. Two things follow. First, being CNHC registered does not automatically make you personally exempt wherever you happen to work that week. Second, "exempt in London" is not a statement you can make without naming the borough. Ask the borough you actually work in, in writing, and keep the reply.

How does Scotland treat acupuncture?

Scotland does not run a general special treatment regime. It runs a skin piercing and tattooing regime, and it puts acupuncture inside it.

Under the Civic Government (Scotland) Act 1982 (Licensing of Skin Piercing and Tattooing) Order 2006, acupuncture counts as skin piercing and is licensable by the local authority. The order then exempts members of professions regulated by a body listed in section 25(3) of the NHS Reform and Health Care Professions Act 2002. That list covers the statutory healthcare regulators, so HCPC, General Osteopathic Council and General Chiropractic Council registrants sit outside the scheme.

The practical result is the mirror image of Wales. In Scotland the regulated health professional exemption works the way practitioners expect it to work. In Wales it does not.

What about England outside London?

Outside London, special treatment licensing in England runs on private local Acts, not national legislation. A council only has these powers if a local Act gave them to it.

The Nottinghamshire County Council Act 1985 applies in Nottingham City, Bassetlaw, Ashfield, Rushcliffe, Broxtowe and Mansfield. The Birmingham City Council Act 1990 applies in Birmingham. Other cities have their own equivalents. Large parts of England have no regime at all, which is why a therapist can move practice ten miles and go from licensable to unlicensable without changing anything about the treatment.

Do not reason by analogy with a neighbouring council. Adjacent authorities routinely sit on opposite sides of this line.

Does a mobile therapist need a licence?

Often not, and this is the most useful sentence in the article.

These regimes license premises where treatment is provided to the public. Bromley states this explicitly: mobile therapists visiting clients in their own homes do not need a licence. The same massage, given by the same therapist, is licensable in a rented treatment room and unlicensable in the client's living room.

That asymmetry is real and it is legitimate, but do not over-read it:

• Renting a room in a salon, gym or clinic usually puts you inside the regime, and the premises licence holder may require you to be named on it.
• Treating clients at your own home may make your home the licensable premises.
• Wales is the exception to the pattern. Its practitioner licence attaches to you, so a mobile needling practitioner in Wales does not escape it by working at the client's kitchen table.

If you are weighing a room rental against a mobile model, licensing belongs in the sums alongside rent and insurance. Our first-year cost breakdown covers the rest of that arithmetic.

How do I check my own council?

Five steps, in order:

1. Search your council's website for "special treatment licence", then try "skin piercing", "acupuncture" and "massage licence". The scheme may sit under any of those headings.
2. Name the treatment precisely. Ask about dry needling by name, not "acupuncture". Ask about sports massage by name, not "massage".
3. Ask which exemption they apply and to whom. Premises exemption and practitioner exemption are different things, as the CNHC position in London shows.
4. Get the answer in writing. An email from a licensing officer is the document you want if anyone queries it later, including your insurer.
5. Check every area you work in. Multi-site clinics and associates covering two boroughs need an answer per area, not one answer.

Then record the licence number and its renewal date against each site you work from. Whether that lives in your practice management system, as it does in Atlacare's location records, or in a calendar reminder, the point is that annual renewals are easy to miss and a lapsed licence is not a technicality in Wales.

Frequently asked questions

I am HCPC registered. Am I exempt everywhere?

No. You are exempt in London under the 1991 Act and in Scotland under the 2006 order. You are not exempt in Wales unless you are practising in the NHS or on HIW-registered premises.

Does professional indemnity insurance cover unlicensed practice?

Assume not. Insurers commonly require you to hold any licence your practice legally needs, so practising unlicensed risks leaving the treatment uninsured as well as unlawful. Ask your insurer directly.

I only needle occasionally. Does that change anything?

Not in Wales. The offence relates to performing the procedure, not to how central it is to your caseload.

Do I need a licence just to advertise the treatment?

In London, advertising special treatments without a licence is capable of being an offence under Part II of the 1991 Act. Take the service page down before you take the booking.

This is general information, not legal advice. Licensing varies by council and changes without much publicity, so check with the local authority for every area you work in.

Sources: GCC advice for chiropractors using acupuncture in Wales | Public Health (Wales) Act 2017, Part 4 | Civic Government (Scotland) Act 1982 (Licensing of Skin Piercing and Tattooing) Order 2006 | CNHC special treatment licences in London

Related: Is My Practice VAT Exempt? | What It Costs to Set Up a Private Practice in Year One