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7.1 - Hairdressing: Regulatory Requirements

There's no national register for hairdressers in England. Nobody checks your qualifications before you start cutting hair. That doesn't mean there are no rules - it means the rules are scattered across half a dozen different pieces of legislation, and nobody bothers to tell you what they are until something goes wrong. This guide pulls them all into one place.

Quick rule of thumb: you don't need a licence to cut hair in England, but you do need COSHH assessments, proper insurance, and the right qualifications for your insurer to actually pay out if something goes wrong.

Is there a mandatory registration for hairdressers?

No. Not in England. There's no national licensing system and no compulsory registration with a professional body. Anyone can legally call themselves a hairdresser and start taking clients.

This is different from Scotland, where the Hairdressers (Registration) Act 1964 technically still exists, though enforcement is patchy. In Northern Ireland, there's no mandatory registration either.

The industry has been pushing for regulation for years. The Hairdressing Council (now the Hair Council) operates a voluntary register, but it's optional and there's no legal requirement to be on it. If you are on it, you can use the title "State Registered Hairdresser" - but most clients have never heard of it.

Bottom line: you can work legally without registration. But "legal" and "covered" are different things. Your insurance, your landlord, and your clients will all have expectations.

Tip for new starters: Check with your local council what registrations you need BEFORE you start taking clients. Requirements vary by area and some councils take weeks to process applications.

Qualifications: what you actually need

The NVQ framework

Level 2 NVQ in Hairdressing (or the equivalent diploma) is the accepted minimum standard for working unsupervised as a hairdresser. Most salons won't rent you a chair without it. Most insurers won't cover you without it.

Level 3 opens doors to senior roles, teaching, and assessing. If you want to train apprentices, you'll need Level 3 plus an assessor qualification.

What if you trained abroad?

Foreign qualifications aren't automatically recognised. You'll need to get your qualification assessed by a body like UK ENIC (the UK's national information centre for international qualifications). Your insurer will want to see evidence that your training is equivalent to a UK Level 2.

What if you're self-taught?

Some people learn entirely on the job. That's not illegal - but it creates insurance problems. Most insurers require a recognised qualification. If you can't show one, your options are:

• Get a qualification retrospectively (many colleges offer fast-track Level 2 for experienced hairdressers)
• Find a specialist insurer who accepts a portfolio of evidence and references
• Accept that you're taking a significant financial risk every time you work

COSHH: the law that definitely applies to you

If you use hair dye, bleach, developer, perm solution, keratin treatments, or any product with a warning label, the Control of Substances Hazardous to Health Regulations 2002 applies.

This is covered in full in Guide 4 (COSHH for Self-Employed Hairdressers). The short version:

• You must do a COSHH assessment for every hazardous product you use
• You must keep safety data sheets (SDS) for every chemical product
• You must put controls in place - ventilation, gloves, eye protection, substitution of safer products
• You must train anyone who works with or near those substances
• You must review your assessments regularly

The HSE has made it clear: self-employed hairdressers have the same COSHH duties as employed ones. "I'm just a chair renter" doesn't get you off the hook.

Patch testing: a legal obligation for colour services

If you apply hair colour containing known sensitisers (PPD, PTD, or related compounds), you must carry out an allergy alert test (patch test) at least 48 hours before the service.

This isn't optional. It's a legal requirement under:

• The Consumer Protection Act 1987
• The General Product Safety Regulations 2005
• Manufacturer instructions (which form part of product liability)

If a client has an allergic reaction to colour and you didn't patch test, you're exposed to:

• A personal injury claim (which your insurer may refuse to cover if you breached protocol)
• An HSE investigation
• A Trading Standards complaint
• Prosecution if the harm is serious

Common mistakes with patch testing

• "She's been having the same colour for years" - doesn't matter. Sensitivity can develop at any time. Manufacturers say: every time, or at least every 6-12 months. Check your insurer's requirements.
• "I did a strand test" - a strand test checks for colour result, not allergy. It's not a patch test.
• "I asked if she'd had a reaction before" - that's a verbal check, not a patch test. It helps, but it doesn't replace physical testing.
• "The client refused a patch test" - then you must refuse the service. Document the refusal in writing.

Tip for new starters: Keep a simple log of every patch test you do, with the client's name, date, product used, and result. If a client ever makes a claim, that log is your best defence.

Insurance requirements

Public liability insurance

Not legally required for sole traders, but practically essential. If a client slips on your wet floor, reacts to a product, or gets burned by straighteners, public liability insurance covers the claim.

Most salon landlords require proof of public liability insurance before they'll let you rent a chair. Typical minimum: £1 million, though many require £2 million or £5 million.

Professional indemnity insurance

Covers claims arising from your professional advice or services - for example, if a client alleges their hair was damaged by your colour technique.

Employer's liability insurance

If you employ anyone - even one person, even part-time - you must have employer's liability insurance of at least £5 million. This is a legal requirement under the Employers' Liability (Compulsory Insurance) Act 1969. The fine for not having it is up to £2,500 per day.

Product liability

If you sell retail products (shampoo, conditioner, styling products), you need product liability insurance. If you mix products (colour, bleach), you're effectively manufacturing - and that carries product liability too.

Treatment risk insurance

Covers specific treatments - colouring, chemical straightening, keratin treatments. Check that your policy explicitly covers every service you offer.

Professional bodies

None of these are mandatory, but membership often comes with insurance, training, and credibility.

Advertising rules

The Advertising Standards Authority (ASA) and the Committee of Advertising Practice (CAP) Code apply to everything you put out publicly - social media posts, website copy, leaflets, window displays.

Claims you need to back up

• "Best hairdresser in town" - you need evidence. Unless you've won a verified award or can prove the claim objectively, this is likely to breach the CAP Code.
• "Award-winning" - you must name the award and be able to prove you won it.
• "Specialist in..." - you should have specific training or qualifications to back this up.
• "Fixes damaged hair" - this is a performance claim. You need evidence (before/after documentation, product testing).

Before and after photos

Allowed, but:

• Must be genuine (your own work, not stock photos)
• Must not be digitally enhanced in a misleading way
• Must be representative of typical results
• Must have client consent (written, ideally)

Pricing

• Must be clear and not misleading
• "From £30" is fine if £30 is a real starting price
• "Was £60, now £30" - the £60 must have been a genuine price for a reasonable period

Product safety regulations

If you buy and use professional products, the manufacturer carries primary product safety responsibility. But you still have duties:

• Don't use products past their expiry date - you're responsible if harm results
• Follow manufacturer instructions - if the SDS says "use in a ventilated area," you must
• Don't mix products from different manufacturers unless both confirm compatibility
• CLP labelling - if you mix colour, bleach, or any chemical products, the Classification, Labelling and Packaging Regulation (CLP) applies. In practice, this means you need to know what's in the products you're mixing and what hazard classifications apply. You're not required to label every bowl of colour mix, but you must know the hazards and communicate them.

If you sell retail products to clients, you're acting as a retailer and the General Product Safety Regulations 2005 apply. Products must be safe, properly labelled, and you must be able to trace them back to the supplier.

Health and safety: the basics

Even without specific hairdressing legislation, the following apply:

• Health and Safety at Work etc. Act 1974 - general duty to conduct your work safely
• Workplace (Health, Safety and Welfare) Regulations 1992 - if you have a fixed workplace, it must be safe, clean, ventilated, lit, and at a reasonable temperature
• Manual Handling Operations Regulations 1992 - relevant if you're lifting heavy stock
• Personal Protective Equipment at Work Regulations 2022 - you must provide and use appropriate PPE (gloves for colouring, at minimum)
• Electricity at Work Regulations 1989 - electrical equipment (dryers, straighteners, clippers) must be maintained and, if you're in rented premises, may need PAT testing

Record keeping

No specific regulations force you to keep client records. But practically:

• Patch test records - essential for defending colour allergy claims. Keep them for at least 3 years (the limitation period for personal injury claims, though it can extend to 6 years for contractual claims).
• Consultation records - allergies, medications, skin conditions, previous reactions. These protect you.
• COSHH assessments - keep them as long as you use the products, plus 40 years for substances that may cause occupational disease (HSE guidance).
• Insurance certificates - keep copies of all past policies. You might need them years later if a historic claim surfaces.

What to do next

1. Check your qualifications meet your insurer's requirements - not just the legal minimum
2. Get or update your COSHH assessments (see Guide 4)
3. Review your patch testing protocol - make sure it matches your manufacturer's instructions AND your insurer's requirements
4. Check your advertising against the CAP Code
5. Keep your insurance up to date and make sure every service you offer is explicitly covered

Who to Contact

• HSE (Health and Safety Executive): 0300 003 1647 (Free) - hse.gov.uk - COSHH guidance, workplace safety
• NHBF (National Hair & Beauty Federation): nhbf.co.uk - trade body, insurance, legal helpline (Free for members)
• Hair Council: haircouncil.org.uk - voluntary register
• ASA (Advertising Standards Authority): asa.org.uk - advertising complaints and guidance (Free)
• Your local council licensing/Environmental Health team (Free)
• Your local Trading Standards office - product safety, consumer protection (Free)
• HMRC Self Assessment: 0300 200 3310 (Free)
• Citizens Advice: 0800 144 8848 (Free)
• UK ENIC: enic.org.uk - international qualification recognition

Sources

• Health and Safety at Work etc. Act 1974
• Control of Substances Hazardous to Health Regulations 2002 (COSHH)
• Consumer Protection Act 1987
• General Product Safety Regulations 2005
• Employers' Liability (Compulsory Insurance) Act 1969
• CLP Regulation (retained EU law)
• ASA/CAP Code (Advertising Standards Authority)
• HSE guidance: "Hairdressing - Managing health risks" (hse.gov.uk)
• NHBF guidance notes
• Habia National Occupational Standards

Related Guides

• Guide 4 - COSHH for Self-Employed Hairdressers
• Guide 7.2 - Barbering: Regulatory Requirements
• Guide 7.3 - Beauty Therapy: Regulatory Requirements
• Guide 7.8 - Advertising Rules for Beauty and Aesthetics
• Insurance by Specialism
• Chair Rental Complete Guide
• Choosing the Right Qualifications

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