Aesthetic medicine reserved for doctors: does it take hours away from public care?.

Since 2023 the rules have provided for a separate medical skill: “aesthetic and restorative medicine” (medycyna estetyczno-naprawcza). In January 2026 the Ministry of Health explained that procedures with botulinum toxin, fillers or lasers are healthcare services that a cosmetologist may not perform. Cosmetologists who performed them for years want this reversed.

In this dispute an argument also comes up that concerns patients of the National Health Fund (NFZ). If the market for aesthetic procedures is reserved for doctors, some of their hours may go there instead of to public care. This is a hypothesis. Nobody measures or publishes how many doctors’ hours actually shift outside the public system.

What the rules say

A regulation of the minister of health of 13 June 2023 added “aesthetic and restorative medicine”, with code 028, to the list of professional skills of doctors and dentists.¹ The skill is confirmed by a certificate. The scope of procedures is described by the minimum certification standard, which the Centre of Postgraduate Medical Education (CMKP) published in July 2025.²

In January 2026 the Ministry of Health issued a statement in which it classed these procedures as healthcare services and indicated who may perform them.³⁴ The statement is not a new provision. In it the ministry relied on the Act on the professions of doctor and dentist and the 2023 regulation,³ and the trade magazine Wiadomości Kosmetyczne judged that it confirms the existing legal position.⁵

Not every doctor has this entitlement. According to the statement, it belongs to specialists in two fields and to doctors who have obtained the certificate.³⁶

The standard covers, among other things:⁶⁴

• procedures with botulinum toxin;
• fillers: cross-linked hyaluronic acid, calcium hydroxylapatite, poly-L-lactic acid and polycaprolactone;
• needle mesotherapy, for example with non-cross-linked hyaluronic acid, vitamins or peptides;
• procedures with platelet-rich plasma and fibrin;
• procedures with medical devices: lasers, IPL, radiofrequency and HIFU;
• medium-depth and deep medical peels;
• threads, sclerotherapy, lipotransfer, injection lipolysis and the treatment of complications after procedures.

The standard does not cover microneedle mesotherapy or procedures with devices that the manufacturer has approved for use by people who are not doctors.⁶⁴ Who may work with a given device is therefore decided by its documentation.⁵

The dispute with cosmetologists

Cosmetology is taught at university, but the profession of cosmetologist is not regulated by any act. The Beauty Razem Foundation (Fundacja Beauty Razem), which represents the beauty industry, appealed to the prime minister in November 2025 to delete code 028 from the regulation. It argues that complications are caused by people without relevant education, not by cosmetologists with a degree.⁷

Patient safety speaks in favour of the restriction. Many of these procedures are injections or procedures with high-energy lasers,⁴ and complications after them are treated by a doctor. The dispute therefore concerns who, after what training, may perform which procedures.

The hypothesis: hours outside the NFZ

For aesthetic procedures the patient pays out of pocket, outside the NFZ, and the price is set by the clinic. If only a doctor may perform them, demand that cosmetologists used to serve may move to doctors. Hence the hypothesis: some doctors’ hours that could go to patients of the public system go to aesthetic clinics instead. A doctor who moves part of their work to where it pays better is doing nothing wrong. They are responding to conditions set by the rules.

This hypothesis has weak points:

• Hours in an aesthetic clinic may be added to work in the public system rather than replace it. Many doctors work in several places at once, which we describe in the mechanism of multiple jobs.
• Some of the demand may not reach doctors at all, but disappear or move to the grey economy.
• Doctors performed aesthetic procedures before 2023 too, so it is not known what part of this work is new.
• The restriction covers doctors with a certificate or one of two specialisations. It is not known how many there are.

Doctors’ hours matter because the workforce is older than the headcount alone suggests. According to the medical chamber’s register, 164,892 doctors practise the profession, of whom 24,595 are aged 71 or over (as at 31.12.2025).⁹ At the same time the workforce is not shrinking: according to the Ministry of Health, there were 155.8 thousand doctors with a licence to practise living in Poland in 2023 and 164.8 thousand in 2025.¹⁰ How many doctors there are under different definitions, and why we do not combine these numbers in one calculation, we explain in our analysis Why Poland is short of doctors.

The scale: estimates from one side of the dispute

The numbers on the size of the market and the possible outflow of doctors that circulate in the debate come from the Beauty Razem Foundation. The foundation is seeking the deletion of code 028, so it has its own interest in this dispute. That is why we give its numbers with the name of the source and with what is not known about them.

Appeal to the prime minister of 10 November 2025. The foundation writes that about 3,000 doctors perform aesthetic procedures today. Of about 141 thousand doctors working directly with patients, it says, 25–30% may leave for the aesthetic sector. It estimates additional NFZ costs at PLN 5–9 billion a year, and the state’s total losses at PLN 12–16 billion a year, including about PLN 5.85 billion (≈ €1.33 billion) of taxes and contributions from businesses that would close.⁷ The figure of 141 thousand comes from Statistics Poland (GUS) and refers to 2024.¹¹ The foundation attributes the estimates of outflow and costs to its own analyses, but does not publish the calculation. The same appeal also contains a different range: “a risk of an outflow of 20–50 per cent of doctors” (our translation).⁷

Survey of 13 November 2025. The foundation surveyed 1,560 people from its own community online, so the sample was not random. 80.8% of respondents were cosmetologists with a degree. The survey is the source of the numbers on the industry itself: among respondents who perform procedures, 98.5% are women, and the average age of participants was 36. The 25–30% estimate does not come from this survey.² According to the foundation, about 70 thousand people perform aesthetic procedures, but it does not say how this number was counted.²

The order of magnitude is easy to check: 25–30% of 141 thousand is about 35–42 thousand doctors. That is more than ten times as many as, according to the same foundation, perform aesthetic procedures today. The range is close to another number from the survey: about 39 thousand people may lose their jobs in clinics (salon owners’ declarations extrapolated to the whole market), and the foundation’s president calls this a gap to be filled by doctors.² If this is the basis of the estimate, it assumes that every person who loses their job will be replaced by a doctor. Nobody has checked this.

What is missing to settle this

The hypothesis could be tested if two kinds of data existed. The first is the number of doctors who have obtained certificate 028, and the dates on which they obtained it. The second is information on how the work of the same doctors in the public system changed before and after they obtained the certificate.

The second part would be brought closer by open pseudonymised data, that is, the total paid to each person from public money, under a permanent identifier, without names. It would show whether payments to the same people rise or fall from year to year. A fall for some doctors would be the first hard signal that their hours are shifting outside the public system. Such data would not, however, show where those hours go.

This analysis is the basis for a point in our wider programme (in Polish), in which we propose that the state should not strengthen this incentive by reserving aesthetic procedures for doctors.

Notes 15laws, data and statements we relied on

1. Regulation of the Minister of Health of 13 June 2023 on the professional skills of doctors and dentists, Dz.U. 2023 item 1189 (in Polish), annex 1, item 28: “Medycyna estetyczno-naprawcza” (“Aesthetic and restorative medicine”), code 028. ↩

2. Beauty Razem Foundation, report from the survey “Likwidacja kosmetologii estetycznej” (“The abolition of aesthetic cosmetology”, in Polish), 13.11.2025. Date of publication of the CMKP standard (7.07.2025), description of the sample (CAWI, 1,560 respondents from the foundation’s community, 80.8% cosmetologists), 98.5% women and an average respondent age of 36, about 70 thousand people performing procedures, about 39 thousand jobs at risk according to respondents’ declarations. The foundation is a party to the dispute. ↩ ↩² ↩³ ↩⁴

3. Rzeczpospolita, on the Ministry of Health’s statement on aesthetic medicine (in Polish), 4.02.2026. Statement of 30.01.2026, who is entitled, legal basis (Article 17 of the Act on the professions of doctor and dentist, the 2023 regulation, the minimum certification standard). ↩ ↩² ↩³

4. DOZ.pl, “Te zabiegi medycyny estetycznej wykona tylko lekarz. Jest stanowisko Ministerstwa Zdrowia” (“Only a doctor will perform these aesthetic medicine procedures. The Ministry of Health has issued a position”, in Polish), 3.02.2026. List of procedures and exclusions; in the text the statement is dated 23.01.2026, in the bibliography 30.01.2026. ↩ ↩² ↩³ ↩⁴

5. Wiadomości Kosmetyczne, on what the Ministry of Health’s statement changes for the beauty industry (in Polish), 4.02.2026. The statement confirms the existing legal position; whether a device may be used by a person who is not a doctor is decided by the manufacturer’s documentation. ↩ ↩²

6. Prawo.pl, on the Ministry of Health’s statement on aesthetic medicine (in Polish), 4.02.2026. Who is entitled, groups of procedures in the minimum certification standard, exclusions. ↩ ↩² ↩³

7. Beauty Razem Foundation, appeal to the prime minister on “aesthetic and restorative medicine” (in Polish), 10.11.2025. Request to delete code 028, about 3,000 doctors providing aesthetic services, 25–30% of doctors according to “BR analyses”, PLN 5–9 billion of NFZ costs, PLN 12–16 billion of losses to the state (including about PLN 5.85 billion from VAT, PIT/CIT and ZUS contributions), a second range of 20–50%. The foundation is a party to the dispute. ↩ ↩² ↩³

8. Podatki.biz, “Prezydent nie podpisał ustawy dot. transportu publicznego oraz tzw. Lex Szarlatan” (“The president has not signed the act on public transport or the so-called Lex Szarlatan”, in Polish), 20.08.2026; Wiadomości Kosmetyczne, on the referral of “Lex Szarlatan” to the Constitutional Tribunal (in Polish), 20.08.2026. Status as of August 2026. ↩

9. Supreme Medical Chamber, “Zestawienie liczbowe lekarzy i lekarzy dentystów według wieku, płci i tytułu zawodowego, stan na 31.12.2025” (“Numbers of doctors and dentists by age, sex and professional title, as at 31.12.2025”, in Polish) — 164,892 doctors (excluding dentists) practising the profession, including 24,595 aged 71 or over. ↩

10. Ministry of Health, answer to interpellation no. 15990 on the scale of doctors’ emigration (in Polish), 8.04.2026. No detailed data on departures and returns; doctors with a licence to practise living in Poland according to the Central Register of Doctors (CRL): 155.8 thousand (2023), 160.8 thousand (2024), 164.8 thousand (2025). ↩ ↩²

11. Statistics Poland (GUS), “Zasoby kadrowe w wybranych zawodach medycznych na podstawie źródeł administracyjnych w 2024 r.” (“Human resources in selected medical professions based on administrative sources in 2024”, in Polish): 141,193 doctors working directly with patients in 2024. ↩

12. Supreme Medical Chamber, Central Register of Doctors, “zestawienie nr 5: liczba wydanych zaświadczeń według województwa i okresu” (“compilation no. 5: number of certificates issued by region and period”, in Polish), printout of 31.12.2025. Column L: doctors who were issued at least one certificate in a given year (people are counted, not documents), excluding certificates of equivalence of specialisation. ↩

13. Supreme Audit Office (NIK), “Zasoby kadry medycznej w systemie ochrony zdrowia” (“Medical staff resources in the healthcare system”, in Polish), 2023, pp. 32–33. The NIK notes that the number of certificates is not the number of people who left. ↩

14. OECD, International Migration Outlook 2025, November 2025, table 5.6 and annex 5.C: 16,275 Polish-born doctors in OECD countries around 2020/21, expatriation rate 11.4%. ↩

15. Bundesärztekammer (German Medical Association), Ärztestatistik 2025 (“Physician statistics 2025”, in German), as at 31.12.2025, tables 10 and 12: 2,093 doctors with Polish citizenship (1,840 professionally active), 36 first registrations in 2025. ↩