GMC Response

It is the position of the BAHRS that, in the UK currently, only GMC registered doctors should make incisions in the skin during hair transplant surgery which includes the skin incisions made for the Follicular Unit Excision (FUE) method of donor hair harvesting.

The Position Statement regarding this can be found here which also refers to the position of the International Society of Hair Restoration Surgery (ISHRS) on this matter.

A recent enquiry to the General Medical Council on this issue received the response below that refers to the CPSA Hair Transplant Surgery Standard which clarifies on page 13 and 14 the roles of Hair Transplant Surgical Assistants. In this standard, it is explicitly stated that these non-doctor assistants must NOT perform the surgical steps of the procedure including making Follicular Unit Excision (FUE) incisions.

Thanks for writing to us. In your email you ask for our opinion on the issue of doctors delegating surgical practices to an assistant- you also ask about the legal aspects of this question. Although we are unable to give advice on the law (you’d have to seek independent legal advice for that) I can certainly set out the relevant principles in our professional guidance to doctors.

In our core guidance, Good medical practice, we say that all doctors must make the care of the patient their first concern; provide a good standard of practice and care and work with colleagues in ways that best serve patients’ interests (GMP, duties of a doctor).

Doctors are able to delegate aspects of patients’ care to other members of the team, but only when they are satisfied that the person providing care has the appropriate qualifications, skills and experience to provide safe care for the patient (GMP, paragraph 45); or that the person will be adequately supervised. Doctors are accountable for decisions to transfer care to others, and the steps they take to ensure that patient safety is not compromised. Whenever a doctor delegates care they remain responsible for the overall management of the patient (Delegation and referral, paragraph 2-5).

We also say in GMP that doctors must be familiar and keep up to date with guidelines and developments that affect their work (paragraphs 11-12). This includes any relevant clinical guidance such as the guidance published by the Cosmetic Practice Standards Authority which expressly sets out that all surgical steps of hair transplant procedures should be carried out by the GMC licenced doctors.

If you have concerns that the actions or omissions of a doctor are putting patients at harm, then you can use our online referral form to tell us more. There is more information about the process on our webpages here.

Thanks again for writing to us, I hope this response in helpful to you in deciding what to do next.

Yours sincerely

GMC Standards and Ethics Team


If you are a patient, hair transplant surgeon, or hair transplant surgical assistant and would like further information on this issue you can email