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Botulinum toxin consent: the risks you must record

Botox is the most common injectable in the UK and one of the most claimed. The treatment is rarely the problem. The consent record almost always is. Here is what Montgomery and McCulloch require you to disclose and document, every time.

What botulinum toxin consent must cover

Botulinum toxin is a prescription-only medicine, and consent for it is judged by the same patient-centred test as any other treatment. Under Montgomery, you must disclose the material risks a reasonable patient in this patient's position would want to know, plus anything this particular patient would find significant. A signed generic form does not meet that test. A record of the conversation does.

The material risks to disclose and document

These are the risks a claimant solicitor will check your notes for. If they are not recorded, the assumption is that they were not discussed.

  • Bruising and swelling at injection sites, the most common effect.
  • Eyelid or brow ptosis (droop) and asymmetry, usually temporary but distressing, and a frequent source of complaint.
  • Headache and transient flu-like symptoms.
  • Treatment failure or unevenness requiring review or a top-up.
  • Rare spread of effect beyond the target muscles, and, very rarely, difficulty swallowing or breathing.
  • Off-label use. Many cosmetic indications are off-label. Montgomery expects the patient to be told, and the record to show they were.

Contraindications and prescribing to record

Document that you screened for and discussed: pregnancy and breastfeeding, neuromuscular disorders such as myasthenia gravis, known allergy, and current medication. Botulinum toxin is prescription-only: all four UK prescriber regulators now require a face-to-face consultation for cosmetic prescribing, and the NMC ban on remote prescribing has been in force since 1 June 2025. Your record should show who prescribed, on what basis, and that the assessment was in person.

Alternatives and cooling-off (McCulloch)

McCulloch requires you to discuss the reasonable alternatives. For toxin that includes no treatment, a lower or staged dose, and non-injectable options. Record what was offered and what the patient chose. Where consultation and treatment happen in the same visit, note whether the patient was given time to reflect, and document it. Same-day consult-and-treat with no reflection period is one of the first things a claimant will point to.


Where this sits

Every material risk below is a Montgomery disclosure and, where an alternative exists, a McCulloch one too. If it was discussed, it needs to be on the record. See how the standard rose in the interactive timeline, and how a claim actually unfolds in Anatomy of a Claim.

Related: Dermal filler consent  ·  Vascular occlusion  ·  Aesthetics overview  ·  Montgomery in aesthetics

Common questions

Questions clinicians ask.

No. A signature has never been the legal requirement. What the law requires is the consent process: disclosure of the material risks and reasonable alternatives, capacity, voluntariness and time to reflect. The signature is only evidence that some of that happened. A record of the conversation protects you; a signature on a generic form does not.

At minimum: bruising and swelling, eyelid or brow droop (ptosis), asymmetry, headache, flu-like symptoms, treatment failure or the need for a top-up, and the rare spread of effect. Because many cosmetic uses are off-label, that should be disclosed too. Record that each was discussed, tailored to this patient.

Yes, where the indication is off-label, which many cosmetic uses are. Montgomery is patient-centred: a reasonable patient would want to know they are receiving a medicine outside its licensed indication. Note in the record that off-label use was explained and accepted.

Yes for the prescribing decision. All four UK prescriber regulators require a face-to-face consultation for cosmetic prescribing, and the NMC has banned remote prescribing of these medicines since 1 June 2025. Your record should evidence an in-person assessment.

Next step

Would your Botox consent record survive a Montgomery challenge?

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