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The Expanding Scope of Informed Consent

07/05/2025 • by The RAM Institute

Nurse prescriber and expert witness Jen Vittanuova discusses how informed consent must evolve as regenerative aesthetic treatments become more widely adopted

Regenerative aesthetics is now an established part of aesthetic practice, with treatments such as polynucleotides, platelet rich plasma, exosome-based therapies and collagen-stimulating agents increasingly used to influence tissue quality rather than simply alter structure.  

 

Because these treatments rely on biological response, outcomes are gradual and variable. That variability isn’t a weakness, but it does change what patients need to understand before proceeding. This article explores how informed consent in regenerative aesthetics must extend beyond procedural risks to include discussion of mechanism, timeframe, durability, evidence maturity and regulatory context.  

 

As the field continues to evolve, clear and proportionate communication becomes central to its credibility and long-term development.  

 

The rapid development of regenerative treatments and their place in aesthetics  

 

Regenerative aesthetics has moved quickly over the last decade, but what stands out even more than its speed is how established it now feels. Treatments such as polynucleotides, platelet rich plasma, exosome-based therapies and collagen-stimulating agents are no longer side conversations. They’re being built into long-term treatment plans and used with the intention of improving tissue quality, not just changing shape.  

 

That shift says something important about where aesthetic medicine is heading. We’re no longer focused purely on structural correction, we’re working with biology. Before going further, it is worth pausing on what we mean by regenerative aesthetics. The term is often used broadly, and sometimes loosely. At its core, regenerative practice aims to stimulate or support the body’s own repair mechanisms rather than replace what has been lost.1 

 

As our understanding of ageing has evolved, it is clear that volume loss is only part of the picture. Fibroblast activity declines, collagen production reduces and the extracellular matrix gradually degrades, leading to visible changes in skin quality over time. Regenerative treatments aim to influence these biological processes rather than simply mask their effects.2,3 

 

Traditional structural treatments focus on repositioning or replacing tissue. Regenerative modalities instead seek to modulate cellular signalling, fibroblast activity and extracellular matrix behaviour to support tissue repair and remodelling.2,3 Because these approaches rely on biological processes rather than immediate structural change, outcomes are inherently more gradual and variable. 

Explaining biological variability to patients 

This introduces an important point that must be communicated clearly to patients: variability is part of how regenerative treatments work. Unlike traditional volumising procedures, these modalities rely on the individual’s biological response. Collagen synthesis takes time, and growth factor signalling differs between patients. Even when histological studies demonstrate increased collagen deposition, the visible outcome may not appear identical in every individual.4,5 This variation is a reflection of normal biological diversity. 

 

The challenge isn’t removing variability, because that’s not realistic, the challenge is explaining it clearly. Variability exists on several levels. Some of the key factors include:  

 

  • Age influencing fibroblast density and responsiveness6 
  • Smoking status impacting microvascular perfusion7 
  • Metabolic health and systemic inflammation altering wound healing dynamics8 
  • Hormonal status changing collagen behaviour9 
  • Sun exposure and skincare adherence modifying how tissue responds to stimulation10 

 

Two patients can receive the same product, at the same dilution, injected at the same depth, and still demonstrate different timelines and degrees of visible improvement. 

 

This becomes particularly important when we think about consent. When a treatment produces an immediate structural change, predictability feels more obvious. When it relies on biological stimulation, results tend to appear gradually and sometimes more subtly. One patient may see steady improvement over several months, another may see a softer response despite using the same product and technique. If we describe regenerative treatments in language that suggests immediate, dramatic transformation, we then risk creating expectations that biology can’t always match.There is also a psychological dimension to this. Patients often tolerate swelling, bruising or temporary discomfort because they understand those risks as part of a procedure.  

 

What is harder to tolerate is ambiguity. Subtle improvement can feel like uncertainty. Gradual change can feel like doubt. If that nuance hasn’t been explained in advance, the patient may interpret normal biological variation as treatment failure. That gap between expectation and physiology is where dissatisfaction most commonly arises.  

 

Regenerative treatments are also often perceived as more natural or more aligned with the body’s own processes. That perception isn’t necessarily inaccurate, but it can create an assumption that outcomes will be gentle, predictable and universally positive simply because they are biologically based.  

 

Natural doesn’t automatically mean uniform. Biological compatibility does not equal clinical certainty. Making that distinction clear is part of meaningful consent, particularly in a field that often promotes regeneration as inherently reassuring. As well as knowing a treatment is safe, patients want to know what it’s likely to look like, how long it might take, how long it may last, and how strong the evidence is behind it.  

 

Understanding the evolving evidence base 

In regenerative aesthetics, those questions are often more significant than the short-term side effect profile. The scientific literature reflects this nuance. Reviews of platelet rich plasma report improvements in skin texture and elasticity, while also noting differences in preparation methods and reporting standards across studies.4 

 

Research into collagen-stimulating agents shows increased collagen production, but the degree of visible change still depends on the individual.5 Exosome research continues to develop, with ongoing discussion about standardisation and consistency.6 None of this weakens regenerative aesthetics, it simply places it within a field that is still evolving and refining itself.  

 

What also emerges from the literature is heterogeneity. Preparation protocols differ. Centrifugation speeds vary. Concentrations are not always standardised. Sample sizes are often modest. Some studies rely on histological or imaging endpoints rather than patient-reported outcome measures. In newer areas such as exosome-based therapies, isolation techniques, purity thresholds and characterisation methods remain under discussion.  

 

Commercial interest and clinical adoption have, in some areas, progressed faster than methodological standardisation. That does not render these treatments unsafe or inappropriate. It does, however, situate them within a spectrum of evidence maturity. 

 

Evidence in medicine ranges from early exploratory data through to large scale, reproducible trials with long-term follow up. Many regenerative modalities sit somewhere in the middle of that spectrum. The biological rationale may be strong. Early clinical data may be promising. Long-term comparative datasets may still be limited.  

 

Under Montgomery, the test is not whether uncertainty exists, but whether that uncertainty would be material to a reasonable person in the patient’s position.11 For some patients, knowing that a treatment has decades of longitudinal data matters. For others, understanding that it is biologically plausible and increasingly adopted may be sufficient. The role of the practitioner is not to overwhelm with academic detail, but to communicate proportionately where a treatment sits within that evidential landscape.  

 

Emerging evidence is not a warning label, it’s context. When that context is explained clearly, regenerative practice remains innovative without becoming overconfident. When it is omitted, marketing fills the gap. Consent, in this setting becomes the mechanism by which scientific nuance is translated into patient understanding.  

Legal expectations and the standard for informed consent 

In the UK, the legal standard for consent was clarified in Montgomery v Lanarkshire Health Board.11 We’re required to make patients aware of material risks and reasonable alternatives, including the option of no treatment at all. Material means information that a reasonable person in that patient’s position would consider important. In regenerative practice, what patients often consider important includes predictability, timescale, durability and the strength of supporting evidence, not just complications such as redness, swelling or bruising.  

 

The statutory framework supports this. Regulation 11 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 requires valid consent, and Regulation 12 requires safe care and proper risk assessment.12 Professional guidance from the General Medical Council and the Nursing and Midwifery Council emphasises practising in accordance with the best available evidence and communicating clearly.13,14 These standards support regenerative innovation by ensuring that it develops responsibly.  

 

From a medico-legal perspective, it is not difficult to imagine the shape of a future complaint in regenerative aesthetics. The allegation is unlikely to centre on catastrophic complication. It is more likely to read: “I wasn’t told results might be subtle,” or “I thought this would replace filler,” or “I didn’t realise the evidence was still emerging.”  

 

Those concerns are less dramatic but equally significant. They revolve around expectation, not injury. Clear documentation that variability, timeframe, durability and evidence maturity were discussed is good clinical practice.  

 

Practical steps for regenerative consent conversations 

 

So what does effective consent look like in regenerative aesthetic practice? The following principles provide a practical guide. 

 

 1. Explain mechanism of action  

 

Detail how the treatment works in straightforward terms. If a modality stimulates collagen, the patient should understand that collagen builds gradually and that response varies. If the treatment uses platelet rich plasma, they should understand that their own biology influences the outcome. Explaining mechanism helps patients understand why results may take time.  

 

In clinic, that explanation might sound simple. “This isn’t a filler. It’s designed to encourage your skin to produce more of its own collagen. That takes time, and everyone’s response is slightly different. Some people see steady change over three to six months. Others see more subtle improvement. We’ll review as we go.”  

 

2. Make timelines clear  

 

Instead of saying that results “develop over time,” it’s more helpful to outline what that time may look like. When might they first notice change? When is improvement likely to peak? Will more than one session be required? Being specific reduces the risk of disappointment.  

 

3. Detail durability and maintenance  

 

Durability should also be discussed honestly. Regenerative treatments are often described as longer lasting, but duration varies depending on the modality and the individual. If maintenance is likely, that should be part of the initial conversation rather than an afterthought.  

 

4. Discuss combination approaches  

 

In reality, regenerative modalities are rarely delivered in isolation. They are often combined with structural treatments, devices or ongoing skin health strategies. When treatments are layered, consent needs to address how biological stimulation interacts with other interventions and how outcomes may overlap or evolve together. That broader framing helps patients understand that improvement may be cumulative rather than attributable to a single step.  

 

 5. Outline the evidence-base  

 

Evidence matters too. Some regenerative approaches have stronger and longer datasets than others. Patients don’t need detailed academic discussion, but they do deserve to know whether a treatment is well established or still building its evidence base. Being open about that strengthens trust rather than weakening it. 

 

Off-label/off-licence use is another area where clarity helps. Off-label prescribing is lawful when clinically justified and supported by appropriate evidence or experience.13,14 In regenerative practice, where indications are evolving, explaining whether a treatment is being used within its licence or outside it gives patients a clearer understanding of context.  

 

 6. Highlight products’ regulatory status  

 

Regulatory awareness also plays a role. The Medicines and Healthcare products Regulatory Agency determines how medicines and devices are classified in the UK.15 As newer regenerative products enter the market, understanding their regulatory status helps distinguish careful medical practice from trends. The medico-legal framework, informed by Bolam v Friern Hospital Management Committee, requires that practice is supported by a responsible body of professional opinion.16 

 

 7. Consider your marketing language  

 

Marketing is part of the ecosystem as well. The Advertising Standards Authority requires that claims are accurate and not misleading.17 When promotional language reflects scientific reality, the consultation becomes an extension of that honesty rather than a correction of exaggeration. If regeneration is presented publicly as guaranteed rejuvenation, consent becomes damage control. If it is presented as biologically guided improvement with inherent variability, consent becomes a continuation of that same message. 

 

 8. Ensure clear documentation of discussions  

 

In regenerative aesthetics, that support comes not only from published data but from clear reasoning and careful documentation. Records should reflect that variability, timescale and durability were discussed. Generic phrases don’t capture biological nuance.   

  

Building credibility through transparent consent 

 

What will define the long-term credibility of regenerative aesthetic treatments is not uniform outcomes, because uniformity is not biologically possible, but the transparency with which we discuss variability and evolving evidence. 

 

Innovation without proportionate communication risks turning regenerative medicine into another cycle of overpromise and correction. If we want this field to mature, we must resist the temptation to present biological stimulation as guaranteed rejuvenation. The science is promising. The biology is complex. Consent is where that complexity must be respected.   

Comment from Anna Baker, RN INP, Advisory Contributor: “An insightful piece which reinforces due diligence to medical aesthetic practitioners regarding specific factors to include within the consent process, relevant to this evolving and specialised field of practice. Emphasis is placed on providing transparency to patients with guidance around managing patient expectation in terms of timeframe of improvement with regenerative treatments. This paper provides relevant and practical steps to guide clinicians in undertaking rigorous consent for a variety of regenerative procedures.” 

Jen Vittanuova is a nurse prescriber, clinical director and expert witness with more than 25 years’ experience in medical aesthetics and cosmetic surgery. She is known for her clear, practical approach to clinical safety, consent and documentation and regularly speaks at conferences across the UK on risk management and best practice in aesthetics. Alongside her clinical work, Jen provides expert witness reports in cases involving aesthetic treatments and teaches medical professionals through her education brand, Legally Aesthetic. Her style is warm, direct and grounded in real world experience, making complex medico-legal topics accessible and genuinely useful for everyday practice.

References

  1. Mao AS, Mooney DJ. Regenerative medicine: Current therapies and future directions. Proc Natl Acad Sci U S A. 2015;112(47):14452-14459. 
  1. Fisher GJ, Varani J, Voorhees JJ. Looking older: fibroblast collapse and therapeutic implications. Arch Dermatol. 2008;144(5):666-672. 
  1. Quan T, Fisher GJ. Role of age-associated alterations of the dermal extracellularmatrix microenvironment in human skin aging. Gerontology. 2015;61(5):427-434. 
  1. Alves R, Grimalt R. A review of platelet-rich plasma: history, biology, mechanism of action and classification. Skin Appendage Disord. 2018;4(1):18–24.   
  1. Fitzgerald R, Vleggaar D. Facial volume restoration with collagen-stimulating agents. Dermatol Surg. 2011;37(1):31–44.   
  1. Quan T, Fisher GJ. Role of age-associated alterations of the dermal extracellular matrix microenvironment in human skin aging. Gerontology. 2015;61(5):427-434. 
  1. Morita A. Tobacco smoke causes premature skin aging. J Dermatol Sci. 2007;48(3):169-175. 
  1. Guo S, Dipietro LA. Factors affecting wound healing. J Dent Res. 2010;89(3):219-229. 
  1. Thornton MJ. Estrogens and aging skin. Dermatoendocrinol. 2013;5(2):264-270. 
  1. Krutmann J, Bouloc A, Sore G, Bernard BA, Passeron T. The skin aging exposome. J Dermatol Sci. 2017;85(3):152-161. 
  1. Montgomery v Lanarkshire Health Board [2015] UKSC 11. 
  1. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. London: The Stationery Office; 2014. 
  1. General Medical Council. Decision making and consent. London: GMC; 2020.   
  1. Nursing and Midwifery Council. The Code: Professional standards of practice and behaviour for nurses, midwives and nursing associates. London: NMC; 2018.   
  1. Medicines and Healthcare products Regulatory Agency. Guidance on regulating medical devices in the UK. London: MHRA; 2023.   
  1. Bolam v Friern Hospital Management Committee [1957] 1 WLR 582.   
  1. Advertising Standards Authority. UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code). London: ASA; 2023.  

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