EOHCB STANCE ON THE ALLIED HEALTH PROFESSIONS ACT - SOMATOLOGISTS SCOPE UNDER ALLIED HEALTH PROFESSIONS COUNCIL OF SOUTH AFRICA (AHPCSA)
- EOHCB National
- 1 day ago
- 15 min read
Subject: Submission regarding the Proposed Inclusion of Somatology Under the Provisions of the Allied Health Professions Council of South Africa (AHPCSA)
The Employers’ Organisation for Hairdressing, Cosmetology and Beauty (EOHCB), a registered employers’ organisation representing over 2000 employers within the cosmetology and beauty industry, we express our concern regarding the Allied Health Professions Council of South Africa’s (AHPCSA) intention to open a statutory register for Somatologists.
While we acknowledge the importance of professional regulation, we believe this proposal raises significant sectoral challenges that warrant consideration and call for a more nuanced, consultative approach.
Concerns have also been raised by United Association of South Africa (UASA), Solidarity, The National Bargaining Council for Hairdressing, Cosmetology, Beauty, and Skincare Industry (HCSBC), The South African Association of Health and Skincare Professionals (SAAHSP) and other industry role-players.
KEY CONCERNS:
The practice of Somatology within the Beauty Industry
The beauty industry has evolved rapidly, with new technologies, techniques, and products expanding the scope of services offered by professionals such as Somatologists. In some cases, this evolution has positioned Somatologists to receive referrals from healthcare practitioners, particularly where advanced aesthetic or wellness interventions are involved. However, not all Somatologists engage in medical aesthetics, and this divergence in practice has raised concerns about how regulation should be applied across the profession.
The Somatology Diploma (NQF Level 6), a three-year higher education qualification, provides expertise in skincare, health, and holistic wellness. It is designed to prepare
graduates for careers in salons, spas, aesthetic clinics, and the beauty industry, offering a theoretical knowledge and practical skills from basic to advanced treatments.
The Advanced Diploma in Somatology (NQF Level 7) includes specialisation in complementary and palliative care, incorporating techniques such as deep tissue, lymphatic, and sports massage skills that can provide auxiliary support to medical professionals.
Somatologists are positioned to pursue different career avenues, two of which are compared below:
| Basic Aesthetics (Personal Care) | Advanced Aesthetics (Health Related) |
Focus area: | Purely aesthetic focus. Beauty and relaxation. | Complementary and palliative care (may be referred by Medical Practitioner) |
Work environment: | Traditional salon and spa environments | Specialised settings like wellness clinics or medical spa’s |
Client: | Client seeking improved general wellness and aesthetic appearances. | Client seeking health-aligned services |
Services: | Purely aesthetic treatments, information and the practice of healthy lifestyle habits. | Medical or therapeutic approaches to skincare and body care. Auxiliary support to medical professionals |
Typical qualification: | Beauty technologist, Beauty Therapy (NQF 4), Advance Beauty Therapy (NQF 5), Diploma in Somatology (NQF 6) | Somatology Diploma (NQF6), Advanced Diploma in Somatology (NQF 7) or Advanced Diploma in Aesthetic Medicine (NQF 7) |
A differentiation needs to be drawn between Somatologists that practice basic aesthetics in a salon environment and those who practice advanced aesthetics.
Overlapping Competencies Across Designations
Somatologists operate across a spectrum - not all Somatologist practice health-aligned services.
A blanket requirement for all Somatologists to register risks regulatory overreach due to overlapping competencies across different designations.
Exclusive scopes for Somatologists may marginalise other qualified practitioners and restrict service delivery.
Services like chemical peels, and laser treatments are performed by various professionals - beauty therapists, somatologists, medical aestheticians. By using the Somatology curriculum as a scope of practice there is a risk of regulatory overreach or exclusion of existing practitioners who perform similar services under different qualifications. Such an approach could exclude practitioners who operate within the traditional personal care sector (salon and spa environments) and do not engage in advanced aesthetics or health-aligned services.
In addition, while considering that a registered Somatologist would be prohibited from practicing a non-registered profession, they may not be able to perform services for which they are qualified to perform but was not included in the scope such as facials, waxing, tinting, basic massage, nail care (manicures, pedicures), makeup application and retail skincare advice.
This could disrupt existing business models, particularly for small enterprises leading to the potential for job losses and business closures if regulations are enforced without differentiation between basic and advanced aesthetic services.
Scope Ambiguity
There is a lack of clarity on how curricula, CHE/SAQA accreditations, and qualifications will be interpreted. Reliance on curriculum classification as criteria for scope inclusion creates significant ambiguity without detailing exactly how these are applied.
A blanket registration requirement risks overregulation and misalignment with non-medical beauty practices.
No transparent criteria for scope inclusion/exclusion, creates uncertainty and risk for existing practitioners.
While curriculum and accreditation bodies are cited by The Allied Health Professions Council of South Africa, there is no explanation of how these are interpreted or weighted. For instance, many beauty qualifications include modules on chemical peels, laser treatments, and other procedures, yet it remains unclear whether these would be deemed sufficient for scope inclusion or exclusion.
The Risks identified by The Allied Health Professions Council of South Africa include services offered by Somatologist being “invasive and carrying health risks”. Services included in their examples included laser therapies, micro-needling, chemical peels, treatment to damaged capillaries, tattoo removal and palliative care however the risk profile of these services varies substantially:
Micro-needling: Treatments range from low-risk epidermal procedures (0.25mm–1mm), which use devices readily available over the counter (e.g., at Clicks), to higher-risk dermal interventions (up to 2mm).
Laser therapies: There are significant differences between non-ablative, fractional, and ablative laser treatments, each with distinct safety considerations.
Chemical peels: These can be performed at superficial levels or penetrate to the dermal layer, depending on the product and formulation used.
This ambiguity prevents stakeholders in the beauty industry from accurately assessing the regulatory impact, particularly regarding overlapping job functions.
Jurisdictional Overlap and Professional Oversight
The proposal risks creating jurisdictional overlap within the beauty industry. The beauty industry is already governed by the HCSBC (statutory) and SAAHSP (voluntary).
AHPCSA’s involvement may create confusion and regulatory duplication and jurisdictional overlap
The beauty and personal care industry already operates under two established bodies:
The National Bargaining Council for Hairdressing, Cosmetology, Beauty, and Skincare Industry (HCSBC), a statutory body mandated to manage labour relations, collective agreements, and employment standards.
The South African Association of Health and Skincare Professionals (SAAHSP), a voluntary professional body that promotes ethical standards and professional development.
The Allied Health Professions Council of South Africa is a Statutory Body empowered to regulate and govern twelve professions including: Aromatherapy, Ayvrveda, Chinese Medicine and Acupuncture, Chiropractic, Homeopath, Naturopathy, Osteopathy, Phytotherapy, Therapeutic Aromatherapy, Therapeutic Massage Therapy, Therapeutic Reflexology and Unani-Tibb.
The AHPCSA’s mandate does not extend to aesthetic or beauty-related services unless they directly overlap with therapeutic health professions.
While AHPCSA cites “invasive treatments such as laser therapy and chemical peels” as justification, for oversight, these services are already subject to consumer protection laws, occupational health standards, and voluntary professional oversight.
Regulatory Misfit
AHPCSA’s health-sector norms (e.g., advertising bans, employment restrictions, consulting room requirements) conflict with standard beauty industry practices. These norms could disrupt business models, especially for small enterprises and non-health-aligned practitioners.
Potential for job losses and business closures if regulations are enforced without differentiation
The traditional beauty industry operates under a commercial model that includes practices typically restricted in the health professions, such as commission-based remuneration, retail product sales, client advertising, and shared premises with non-registered professionals (e.g. beauty therapists, hairdressers, personal trainers). Imposing health-sector regulatory norms on the entire Somatology profession could therefore fragment the industry, disrupt livelihoods, and create unnecessary barriers for beauty salons who do not align with a medical model.
The Employers’ Organisation for Hairdressing Cosmetology and Beauty (EOHCB) and the National Bargaining Council for Hairdressing, Cosmetology, Beauty and Skincare industry (HCSBC) conducted a voluntary survey across a number of businesses to obtain a view of the impact that the current AHPCSA regulations would have. A summary of the key findings is included below:
Regulation | Risk Level | Key Findings |
Advertising restrictions | High | All the surveyed businesses use advertising platforms |
Use of “clinic/institute” | Low | Minority use these terms |
Signage limitations | High | Incompatible with beauty sector norms |
Employment restrictions | High | Most employers are not Somatologists |
Shared premises | High | All surveyed operate in shared spaces |
Scope of services | High | Overlap with non-registered professions |
Retail and commissions | High | Majority surveyed offer retail commissions |
A more detailed analysis of AHPCSA regulations and their practical implications is contained below in Annexure A.
Financial Burden
Mandatory AHPCSA registration entails significant fees, plus indirect costs (e.g., First Aid certification).
The Allied Health Professions Council of South Africa is a Statutory Body and therefore, should a professional register be opened for Somatology, registration will be compulsory.
The following fees for 2025 have been extracted from the AHPCSA website.
R720 registration fee for students
R2,000 examination fee
R2,899 application fee
R2,899 Compulsory annual registration fees (in respect of one profession)
A comprehensive list of imposed fees is available at https://ahpcsa.co.za/schedule-of-fees/. At the time of drafting this letter, there was no indication on their website what the fees for 2026 would be.
There would also be indirect costs including, as an example, requirements for a current Level One First Aid Certificate. (https://ahpcsa.co.za/registration-requirements/)
This, in addition to statutory fees payable due to the HCSBC and non-statutory fees for voluntary professional bodies (e.g. SAAHSP) by beauty industry participants.
These costs are unsustainable for many in the traditional beauty sector.
Lack of proper consultation
Industry is unable to properly assess and respond to the potential impact without understanding the scope.
The lack of clarity regarding what will be included or excluded from the scope of proposed regulatory or policy changes renders any attempt to assess their impact on the beauty industry premature, speculative, and potentially misleading. Stakeholders are entitled to understand the rules that may govern them before being expected to comply or comment meaningfully.
Without a clear definition of scope, stakeholders cannot determine whether specific beauty sector activities will be affected. This uncertainty makes it impossible to isolate relevant provisions and evaluate their implications.
No formal risk assessment has been done to measure the impact of statutory regulation by AHPCSA however, initial survey responses received indicate that there would be widespread consequences to the traditional beauty industry and that it is crucial to differentiate between Somatologists who are employed in the traditional Beauty industry and Somatologists who actively pursue promotive or curative health work, or who collaborate with medical practitioners rather than a blanket obligation across the entire Somatology profession.
Conclusion and Recommendation
Until the scope is clearly defined - preferably with clause-referenced inclusions and exclusions, the beauty industry cannot responsibly assess the impact of the proposed changes. Any attempt to do so would be speculative and risk misinforming members and undermining the regulatory process.
We therefore respectfully urge the Minister to:
Defer any decision on statutory registration until a full impact assessment and stakeholder consultation is conducted.
Condict a muti-stakeholder consultation forum including the National Bargaining Council for Hairdressing, Cosmetology, Skincare and Beauty industry (HCSBC), the Employers’ Organisation for Hairdressing, Cosmetology, and Beauty (EOHCB) and United Association of South Africa (UASA).
Define the proposed scope clearly with draft regulations for public comment
Consider alternative regulatory models, such as strengthening voluntary professional bodies or introducing targeted licensing for higher-risk procedures (e.g. Advanced aesthetics).
Consider that imposing health-sector regulatory norms on the entire Somatology profession could disrupt the industry and livelihoods, and create unnecessary barriers for practitioners who do not align with a medical model
Ensure that any future regulation aligns with the economic realities and operational structures of the beauty and wellness sector.
We remain committed to supporting safe, ethical, and professional practice within Somatology and welcome the opportunity to engage further on this matter.
ANNEXURE A
Industry Survey
Analysis of the AHPCSA regulations and their practical industry implications:
ADVERTISMENT AND CANVASSING OR TOUTING FOR PATIENTS |
AHPCSA regulation: “Canvassing or touting for patients in whatever manner shall be prohibited.” Advertising services in a manner which contravenes the provisions as stipulated in the HPCSA Guidelines for Making Professional Services Known [Section 5] or acquiescing to, permitting, or sanctioning such advertising is prohibited.
Practitioners may communicate with their patients with whom they hold a bona fide practitioner-patient relationship via practice notices, including newsletters, but such communications may not be distributed to the public at large, except with the explicit permission of the patient only. |
Survey: “Do you make use of any advertising to attract new business and in what form?”
All of surveyed businesses that employ Somatologists made use of advertising to canvas new clients including social media (Instagram, Facebook, TikTok), SMS, email, WhatsApp, newspaper adverts, pamphlets, street poles, Google Meta ads, networking, local events and other professional platforms
|
Industry impact: Larger employer like The Sorbet Group specifically have an entire Marketing Department that cavasses for new business. One business owner specifically commented “our entire business runs on Advertising to recruit new business and sustain the business model”.
The regulation is of high risk to the industry |
USE OF NAMES |
AHPCSA regulation: Descriptive trade names for the practices may not be used.
The use of an expression for a practice or building name such as “hospital”, “clinic” or “institute” or any other special term which could create the impression that a practice is, or forms part of, or is in association with a hospital, clinic or similar institution, may not be used.
“A practitioner may not use as a name for a private practice – (a) any name or expression, except the name of the practitioner or where practitioners practice in partnership or as a juristic person, the names of such practitioners; or (b) the expression “hospital” or “ medical clinic” or any other special term in a way that could create the perception that such a practice forms a part of, or is in association with, a medical hospital, medical clinic or similar institution.” |
Survey: Do you make use of the words "hospital", "clinic" or "institute" or similar word/s in your business name or advertisements? There are a few businesses that use beauty clinic and beauty institute as part of their business name or advertising however the majority of businesses do not use these expressions. |
Industry impact: The regulation is of low risk to the industry. |
ADVERTISMENT |
AHPCSA regulation: Only one outside sign may be used, except in the case of a large complex with more than one entrance where a sign may be placed at each entrance. The sign should be placed on the premises where the practice is situated, or, at most, at the street corner closest to the premises.
Signs and name-plates may not be larger than 360mm X 250mm
The Regulations provide that a practitioner may only display a sign on the premises of the practice which sign may state the following:
You may not advertise non-registered qualifications together with registered qualifications, and you may not make unlawful health or curative claims of any kind. |
Industry impact: This regulation would be problematic for Somatologists who are employed in the traditional beauty sector and do not engage in health-aligned services. |
EMPLOYMENT AND PARTNERSHIPS |
AHPCSA regulation: Employing or being employed by a non-registered professional is prohibited. “Subject to the provisions of subregulation (2) a practitioner, in the pursuance of his or her profession, may not enter into a partnership or, where any partnership exists at the commencement of the regulations, maintain that partnership, with a person who is not registered - (a) as a practitioner under the Act; or (b) (c) as a medical practitioner in terms of the Health Professions Act, 1974; or in terms of the Health Professions Act, 1974, in respect of a supplementary health service profession which is approved by the professional board as an acceptable profession for the purposes of a partnership.
Subregulation (1) shall not be construed to prevent a practitioner from employing a person practising a profession to which the provisions of the - (a) Pharmacy Act, 1974; (b) (c) Health Professions Act, 1974; or Nursing Act, 1978 apply, or maintaining that employment or co-operation with such person.
A registered person may not employ - (a) as a professional assistant or locum tenens any person who is not registered in terms of the Act; (b) (c) a person whose name has been removed from any register kept by the council in terms of the Act or who has been suspended from practising his or her profession; or any other unregistered health service person or refer patients to such unregistered person. |
Survey: Are you (as an Employer) a qualified Somatologist yourself? Which of the following job designations do you employ within your business?
In a sample group of 25 surveyed businesses that currently employ Somatologists only seven employer were Somatologists themselves.
Of these seven employers who were qualified Somatologists themselves, they all employed non-registered professions such as Nail Technicians, Massage Therapists, Beauty Therapists, Hairdressers/Stylists etc |
Industry impact: This regulation would be problematic for Somatologists who are employed in the traditional beauty sector and do not engage in health-aligned services.
There are more than 70 Somatologists currently employed by businesses in the Hairdressing, Cosmetology, Beauty and Skincare Industry (statistics provided by the HCSBC) which would be prohibited from employing or being employed by a non-registered professional should a Somatology register is established.
These employees could only continue their employment if their employers themselves are qualified Somatologists. This will certainly lead to the widespread retrenchment of Somatologists currently employed in the industry and therefore of high risk to the industry. |
SHARED PREMISIS AND CONSULTING ROOMS |
AHPCSA regulation: Registered practitioners may not work with or share premises with non-registered persons/practitioners. Meaning Somatologists will not be allowed to share a premises with Hairdressers, beauty therapists, personal trainers, etc.
“The consulting rooms of a practitioner shall consist of – (a) at least two separate rooms, one of which is used for consultation with and the examination and treatment of patients, and the other, a room easily accessible from the first room, for a reception and waiting room providing sufficient seating for patients; and (b) a changing cubicle or screen where a patient, if so required, may undress and dress in privacy.
The consulting rooms must have accessible ablution facilities. If any part of a residence is used as consulting rooms, such part shall be used exclusively as consulting rooms and shall be accessible from the outside without necessitating the patient’s entering such part through the residence.
In the case of therapeutic aromatherapy, therapeutic massage therapy and therapeutic reflexology, a practitioner registered in that profession shall be afforded a period of five years from the date of establishment of the register to comply with subregulations (1), (2) and (3), and when a treatment is carried out on site the facilities shall be commensurate with the community environment. |
Survey: Does your Somatologist have their own space (or room/s)? Please explain the space (one or two rooms, does it have a waiting room, own reception, seating area, changing cubicle etc).
In a sample group of 25 surveyed businesses that currently employ Somatologists none of the businesses would currently comply with this regulation. Even those who have their own treatment rooms still operate within a shared space with non-registered persons (such as Nail Technicians, Massage Therapists, Beauty Therapists, Hairdressers/Stylists etc). |
Industry impact: The traditional beauty sector employs a variety of professions alongside one another.
This regulation is not feasible for Somatologists who are employed in the traditional beauty sector and do not engage in health-aligned services.
The regulation is of high risk to the industry. |
SERVICES |
AHPCSA regulation: As a registered practitioner, practicing a non-registered professions is prohibited. |
Survey: Which services does your Somatologist/s provide?
The majority of survey respondents indicated that their employed Somatologists provided both basic skincare therapy (skin analysis; facial treatment; exfoliation treatment; body wraps and/or mask treatment) as well as advanced facial skincare (Non-invasive classic deep cleansing facial treatment; Invasive deep cleansing facial treatment; Chemical peels; Skincare therapy performed with electrical equipment and/or machines such as galvanic and/or high frequency; Micro Needling) |
Industry impact: There may be part of a Somatologists duties that does not require a person to be licensed or registered with a specific statutory body to practice. A more detailed explanation can be found under the heading of “Overlapping Competencies Across Designations” above.
The regulation is of high risk to the industry. |
PROHIBITION OF RETAIL SALES AND COMMISSION AGREEMENTS - |
AHPCSA regulation: The following acts, among others, are not permitted:
“A practitioner in active practice may not: (a) accept request or insist on any commission, remuneration, pecuniary or otherwise, from a pharmacy, health shop, manufacturer or dealer in medicines, remedies or any equipment, apparatus, instruments, appliances or material used in the course of his or her practice or prescribed for patients; (b) pay, give or accept any commission or remuneration, pecuniary or otherwise, to any person for the recommendation of patients; (c) share any fees charged for a service with any person other than a partner unless such sharing is commensurate with the scope of such other person’s participation in the rendering of such service; (d) have financial interest, whether by way of fixed salary or otherwise, in medical aid schemes, institutions or associations which canvass members by way of advertisement; (e) act as an agent or representative or in any capacity whatsoever market or sell a product, device or thing whether such sale or promotion is for his or her own account or the account of another person or company or receive any commission or remuneration, pecuniary or otherwise; (f) use or allow his or her name to be used in an advertisement or in the promotion or sale of any product, medicine, device or thing from another person or company; or in any way provide anything from his or her practice premises by means of sale or otherwise to any person with whom he or she has not had a recorded consultation: Provided that the professional board concerned may, after a substantiated application has been received from a registered practitioner, at its discretion, approve such provision.” |
Survey: Does the Somatologist you employ retail products as part of their employment? Do you offer Commission on the sale of Retail products?
In a sample group of 25 surveyed businesses that currently employ Somatologists all of the businesses offered commission on the sale of retail products. |
Industry impact: It is common practice within the traditional beauty industry to have retail product shelves in their businesses and to offer employees commission on the sale of retail products. Somatologists regularly make product recommendations (not prescriptions) for retail products that are best suited to a client’s skin type based on an analysis of their skin.
This regulation would be a high risk for Somatologists who are employed in the traditional beauty sector and do not engage in health-aligned services. |
Scope Ambiguity and Lack of Transparent Criteria Application
|
Questions posed to Ms Esther Pillay-Naidoo, Registrar of Allied Health Professions Council of South Africa:
“Please could you indicate what exact criteria do you use to determine when a job category/qualification falls under your scope?
Should a register be started for Somatology, what effects would it have on other job designations as to what work they may or may not perform? Eg Chemical peels, laser, tattoo removal etc.”
Answer received from Ms Esther Pillay-Naidoo, Registrar of Allied Health Professions Council of South Africa:
“This is based on curriculum, CHE and SAQA accreditations and classification.
A register will have a scope of practice that will determine what a Somatologist is allowed to do. This means that only a Somatologist will be allowed to do the work as defined in the scope of practice which is based on curriculum.” |
Industry Concern: See “Scope Ambiguity” above. |
