In January 2026 the MHRA updated the prescribing requirements for isotretinoin. The headline change: the requirement for two prescribers to agree treatment for patients under 18 has been removed.
That rule had been introduced as an additional safeguard for younger patients. On review, the MHRA found it was causing delays in access with minimal evidence of prescribers actually disagreeing — in other words, it was adding waiting time without adding much scrutiny.
What Replaced It
The two-prescriber rule was not simply deleted. It was swapped for measures the regulator judged more likely to affect outcomes:
- A revised Acknowledgement of Risk Form, which asks the patient to confirm they understand what isotretinoin is for, and asks the prescriber to confirm it is clinically indicated with no other appropriate effective treatment
- A patient information video produced by the British Association of Dermatologists with MHRA and Commission on Human Medicines oversight
- Clinical audit of risk minimisation measures, developed by the BAD, with data submitted to the MHRA
- Updated guidance on follow-up consultations, pregnancy testing, and discussing mental health and sexual side effects
The shift is from a procedural check at the start to ongoing oversight during treatment — and from one prescriber checking another to systematic data about how services actually perform.
What Did Not Change
Everything substantive about safety remains:
- Isotretinoin is still initiated under consultant dermatologist supervision
- The pregnancy prevention programme is unchanged and unrelaxed
- Signed risk acknowledgement before starting is still required
- Counselling about side effects before treatment is still required
- Patients under 18 can still request a second opinion — it is now a right they can exercise rather than a step imposed on everyone
Why This Is a Reasonable Trade
Severe acne scars, and scarring is permanent. Delay in treating it has a real cost that is easy to overlook when the focus is on the risks of the medicine. A safeguard that adds months of waiting without changing decisions is not free — it is paid for in scarring.
Equally, the measures replacing it are not weaker in any obvious sense. A patient who has watched a proper information video and signed a form that spells out the alternatives is arguably better informed than one whose prescription was countersigned by a second doctor they never met.
What It Means If You Are Waiting
If you are under 18 and have been referred for isotretinoin, one procedural step in the path has been removed. It does not remove the dermatology waiting list, which in most areas is the larger constraint.
What It Means If You Are Being Treated
Expect follow-up consultations to include direct questions about mental health and sexual side effects. Those questions are now explicitly part of the guidance. They are asked because the answers matter, and the appropriate response is a straight answer rather than a polite one.
The Wider Point
Regulators do sometimes remove requirements, and doing so is not a weakening of standards by definition. Reviewing whether a safeguard actually works — rather than keeping it because removing it looks bad — is what proportionate regulation is supposed to look like.