Ahpra: New cosmetic guidelines to ‘futureproof’ system

With Ahpra announcing that it is putting the ‘booming billion-dollar cosmetic industry on notice’ with new cosmetic procedures guidelines coming into effect on 2 September, we take an in-depth look.

The Australian Health Practitioner Regulation Agency (Ahpra) has declared Australians ‘undergoing cosmetic procedures such as anti-wrinkle injections and fillers will have greater protections under sweeping guidelines being introduced across the booming billion-dollar industry’.

In its June 3 announcement, Ahpra explained that ‘with more professions being enticed to the lucrative cosmetic procedures industry, the regulator is future-proofing the system by having guidelines for all registered health practitioners’.

In addition, further training or education ‘will be necessary for many practitioners wanting to expand their scope of practice into non-surgical cosmetic procedures’.

And young Australians ‘will be protected with targeted advertising banned and a seven- day cooling off period for those under the age of 18’.

Ahpra and the National Boards have published advance copies of two sets of guidelines ‘which will strengthen safeguards across the industry’ when they come into effect on 2 September 2025:

• Guidelines for practitioners who perform non-surgical cosmetic procedures;
• Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures.

Nursing and Midwifery Board of Australia Chair Adjunct Prof Veronica Casey said the safety of the Australian public is paramount.

These types of procedures ‘are undertaken every day and can have serious consequences if not done correctly’, said Prof Casey.

‘No practitioner should put their bottom line ahead of patient welfare, and these guidelines place the focus squarely on the safety of those in their care.’

Ahpra emphasised the new protections ‘highlight that many practitioners need more than just the foundational qualifications included in their initial training before they can safely perform non-surgical procedures like cosmetic injections’.

It noted further training or education will be necessary for those practitioners wanting to expand their scope of practice.

Nurses will also be required to complete a set period of practice before expanding their scope to include non-surgical cosmetic procedures.

Ahpra said while cosmetic procedures ‘remain out of scope for many practitioners, the guidelines will now apply to all regulated professions, future- proofing those that may join the lucrative cosmetic industry’.

The new practice guidelines ‘bring all registered health practitioners in line with medical practitioners, who already have their own guidelines. They also remind practitioners of their obligation to put patient welfare first and foremost with the prescriber remaining responsible for patient care.’

Ahpra said the guidelines build on the safeguards put in place by the Medical Board of Australia (MBA) in 2023 and replace the Nursing and Midwifery Board of Australia’s ‘Position statement: nurses and cosmetic medical procedures’.

MBA Chair Dr Susan O’Dwyer said the guidelines would help better protect patients by aligning standards across professions. ‘These guidelines make sure we’re all working from similar play books for the safety of our patients,’ she explained.

‘We’re also raising the bar for anyone advertising these procedures, making it simpler for consumers to make safe and informed decisions.’

The advertising changes include a focus on higher risk procedures by:

• requiring advertisements to contain information about the practitioner performing the procedures;
• strengthening the ban on the use of testimonials from social media influencers; and
• putting measures in place to stop the trivialisation or sexualisation of a cosmetic procedure.

Those under age 18 considering non-surgical cosmetic procedures will have a mandatory seven-day cooling off period between their first consultation and any procedures, while advertising aimed at under 18s will be totally banned.

‘This industry relies heavily on a social media presence. So practitioners have been put on notice that their advertising must comply with the new guidelines when they come into effect later this year,’ says Ahpra CEO Justin Untersteiner.

Nurse & dentist targets

The ABC commented that Ahpra ‘is tightening guidelines for dentists and nurses performing non-surgical cosmetic injectable procedures’, noting that ‘nurses and dentists have been operating in the cosmetic injectable industry for years without being required to undertake any formal additional education or training before injecting patients with neurotoxins like Botox’.

While many have become highly skilled at the practice, ‘there is concern clearer rules are needed to ensure those wanting to enter the industry have enough training’.

From September 2, nurses will be required to complete a set period of 12 months’ full-time practice before expanding their scope to include non-surgical cosmetic procedures. Specifically, the new rules ‘mandate further education and training before healthcare practitioners can perform cosmetic procedures like Botox and filler injections’.

Ahpra’s Untersteiner said not all cosmetic injectors would be happy with the tighter rules and he expected some would choose to leave the industry.

‘There will be others who have to modify their business models and modify their practices to meet these guidelines,’ he said. ‘This is a growing industry and, I’ve got to say, what we do see in some cases is that there are people out there putting profit before patient safety.’

While nurses and dentists have until September to prepare for the changes and ensure they are compliant with the new guidelines – which align with those already in place for doctors – Untersteiner told the ABC: ‘After that we will be identifying those that are doing the wrong thing and we will take action where we need to.’

Untersteiner emphasised the new rules are ‘really making it crystal clear’ about what the industry expects for cosmetic injectable procedures. ‘That will likely require specific training around facial anatomy or physiology. And I can tell you that is not a weekend course; this is proper training that will be required.’

He said the regulator had heard multiple cases of permanent irreversible facial nerve damage as well as potentially life-threatening strokes from cosmetic injectables.

‘What we’re talking about here is not just going in and having a facial. We’re talking about some kind of injection that goes underneath the skin and can create real harm,’ he said.

TGA seeks 12,000 social media fixes

The ABC also reported that the Therapeutic Goods Administration (TGA) – responsible for regulating advertising of prescription medications or related services including cosmetic injectables in Australia – had recently sent about 100 ‘targeted guidance letters’ to providers in the cosmetic injectables industry following the identification of alleged non- compliance with advertising regulations, and more would follow ‘in the coming weeks’.

The agency confirmed last financial year it submitted more than 12,000 requests for removal to social media platforms over the alleged unlawful advertising of therapeutic goods, including ‘over 2,500 advertisements relating to cosmetic injectable products’.

The new Ahpra guidelines noted concerns advertising was promoting the ‘trivialisation and glamourisation’ of cosmetic procedures to vulnerable patients, especially on social media. Examples of features more likely to be considered entertainment included imagery like music, dancing, singing or comedic comments.

End for speedy Botox scripts

Under the headline ‘Cosmetic crackdown: End looms for speedy Botox scripts, influencer freebies banned’, the Sydney Morning Herald and The Age reported ‘speedy telehealth consultations granting patients access to Botox, lip fillers and other beauty treatments will become ‘unviable’ under a crackdown on Australia’s booming cosmetic injectables industry’.

They noted Ahpra’s new guidelines also ban ‘cosmetic injectors from offering free or discounted cosmetic injectables to social media influencers, and will prevent nurses entering the lucrative sector straight out of university’.

The changes follow revelations in those newspapers in March that ‘some Australian doctors were using telehealth to spend as little as 52 seconds with patients before writing a script for cosmetic injectables such as Botox and fillers’.

They noted ‘speedy telehealth calls are the foundation of Australia’s $4 billion, fast-growing cosmetic injectables sector. Nurses in stores take customer details before doctors issue scripts for beauty treatments after consultations usually lasting less than a few minutes.

‘While the new guidelines stop short of specifying how long doctors and nurse practitioners must spend with patients when prescribing cosmetic injectables, they state practitioners must conduct detailed evaluations of patients, including an assessment to ensure expectations are realistic.’

‘The move follows concerns that some nurses, after undertaking publicly funded courses intended to tackle hospital and aged care workforce shortages, were immediately moving into the injectables field without acquiring the necessary complex anatomical knowledge,’ noted smh.com.au.

The new guidelines also bar artificial intelligence being used to ‘predict an individual’s appearance post-procedure or predict a person’s appearance without a procedure. The use of these tools in advertising can create unreasonable expectations of outcomes’.

Industry researchers Operation Redress have campaigned for tighter rules since 2020, and researcher Michael Fraser told theage.com.au the new guidelines made clear ‘the current advertising of cosmetic injectables has no place in Australia’s medical sector’.

Guidelines for practitioners who perform non-surgical cosmetic procedures

1. Recognising potential conflicts of interest

Registered health practitioners must recognise that conflicts of interest can arise when providing cosmetic procedures. This is particularly relevant given the commercial nature of the industry and the role that advertising and business models play in creating a demand for services. Practitioners must ensure that the care and wellbeing of the person they are providing cosmetic procedures to is their primary consideration.

2. Assessment of patient suitability

Registered health practitioners:

• must ensure all assessments are culturally safe;
• have a responsibility to ensure an evidence-based, holistic assessment of the person is undertaken; the assessment should consider the person’s history, relevant psychological, social and cultural aspects, and, in particular, assess for any condition, including underlying psychological conditions such as body dysmorphic disorder (BDD), which may make them an unsuitable candidate for the procedure;
• must ensure the person’s reasons and motivation for requesting the procedure are discussed, including external reasons (for example, a perceived need to please others) and internal reasons (for example, strong feelings about appearance); the person’s expectations of the procedure must be discussed to check they are realistic; the person should be assisted with decision- making based on an understanding of their personal motivation for the procedure and whether the procedure and outcome/s are likely to align with their expectations.
• if there are indications that the person has a significant underlying condition or psychological issue that may make them an unsuitable candidate for the cosmetic procedure, the practitioner performing the assessment or identifying the condition or psychological issue should ensure the person is referred to and seen by an appropriate registered health practitioner, who works independently of the practitioner intending to perform the cosmetic procedure or prescribe the cosmetic injectable, before commencing any procedure;
• must ensure other options are discussed with the person, including cosmetic procedures or treatments offered by other health practitioners and the option of not having the procedure;
• must decline to perform a cosmetic procedure or prescribe a cosmetic injectable if, following an assessment, they believe it is not appropriate for that person.

Only registered nurses or nurse practitioners can undertake the assessment outlined in this section.

3. Consultation with the person receiving a prescription for cosmetic injectables

Registered health practitioners must know and comply with relevant drugs and poisons legislation (or equivalent) of the jurisdiction in which they are practising in relation to repeat prescriptions.

In addition to the requirement to assess the person (section 2), registered health practitioners who are authorised to provide prescription-only cosmetic injectables must have either an in-person or video consultation with the person, each time they prescribe them a cosmetic injectable.

Asynchronous prescribing of cosmetic injectables by text, email or online (or equivalent) is not acceptable practice.

The provision of one prescription for multiple people (known as ‘bulk’ or ‘batch’ prescribing) is not acceptable practice. Every person must have an individual prescription.

4. Additional responsibilities if providing cosmetic procedures to persons under 18

Registered health practitioners:

• must know and comply with relevant legislation of the jurisdiction in which they are practising in relation to restrictions on non-surgical cosmetic procedures for persons under 18;
• must consider the appropriateness of any cosmetic procedure for a person who is under 18. National Boards consider botulinum toxin and dermal fillers should not be prescribed for cosmetic purposes for persons under the age of 18;
• have a responsibility to assess and be satisfied the person has the capacity to consent to the procedure;
• should, to the extent practicable, have regard for the views of a parent or guardian of the person under 18, including whether the parent or guardian supports the procedure being performed.

For persons under 18:

• there must be a cooling-off period of at least seven days between obtaining informed consent and the non-surgical cosmetic procedure being performed;
• no money should be payable until after the cooling-off period (other than for initial consultations);
• the person should be encouraged to discuss why they want to have the non-surgical cosmetic procedure with an appropriate independent registered health practitioner during the cooling-off period.

Only registered nurses or nurse practitioners can undertake the assessment outlined in this section.

5. Informed consent

Consent to the cosmetic procedure

• Registered health practitioners have a responsibility to ensure the person has been provided with enough information for them to make an informed decision about whether to have the procedure. There must be a verbal consent discussion with the person as well as written information provided in plain language. All practical steps must be taken to provide information in a language understood by the person. The information provided must not:

1. glamorise cosmetic procedures;
2. minimise the complexity of the cosmetic procedure;
3. overstate results or imply the person can achieve outcomes that are not realistic.

• In addition to any specific National Board guidance, information must include the risks and benefits associated with the cosmetic procedure and what alternatives may be available. This includes information about:

1. the cosmetic procedure, including: what the procedure involves (for example the type of anaesthesia and pain management if applicable); for cosmetic injectables, which cosmetic injectable is being prescribed or used (type and quantity); whether the procedure is new or experimental; the range of possible outcomes of the procedure, in the short and long term (for example the longevity of the treatment product and requirements to maintain the desired appearance); the risks specific to the person, including the possible impact of any comorbidities the person has; the possibility of the need for further treatment in the short term (such as treatment for anaphylaxis, hyaluronidase to dissolve dermal filler, oral or topical antibiotics) or the long term (such as surgical removal of dermal filler); recovery times and specific care requirements during the recovery period; alternative options to the cosmetic procedure such as topical products (over the counter face creams) and other non-invasive treatments;
2. the registered health practitioner providing the cosmetic procedure and the registered health practitioner prescribing the cosmetic injectable (where applicable) including: the practitioner’s registration; the practitioner’s qualifications, education, training and experience; information about other practitioners who will be involved in the cosmetic procedure (if applicable);
3. costs including: total cost; costs of maintenance requirements, including potential variability of future costs over time; details of deposits and payments required and payment dates; refund of deposits; costs/payments due for follow up care; possible further costs for revision or additional treatment; advising the person that cosmetic procedures are not covered by Medicare.

• A person’s consent to the cosmetic procedure and financial consent must be obtained and must be documented appropriately and a copy of the signed consent form must be given to the person.

Consent for use of images

• Consent must be requested for any photographs or videos (images) a registered health practitioner proposes to take of a person in a consultation or during a cosmetic procedure.The person must be given information about the proposed use of any such images, including:

1. their purpose (for example, for practice record only, for advertising); how they will be used (for example, stored in practice record, shown to other
2. people seeking cosmetic procedures in consultations, published on a website, posted on social media);
3. where they will be stored and who will have access.

• A person’s images must be stored on a secure device. Registered health practitioners must not
  store a person’s images on a personal device.
• The person must be given an opportunity to view images before consenting to their use in advertising. People have the right to refuse the use of their images, and the person cannot be required to agree to the use of their images in advertising.
• Consent for the use of images in advertising must be separate from consent to the cosmetic procedure.
• People must be allowed to withdraw their consent for the use of their images. People should be informed if removing their images from advertising may not be possible (for example, if images are used in material that has already been published, such as magazines).
• The registered health practitioner must promptly stop using the person’s images where possible (for example, not show them to other people seeking cosmetic procedures or delete them from advertising) if the person withdraws consent for the use of their image.
• A person’s consent for the taking, use and storage of images must be obtained, must be documented appropriately, and a copy of the signed consent form must be provided to the person.

6. Prescribing and administering Schedule 4 (prescription-only) cosmetic injectables

• Registered health practitioners must know and comply with the requirements of their state or territory drugs and poisons (or equivalent) legislation for Schedule 4 (prescription-only) cosmetic injectables. For example, requirements relating to permits, prescribing, records, supply, storage and transport.
• The Therapeutic Goods Administration (TGA) regulates therapeutic goods (for example, medicines and medical devices). Registered health practitioners must comply with TGA requirements when using and advertising therapeutic goods. Administering and/or advertising unapproved and/or unregistered products is unlawful, unless exempt under certain conditions, for example medicines that are dispensed or extemporaneously compounded by practitioners.

7. Management of the person receiving the cosmetic procedure

• The registered health practitioner who performs the cosmetic procedure is responsible for the management of the person, including ensuring the person receives safe, appropriate and responsive care during and after the procedure.
• If a cosmetic procedure involves administration of a prescription- only cosmetic injectable by a registered health practitioner who is not the authorised prescriber of the medicine, the authorised prescriber remains responsible for the management of the person, including ensuring the person receives appropriate post-procedure care. The registered health practitioner who administers the cosmetic injectable is responsible for informing the authorised prescriber of any concerns relating to the administration or post-procedure care.
• If the registered health practitioner who performed the cosmetic procedure or the authorised prescriber is not personally available to provide post-procedure care, they must have formal alternative arrangements in place for the post procedure care of the person by another suitably qualified and supervised (if required) registered health practitioner. These arrangements must be made in advance, documented and made known to the person receiving the cosmetic procedure and any other relevant treating practitioners.
• There must be protocols in place for managing complications and emergencies that may arise during the cosmetic procedure or in the immediate post-procedure phase. Registered health practitioners must be familiar with and follow protocols in place for managing complications and emergencies.
• In the event of complications requiring hospital admission, the registered health practitioner who performed the cosmetic procedure, or, if the procedure involved a cosmetic injectable, the registered health practitioner who prescribed the cosmetic injectable is responsible for coordinating the care of the person until the person is under the management of another nominated registered health practitioner or hospital.
• Written instructions must be given to the person after they have received the cosmetic procedure/s including:

1. contact details for the: registered health practitioner who prescribed the cosmetic injectable (where an injectable was part of the procedure); registered health practitioner who performed the cosmetic procedure; registered health practitioners responsible for coordinating their care (if this is not the practitioner who prescribed or performed the procedure); a nominated registered health practitioner in case the registered health practitioner who performed the procedure or prescribed the cosmetic injectable is not available;
2. details of the procedure(s) performed, and any anaesthesia used;
3. name and details of the product/s used;
4. the usual range of post-procedure symptoms;
5. instructions for the person if they experience unusual pain or symptoms (escalation points and who to contact and when);
6. instructions for medication, activity restrictions and self-care; and
7. dates and details of follow-up visits (if applicable).

• The health records kept of the procedure must comply with relevant National Board’s code of conduct and include details of the cosmetic procedure performed, described in enough detail to enable another registered health practitioner to take over post-procedure care with an adequate understanding of what has been done. All relevant health records need to be accessible and transferrable to another registered health practitioner.

8. Complaints

People who are dissatisfied have the right to make a complaint. Before the procedure, registered health practitioners must ensure all people receiving cosmetic procedures are provided with information about the range of complaints mechanisms available including:

1. raising and resolving the complaint directly with the practitioner who provided the procedure;
2. accessing the clinic or facility’s complaint process;
3. making a complaint to the health complaints entity in the state or territory where the procedure was performed;
4. making a complaint to Ahpra, the Health Care Complaints Commission, the health professional councils (in NSW) or the Office of the Health Ombudsman (in Queensland).

• Registered health practitioners must ensure any non-disclosure agreement (NDA) they use makes clear that a person, or a person on their behalf, can still make a complaint to Ahpra, the Health Care Complaints Commission, the health professional councils (in NSW) or the Office of the Health Ombudsman (in Queensland).

9. Education and experience

• Cosmetic procedures or cosmetic injectables must only be provided or prescribed by registered health practitioners who have appropriate education, knowledge, training, competence, authorisations (where required) and experience to safely perform the specific cosmetic procedure. This includes competence and experience not just to perform the cosmetic procedure and deal with all routine aspects of care but also the ability to deal with any likely complications.
• All registered health practitioners are responsible for ensuring they are sufficiently educated, trained and competent to safely undertake any cosmetic procedure they may perform. Registered health practitioners must ensure any education and training they undertake is sufficient to enable competent and safe performance of the cosmetic procedure and the subsequent care of the person after the procedure.

• National Boards consider adequate education and training to undertake a cosmetic procedure includes, at a minimum:

1. appropriate training in relevant anatomy and physiology;
2. training on the assessment for suitability for the procedure; and
3. both theoretical and hands-on training in the specific procedure being offered including assessment and demonstration of competence to safely perform the procedure, and care of the person (including side effects, and short and long term complications and their management).

• Registered health practitioners who are changing their scope of practice to include cosmetic procedures are expected to undertake any training necessary to ensure they have the appropriate knowledge and competence before providing cosmetic procedures or prescribing cosmetic injectables.
• All registered health practitioners must participate regularly in continuing professional development (CPD) that is relevant to their scope of practice. All registered health practitioners whose scope of practice includes cosmetic procedures, must undertake CPD that includes activities related to cosmetic procedures.

In addition, nurses should refer to Appendix A for specific requirements in relation to education and experience for their profession.

10. Qualifications and titles

• A registered health practitioner must not make claims about their qualifications, experience or expertise that could mislead people by implying the practitioner is more skilled or more experienced than is the case. To do so is a breach of the National Law (sections 117–119).
• Registered health practitioners must clearly inform people of their registration details, including their registration type, profession, and where relevant, division or endorsement on registration.
• Registered health practitioners must not use a protected title unless they hold the related registration type.

11. Advertising and marketing

• Advertising material, including practice and practitioner websites and social media, must comply with:

1. National Boards’ Guidelines for advertising of regulated health services;
2. National Boards’ Guidelines for advertising higher risk non-surgical cosmetic procedures;
3. the current Therapeutic Goods Advertising Code;
4. any TGA guidance on advertising non-surgical cosmetic procedures and the advertising requirements of section 133 of the National Law.

Advertising must not glamorise non-surgical cosmetic procedures, minimise the complexity of a procedure, overstate results or imply outcomes that are not realistic.

12. Infection prevention and control

• Infection prevention and control systems, appropriate to the level of risk involved in the procedure and the risk profile of the person must be in place. Infection prevention and control processes include (but are not limited to) standard precautions, hand hygiene and maintaining a clean and safe environment.

13. Facilities

• Registered health practitioners must know and comply with relevant legislation, regulations and standards of the jurisdiction in which they are practising (including local council, state, territory and Commonwealth requirements) for the facilities where the cosmetic procedure will be performed.
• Cosmetic procedures must be performed in a facility appropriate for the level of risk involved in the procedure and the risk profile of the person. Facilities must be appropriately staffed and equipped to manage possible complications and emergencies.
• Registered health practitioners who provide any non-surgical cosmetic procedures that include injecting, piercing the skin or incisions are encouraged to provide procedures in a facility
  that is accredited by an Australian Commission on Safety and Quality in Health Care (ACSQHC) approved agency to the current edition of the ACSQHC’s National Safety and Quality Primary and Community Healthcare Standards or the ACSQHC’s National Safety and Quality Health Service (NSQHS) Standards, whichever is the most applicable.

14. Financial arrangements

Registered health practitioners must not:

• provide or offer to provide, either directly or through a third party, financial inducements (such as a commission) to any person or company to recruit people to undertake cosmetic procedures; provide or offer to provide free or discounted procedures to prospective or existing patients, including social media influencers or users, for promotion of cosmetic procedures or services;
• offer, promote or recommend financing schemes, either directly or through a third party, such as loans or commercial payment plans, as part of the cosmetic procedure. This does not preclude a registered health practitioner from informing people of accepted payment methods such as credit cards or ‘buy now, pay later’ products (such as Afterpay or Zip Pay) or from offering the option to pay for a procedure in instalments in a non-commercial payment arrangement between the registered health practitioner and the person receiving the cosmetic procedure;
• offer people additional products or services that could act as an incentive to seek cosmetic procedures.

Registered health practitioners must:

1. disclose any financial interests that could be perceived as influencing the advice they provide to people about cosmetic procedures; and
2. ensure that any advice they provide to people about cosmetic procedures has the care and wellbeing of that person as the primary consideration and is not influenced by financial interests.