Two documents have now been published in advance of the 2 September 2025 commencement date:
- Guidelines for registered health practitioners who perform non-surgical cosmetic procedures and
- Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures
Together, these reforms are aimed at improving safety, oversight and accountability in the rapidly growing cosmetic procedures industry, and align other health professions with the rules already in place for medical practitioners.
A Shift in Regulatory Expectations
These guidelines follow a 2023 review prompted by widespread concerns about unsafe practices and poor oversight, particularly in non-surgical settings such as day spas, clinics and telehealth platforms. Over 360 notifications were made to Ahpra in relation to non-surgical cosmetic procedures between September 2022 and March 2025, many involving nurses, dentists, psychologists and other regulated practitioners.
The key changes are far-reaching and touch almost every aspect of cosmetic practice: patient screening, consent, advertising, prescribing, and the qualifications of those performing procedures.
Who Is Affected?
The guidelines apply to all registered health practitioners, excluding doctors (who are already subject to similar rules). This includes nurses, midwives, dentists, pharmacists, psychologists, and others who may seek to work in the cosmetic space.
While many practitioners are not currently involved in cosmetic work, the guidelines are designed to ‘futureproof’ regulation as the industry expands and more professionals seek to enter it.
Key Changes at a Glance
1. Tighter controls on prescribing
Cosmetic injectables such as botulinum toxin (e.g. Botox) and dermal fillers are Schedule 4 medicines. Under the guidelines, they can only be prescribed after a real-time consultation (either in person or via video). Prescriptions based on text, email or online questionnaires are not acceptable. Nor is “batch prescribing” for multiple patients.
2. Patient screening and assessment
Practitioners must assess each patient’s physical and psychological suitability for treatment. For nurses, only registered nurses (RNs) and nurse practitioners (NPs) can undertake this assessment. Screening must include consideration of conditions such as body dysmorphic disorder, with unsuitable patients referred appropriately.
3. Strengthened consent requirements
Both written and verbal informed consent must be obtained using plain language. Practitioners must explain the nature of the procedure, risks, benefits, alternatives, costs and their own qualifications. Under-18s will be subject to a mandatory seven-day cooling-off period, with payment deferred until after that period.
4. Training, qualifications and supervision
Practitioners must have procedure-specific training and undertake continuing professional development. Nurses will face additional restrictions:
- RNs must have at least 12 months’ experience in another clinical area before entering cosmetic practice.
- ENs may only perform certain procedures under direct supervision, will be prohibited from administering dermal filler injectables in very high-risk areas (such as the nose or glabella), and will only be able to administer dermal filler injectables to high-risk areas (including the temples and nasolabial folds) in a clinical setting where there is immediate onsite access to the prescriber of the cosmetic injectable and/or an RN
5. Advertising restrictions
New limits apply to all advertising of higher-risk cosmetic procedures (including injectables, thread lifts, PRP and hair transplants). Prohibited conduct includes:
- Use of testimonials
- Social media influencer promotions
- Financial inducements such as discounts or contra deals
- Marketing that trivialises procedures or exploits body image concerns, particularly among young or vulnerable patients
Advertising aimed at those under 18 will be banned, and practitioners will need to ensure that their marketing does not create unrealistic expectations.
6. Aftercare and complication management
Practices must have documented protocols for managing complications, and ensure continuity of care even if the original practitioner is unavailable. Patients must be given clear aftercare instructions and must be advised of their right to complain as well as the range of complaint mechanisms available to them prior to the procedure.
7. Financial practices
The guidelines prohibit offering discounts, financial incentives or package deals. Third-party payment plans or “buy now, pay later” arrangements may be used but must not be advertised as part of the procedure offer.
Implications for Clinics and Practitioners
These reforms represent a fundamental shift in how the cosmetic sector is regulated and will require real changes to clinic operations, training, policies and advertising.
Practitioners should begin reviewing their current cosmetic practices to ensure compliance with the new guidelines before they come into effect. Particular focus should be given to:
- Reviewing advertising and social media content
- Updating consent forms and patient screening processes
- Ensuring prescribers and proceduralists are appropriately trained
- Clarifying supervision arrangements and emergency protocols
The guidelines do not have the force of legislation, but they are binding in the sense that they set the expected professional standards. Failure to comply may result in regulatory action, including conditions on registration, suspension or disciplinary proceedings. In more serious cases, criminal or civil liability may also arise.
