The Australian Health Practitioner Regulation Agency (AHPRA) and National Boards have released the Guidelines for registered health practitioners who perform non-surgical cosmetic procedures and Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures (the Guidelines). The Guidelines come into effect on 2 September 2025 and aim to bring all health practitioners in line with previous guidelines that apply to medical practitioners.
Guidelines for registered health practitioners who perform non-surgical cosmetic procedures
The Guidelines set out expectations for registered health practitioners (excluding medical practitioners) involved in non-surgical cosmetic procedures and replace the Nursing and Midwifery Board of Australia’s Position statement: Nurses and cosmetic medical procedures for nurses.
Non-surgical cosmetic procedures include cosmetic injections of botulinum toxin (Botox) and dermal fillers, fat dissolving injections, thread lifts, sclerotherapy and microsclerotherapy, CO2 laser skin resurfacing, cryolipolysis (fat freezing), laser hair removal, dermabrasion, chemical peels and hair transplants.
Patient assessment
Practitioners will need to conduct a thorough, evidence-based assessment of each patient and consider psychological, social and cultural factors, including psychological conditions such as body dysmorphic disorder (BDD). For nurses, only registered nurses (RNs) or nurse practitioners (NPs) may undertake this assessment.
Informed Consent
The Guidelines strengthen informed consent requirements - practitioners will have to provide both verbal and written information (in plain language) about the nature of the procedure, its risks, benefits, potential alternatives, the qualifications of the practitioner and costs associated with the procedure.
For patients under 18, a mandatory seven-day cooling-off period will be required between consent being provided and the procedure being carried out. Payment will not be able to be accepted until after the cooling off period (other than for the initial consultation).
Prescribing of cosmetic injectables
The Guidelines will also specifically impose strict requirements for the prescribing of prescription cosmetic injectables. Each prescription must be based on a real-time consultation (in person or by video) with the patient, and bulk or batch prescribing (where one prescription is prescribed for multiple people) is expressly prohibited. The Guidelines provide that asynchronous prescribing of cosmetic injectables by text, email or online questionnaires is not acceptable practice.
Practitioner Qualifications, Training, and Supervision
Practitioner qualifications and ongoing training are a key focus. Only those with appropriate, procedure-specific education, training and experience will be able to perform cosmetic procedures or prescribe prescription only medicines. Continuing professional development in activities related to cosmetic procedures will be mandatory for all registered health practitioners who perform cosmetic procedures.
The Guidelines also introduce detailed education and experience requirements for nurses. RNs must practise for a minimum of 1 year in an area other than non-surgical cosmetic procedures before expanding their scope of practice. Stringent supervision requirements are also imposed on enrolled nurses (ENs). For example, ENs will only be permitted to perform laser skin resurfacing under the direct supervision of an RN. ENs will not be permitted to administer dermal filler injectables to very high risk areas (such as the glabella, nose and forehead).
Management of complications and aftercare
The Guidelines require clinics to have clear protocols for managing complications and emergencies, and to ensure that patients receive appropriate aftercare. If the practitioner who performed the procedure or the authorised prescriber is unavailable, formal arrangements must be in place for another suitably qualified practitioner to provide post-procedure care.
Financial arrangements
Clinics must not provide or offer financial inducements to recruit people to undertake cosmetic procedures. Free or discounted procedures must also not be offered to patients, including by social media influencers, as part of the promotion of cosmetic procedures. Financing schemes, such as loans or commercial payment plans, must not be promoted as part of the cosmetic procedure (although this will not preclude the use of payment methods such as credit cards or ‘buy now, pay later’ products).
Guidelines for advertising higher risk non-surgical cosmetic procedures
The Guidelines impose restrictions on advertising higher risk cosmetic procedures and set out the types of advertising the National Boards consider will contravene the Health Practitioner Regulation National Law (the National Law).
Examples of higher risk cosmetic procedures include dental veneers, the administration of cosmetic injectables and dermal fillers, injection lipolysis, thread lifts, sclerotherapy and microsclerotherapy, procedures involving platelet rich plasma, biotherapy or injections of any products derived from the patient’s blood, and hair transplants.
Advertising restrictions
Under the Guidelines, advertising of cosmetic procedures by registered health practitioners will be subject to similar controls that were introduced for medical practitioners in 2023 under the Guidelines for registered medical practitioners who advertise cosmetic surgery. The most recent Guidelines reinforce the prohibition on testimonials under the National Law and provide guidance on features of advertising which are likely to trivialise higher risk cosmetic procedures.
The Guidelines also place a greater focus on ensuring that advertising does not exploit or target at risk groups, such as patient groups who are particularly vulnerable to body image pressures and negative body image perceptions.
Implications for businesses
Businesses operating cosmetic clinics should carefully consider their policies and procedures to ensure compliance with the Guidelines which will come into effect on 2 September 2025. The Guidelines will require additional training about patient assessments, consent, advertising, and aftercare. All advertising and marketing materials, including social media content, should also be reviewed. Non-compliance with the Guidelines may result in regulatory action by a National Board.
The Guidelines reflect a heightened regulatory focus on patient safety, transparency, and ethical conduct in the cosmetic industry. We expect the National Boards to monitor compliance with the Guidelines closely.
Our team has deep expertise in the regulation of the cosmetics industry, including advertising. If you have any questions about the Guidelines or regulation of the industry generally, please get in touch.
