Cosmetic Injectable Guideline Updates: What You Need To Know

In Short

• AHPRA’s new guidelines take effect on 2 September 2025, requiring comprehensive patient assessments, mandatory cooling-off periods for patients under 18, and at least one year of general clinical experience for practitioners.
• Advertising restrictions prohibit sexualised images, AI-generated before-and-after photos, guaranteed outcome claims, influencer testimonials, and promotional discounts.
• Clinic owners, prescribing practitioners, and treating practitioners share responsibility for compliance, with non-compliance potentially resulting in fines, registration conditions, or business closure.

Tips for Businesses

Review and update clinic policies before 2 September 2025. Audit advertising materials to remove prohibited content. Implement patient assessment checklists and consent processes. Verify nursing staff have completed required clinical experience. Establish cooling-off period documentation systems. Provide staff training on updated requirements and shared responsibility framework.

Summary

This article explains AHPRA’s new guidelines for non-surgical cosmetic procedures for health practitioners and clinic operators in Australia. LegalVision, a commercial law firm specialising in advising clients on healthcare regulation, outlines the key requirements taking effect from 2 September 2025.

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Table of Contents

• New Guidelines
• 1. Comprehensive Patient Assessments
• 2. Advertising
• 3. Ban on Fast-Tracked Entry into the Industry
• 4. Mandatory Cooling-Off Periods
• 5. Shared Responsibility
• Regulatory Requirements under TGA
• Key Takeaways
• Frequently Asked Questions

The cosmetic injectables industry in Australia has grown significantly over the past decade, becoming a multi-billion-dollar sector. Procedures such as Botox, dermal fillers, and lip enhancements have become increasingly common. Alongside this growth, concerns have emerged regarding patient safety, practitioner qualifications, informed consent, and the ethical marketing of aesthetic procedures. This article outlines AHPRA’s new cosmetic injectables guidelines, effective 2 September 2025, covering assessments, advertising and compliance.

New Guidelines

To address these concerns, the Australian Health Practitioner Regulation Agency (AHPRA) has released new guidelines focused on improving the safety and regulation of non-surgical cosmetic procedures. These guidelines will come into effect on 2 September 2025 and will apply to all registered health practitioners under the National Law, excluding medical practitioners who are regulated under a separate framework.

The updated guidelines replace the Nursing and Midwifery Board of Australia’s Position Statement: Nurses and Cosmetic Medical Procedures. They outline clear expectations relating to practitioner qualifications, advertising standards, patient assessments, and clinical oversight.

1. Comprehensive Patient Assessments

Before administering any cosmetic injectable treatment, practitioners must conduct a full face-to-face or telehealth consultation (that complies with legal standards). This consultation must include:

• a review of the patient’s medical history and a physical assessment;
• a discussion of alternative treatment options, including no treatment;
• an evaluation of whether the patient’s expectations are realistic; and
• completion of an informed consent process using a structured checklist.

This requirement intends to support consistency in patient care and help reduce risks associated with inadequate pre-treatment screening.

2. Advertising

The guidelines introduce stricter controls on the advertising of non-surgical cosmetic procedures by registered health practitioners. These measures align with restrictions introduced for medical practitioners in 2023.

Under the updated regulations, practitioners and clinics must not:

• use sexualised images or lifestyle-focused visuals (e.g., beach settings);
• include AI-generated “before and after” images or predictive imagery;
• use language suggesting outcomes are guaranteed, perfect, or risk-free (e.g., “flawless,” “balanced face”); and
• employ influencer testimonials or promotional discounts.

These rules aim to ensure advertising is factual, balanced, and does not exploit consumer insecurities. Content should not imply that cosmetic procedures are essential to achieve social, professional, or personal success.

3. Ban on Fast-Tracked Entry into the Industry

The guidelines introduce a minimum experience requirement for nurses entering the cosmetic sector. Nurses must now complete at least one year of full-time experience in a general clinical setting such as a hospital, aged care facility, or community health service before performing cosmetic procedures.

This experience provides a foundational understanding of clinical decision making, risk management, patient care, and professional accountability.

Clinic owners and hiring managers will be responsible for making sure that new staff meet this requirement and are appropriately qualified and supervised.

4. Mandatory Cooling-Off Periods

For patients under the age of 18, a mandatory seven-day cooling-off period will apply following their initial consultation.

This period allows time for further consideration before proceeding with any non-surgical cosmetic treatment. It also provides healthcare professionals with an opportunity to reassess suitability, consent, and motivation for seeking treatment. You must document the cooling off period.

5. Shared Responsibility

The guidelines make clear that multiple roles within a cosmetic clinic actively share responsibility for patient safety. This includes:

• the practitioner administering the treatment;
• the prescribing practitioner (e.g., a doctor or nurse practitioner); and
• the clinic owner or franchise operator.

All parties involved must ensure they perform procedures safely and in accordance with the outlined regulatory requirements. This includes maintaining proper oversight, keeping accurate patient records, and implementing appropriate staff training and audit processes.

Regulatory Requirements under TGA

Most cosmetic injectables contain substances that are in Schedule 4 to the Poisons Standard. Under the Therapeutic Goods Act 1989 (TGA), the Act classifies these substances as prescription-only medicines and prohibits advertising them to the general public.

TGA no longer expressly permits references to terms such as ‘wrinkle reducing injections’ or ‘dermal fillers’ where those terms would result in a reasonable consumer understanding that the intention of the content is to promote the use or supply of a prescription-only medicine or a product containing such a substance. This includes through acronyms, nicknames, abbreviations and hashtags, which a consumer may take as a reference to a specific prescription-only medicine or substance.

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Key Takeaways

AHPRA’s new guidelines for non-surgical cosmetic procedures will come into effect on 2 September 2025. They address key regulatory areas such as comprehensive patient assessments, advertising standards, practitioner qualifications, and accountability within clinical teams.

These measures improve safety, transparency, and consistency across the cosmetic injectables industry. We advise health practitioners and clinic operators to review their existing systems, update internal procedures, and ensure full compliance with the updated standards before the effective date. Clinic operators may need to undertake additional planning, staff training, and documentation updates to align clinic operations with these new legal and professional expectations.

This approach ensures that all forms of public advertising – whether explicit or implied – comply with the regulatory framework designed to restrict promotion of prescription-only cosmetic injectables.

LegalVision provides ongoing legal support for all businesses through our fixed-fee legal membership. Our experienced lawyers help businesses manage contracts, employment law, disputes, intellectual property and more, with unlimited access to specialist lawyers for a fixed monthly fee. To learn more about LegalVision’s legal membership, call 1300 544 755 or visit our membership page.

Frequently Asked Questions