Greg Williams
Partner •
Sydney
Navigating the 2025 AHPRA Guidelines on Cosmetic Procedures: Here's what you need to know
2 minutes
On 3 June 2025 the Australian Health Practitioner Regulation Agency (AHPRA) introduced two new sets of comprehensive guidelines aimed at enhancing the safety and regulation of non-surgical cosmetic procedures, with regard to both the performance and advertising of the procedures. The CEO of AHPRA described the new guidelines as being about "putting patients before profits".
The guidelines, which are set to take effect on 2 September 2025, impose new standards on any health practitioner who performs non-surgical cosmetic procedures. The changes also have ramifications for pharmaceutical and cosmetic manufacturers and suppliers.
What are the main changes?
Stricter advertising. The use of testimonials from influencers in advertising cosmetic procedures is now banned. In addition, advertising cosmetic procedures to individuals under 18 is prohibited. This means that advertising of higher-risk cosmetic procedures must be identified as 'adult content' on social media platforms. For those under the age of 18, the guidelines also introduce a mandatory seven day cooling off period between the first consultation and any procedures. We also discussed the TGA's advertising requirements in our recent article which you can read here.
Enhanced training and qualification requirements. All 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 nurses are now required to have a minimum of one year of full-time general nursing experience before performing cosmetic procedures. Additionally, they must complete specialised training in cosmetic practices. All practitioners must also engage in ongoing CPD training specific to cosmetic procedures.
Informed Consent. Practitioners are required to conduct thorough consultations, discussing risks, benefits and alternative treatments with patients. There must be a verbal consent discussion with the patient as well as written information provided in plain language. The information must not minimise the complexity of the cosmetic procedure or overstate or imply the person can achieve outcomes that are not realistic.
Prescribing and administering injectables. Registered health practitioners must have an in-person or video consultation with the patient each time they prescribe a cosmetic injectable. The guidelines also make clear that asynchronous prescribing of cosmetic injectables by text, email or online is not acceptable practice. There are also stricter requirements for the assessment of patient suitability. For instance, health practitioners must ensure a patient's reasons and motivations for requesting a procedure are discussed.
Process for complaints. Before a cosmetic procedure, registered health practitioners must ensure all patients are provided with information about the range of complaint mechanisms available, which includes making a complaint to AHPRA. The practitioner must also make clear the patient can still make a complaint to AHPRA, despite any NDA that is used.
Implications for manufacturers and suppliers
While the guidelines do not directly regulate manufacturers and suppliers, they affect the broader cosmetics injectables landscape. For instance, manufacturers and suppliers must ensure that all promotional materials provided to clinics and practitioners comply with the new advertising standards. In addition, given the emphasis on specialised training, there is an opportunity for manufacturers to develop and offer accredited training programs or resources that align with AHPRA's requirements, thereby supporting practitioners in meeting their obligations.
It is also important to recognise that liability for advertising can rest with more than one person. Individuals and corporate entities should consider their involvement with advertising to see if and what role they have played. Companies and individuals who provide and advertise high-risk cosmetic procedures should conduct an audit of their current and historic advertising practices and ensure it complies with the guidelines.
Get in touch
Stephanie Khan
Senior Associate •
Sydney
Alex Corsaro
Senior Associate •
Sydney
Disclaimer
Clayton Utz communications are intended to provide commentary and general information. They should not be relied upon as legal advice. Formal legal advice should be sought in particular transactions or on matters of interest arising from this communication. Persons listed may not be admitted in all States and Territories.