Key takeaways:
- New guidelines are coming into effect on 2 September 2025 that will apply to registered health practitioners (other than medical practitioners) performing non-surgical cosmetic procedures.
- Practitioners must ensure “patient welfare over profits” and prioritise patients’ “interests, dignity, and privacy ahead of marketing or advertising opportunities”.
- Practitioners should:
- familiarise themselves with the new guidelines
- understand their obligations for advertising and performing non-surgical cosmetic procedures
- start revising their practice procedures and policies to ensure compliance by the date the new guidelines take effect, and
- seek guidance / advice to ensure compliance with the new guidelines.
Introduction
The Australian Health Regulation Practitioner Agency (Ahpra) and the National Boards[1] have issued new, guidelines (New Guidelines)[2] that will apply to registered health practitioners (Practitioners) performing non-surgical cosmetic procedures. They come into effect on 2 September 2025 and are designed to strengthen safeguards across the cosmetic industry.[3]
The New Guidelines include:
- Guidelines for registered health practitioners who perform non-surgical cosmetic procedures, and
- Guidelines for advertising higher risk non-surgical cosmetic procedures.
They follow extensive public consultation will replace the Nursing and Midwifery Board of Australia’s Position Statement.[4]
Who do the New Guidelines apply to?
The New Guidelines apply to all registered health practitioners under the National Law who perform non-surgical cosmetic procedures, except for medical practitioners.
Medical practitioners (ie doctors registered with the Medical Board of Australia) must instead comply with the Medical Board of Australia’s Guidelines for registered medical practitioners who perform cosmetic surgery and procedures.
What do the New Guidelines say?
Procedures regulated under the New Guidelines
Non-surgical procedures include prescription-only injectables such as 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.
Performing non-surgical procedures
1. Patient assessments: Practitioners have a responsibility to ensure that “an evidence-based, holistic assessment of the person is undertaken” prior to performing a non-surgical cosmetic procedure.
For nurses, the New Guidelines state that only registered nurses (RNs) or nurse practitioners (NPs) can undertake patient assessments.
The patient assessment process involves:
- identifying any underlying psychological conditions including body dysmorphia disorder, and
- understanding the patient’s motivations and expectations of the procedure.
Practitioners are expected to refer patients to an appropriate independent registered health practitioner if they identify or suspect an underlying psychological condition which makes the patient an unsuitable candidate for the procedure.
For patients under the age of 18 years, Practitioners must:
- consider the appropriateness of treatment (noting that Botox and dermal fillers are inappropriate for this age group)
- ensure the patient has the maturity and capacity to give informed consent
- consider the views of the underage patient’s parents or guardians
- comply with the mandatory cooling-off period of at least seven days between obtaining informed consent and the procedure being performed, and
- encourage the patient to discuss their reasons for treatment with an independent health practitioner.
2. Consultations: Practitioners authorised to prescribe cosmetic injectables must conduct a consultation with the patient, either in person or via video consultation, each time a cosmetic injectable is prescribed.
Prescribing must not be done asynchronously (e.g. by text, email, or online) or in batches (e.g. providing one prescription for multiple people), as such practices are not considered acceptable.
3. Informed consent: Practitioners must prioritise informed consent for all non-surgical procedures. This includes:
- giving clear, sufficient information in plain language, verbally and in writing, in a language the patient understands
- avoiding glamorisation, minimising risks or overstating results
- disclosing their own qualifications and those of any other involved practitioners, and
- clearly outlining all costs, including total fees, maintenance, deposits, payment terms and confirming no Medicare coverage.
4. Management following procedures: Practitioners must have clear protocols to ensure safe, appropriate and responsive after-care post-procedure. If the treating practitioner or prescriber is unavailable, formal alternative arrangements must be in place.
5. Education and Experience: Practitioners must have the necessary education, training, competence, authorisations and experience to safely perform the specific cosmetic procedure or cosmetic injectable and deal with any likely complications.
For nurses:
- RNs should have at least one year of full-time experience in a general or specialist nursing area before performing non-surgical cosmetic procedures
- enrolled nurses (ERs) must work under the supervision of an RN when performing non-surgical cosmetic procedures, and
- both RNs and ERs must ensure they are adequately skilled and knowledgeable for their role.
6. Financial arrangements: The relevant National Boards are closely scrutinising financial arrangements and have tightened guidelines to ensure “patient welfare before profit”.[5] The New Guidelines now prohibit:
- financially inducing patients directly or via third parties to undergo cosmetic procedures
- financially incentivising the promotion of cosmetic procedures in exchange for free or discounted procedures (which includes social media influencers or users), and
- offering, promoting, or recommending financial schemes such as loans or commercial payment plans.
Advertising high risk non-surgical procedures
The New Guidelines create transparency around the advertising of non-surgical cosmetic procedures, with specific regard to high risk non-surgical procedures. The New Guidelines apply to all persons advertising the particular procedure.
High risk non-surgical procedures include dental veneers, the administration of cosmetic injectables (as above), lipolysis, thread lifts, sclerotherapy and microsclerotherapy, procedures involving platelet rich plasma, biotherapy or injections of any product derived from the patient’s blood, and hair transplants.
The New Guidelines:
- encourage transparency regarding a practitioner’s qualifications, titles, education and experience
- prohibit the use of testimonials (including those from social media influencers) about treatment outcomes, practitioner performance or patient experiences (patients may still share personal reviews independently)
- prohibit the use of ‘before and after’ images of individuals under 18 years
- restrict digital enhancement of advertising visuals, and
- limit exposure of advertisements to minors and classifying high-risk procedure advertisements as adult content.
Practitioners must also ensure their conduct aligns with broader legal and professional standards. This includes compliance with the relevant National Board’s Code of Conduct, the Advertising Guidelines[6], the National Law, Australian Consumer Law, Therapeutic Goods Administration, and any other state or national laws.
Conclusion
As the implementation date of 2 September 2025 approaches, Practitioners should take proactive steps to ensure compliance with the New Guidelines. These guidelines reinforce the principle of “patient welfare over profits”, urging practitioners to prioritise patients’ interests, dignity, and privacy above marketing or promotional opportunities.
Practitioners should familiarise themselves with the new requirements, understand their advertising and procedural obligations, and begin revising internal policies and procedures accordingly. Seeking professional guidance or advice is recommended to ensure full compliance and uphold best practice standards across the cosmetic industry.
Further information
This case note was written by Principal Shannon Mony, Special Counsel Puja Menon and Solicitor Alexa da Paz. For further advice, please contact Shannon.
Disclaimer: This information is current as of August 2025. This article does not constitute legal advice and does not give rise to any solicitor/client relationship between Meridian Lawyers and the reader. Professional legal advice should be sought before acting or relying upon the content of this article.
[1] Except the Medical Board of Australia – see page 2 of Guidelines for registered health practitioners who perform non-surgical cosmetic procedures
[2] https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Information-for-the-public/Injectables.aspx
https://www.medicalboard.gov.au/sitecore/content/Home/News/2025-06-03-New-cosmetic-procedure-guidelines.aspx
[3] https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Information-for-the-public/Injectables.aspx
[4] https://www.nursingmidwiferyboard.gov.au/Codes-Guidelines-Statements/Position-Statements/nurses-and-cosmetic-procedures.aspx
[5] https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Information-for-the-public/Injectables.aspx#:~:text=Ahpra%20and%20National%20Boards%20are,airbrushed%20photos%20or%20misleading%20advertising
[6] https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Cosmetic-procedure-advertising-guidelines.aspx
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