The Australian Health Practitioner Regulation Agency (Ahpra) has released updated guidelines for registered health practitioners who perform non-surgical cosmetic procedures. These changes will come into effect in September 2025, and cover two key areas:
1. Advertising guidelines for higher-risk non-surgical cosmetic procedures
2. Clinical guidelines for performing non-surgical cosmetic procedures
The updated advertising standards clarify previously grey areas and bring existing obligations into sharper focus, helping practitioners to better meet their responsibilities. The good news for Fresh Clinics Members is that while the procedural guidelines have been updated, Fresh has long operated in line with these standards.
Whether you're a registered nurse, doctor, or other health professional offering cosmetic services, these updates apply to you. It’s essential to stay informed and ensure your practice remains compliant.
The below is a summary of the Clinical guidelines for performing non-surgical cosmetic procedures:
Purpose and scope
- These guidelines apply to non-medical registered health practitioners (e.g., nurses, dentists, pharmacists) who perform non-surgical cosmetic procedures.
- They aim to clarify professional responsibilities, ensure safe, ethical practice, and support informed patient decision-making.
- They do not expand the scope of practice or authorise practitioners to perform procedures outside their regulatory limits.
What counts as a non-surgical medical procedure
- Procedures that aim to change appearance (e.g., Botulinum toxin, dermal fillers, PRP, thread lifts, fat-dissolving injections, CO₂ laser resurfacing, and energy-based device treatments).
- They must not be confused with clinically justified treatments (e.g., removing skin cancers, treating severe acne).
Requirements and responsibilities
1. Scope of practice
Practitioners must only perform procedures they are qualified, trained, and competent to do and must comply with state/territory regulations, particularly for Schedule 4 medicines. Fresh Clinics offers state-of-the-art training to practitioners that supports a widening scope of practice for our Members.
2. Patient assessment
A holistic, culturally safe assessment is required, especially for psychological conditions (e.g., body dysmorphic disorder). If there are concerns, referral to an independent health practitioner like a GP or psychologist is required. Fresh Clinics' assessment process is ethical and thorough. Our hybrid model enables both in-person care and doctor support, plus a detailed assessment checklist to vet for BDD.
3. Under 18s
Fresh Clinics does not allow or support treatment for under-18s with S4 medications. According to Ahpra, procedures on minors are restricted and must have:
- A cooling-off period (7 days)
- Parental input & consent
- No upfront payment
4. Prescribing
Prescribing S4 medications must involve real-time (in-person or video) consultations — asynchronous prescribing is banned. No batch prescriptions are allowed; each person must have an individual prescription. Fresh Clinics handles and documents this safely within the Fresh App.
5. Informed Consent
Must include verbal and written plain-language consent from the patient. The practitioner must disclose:
- Procedure details, risks, alternatives
- Recovery expectations
- Provider credentials and fees
- Medicare does not cover cosmetic treatments
Separate, documented consent is required for any image use. These images must not be stored on personal devices. Patients can withdraw consent at any time, and practitioners must stop using images where possible. Fresh Clinics captures consent both physically in the Fresh App and verbally via telehealth.
6. Clinical care and aftercare
Practitioners must ensure continuity of care and have protocols for emergencies and complications, and must provide clear post-procedure instructions and contact details to patients. Fresh Clinics has strict and compliant aftercare, processes, and documentation. Learn more here.
7. Education and experience
Practitioners must complete:
- Relevant theoretical and hands-on training
- Ongoing CPD (Continuing Professional Development) in cosmetic procedures
- Must be competent in managing risks and complications, not just performing the procedure.
Fresh Clinics' training and education are CPD certified. We also regularly host free resources and webinars that offer CPD points to Members. Our complication management and training for complication management is the gold standard and the best in Australia.
8. Advertising and finance
Practitioners must follow:
Practitioners must not:
- Glamourise procedures
- Offer financial incentives, discounts, or influencer deals
- Promote finance schemes (e.g., loans, afterpay)
9. Facilities and infection control
Facilities must match the procedure risk level and be compliant with all legal and safety standards. Procedures involving injections or piercing skin should ideally occur in an accredited facility. Fresh Clinics supports Members through strict compliance checks and protocols.
10. Complaints handling
Patients must be informed of how to lodge complaints (e.g., Ahpra, health complaints bodies), and NDAs must not prevent complaints to regulators.
Specific Guidance for Nurses and Midwives (Appendix A)
- Midwives cannot perform cosmetic procedures.
- RNs: Must have 1 year of full-time postgraduate experience in General or specialist nursing practice (excluding non-surgical cosmetic injectables) before entering cosmetics; endorsement as NP not possible solely in cosmetics. Fresh Clinics has always had this requirement in place for our Members.
- ENs:
- Must work under RN supervision
- Need experience in a related area (e.g., dermatology)
- Cannot inject in high-risk facial areas unless under strict conditions
The below is a summary of the Advertising guidelines for higher-risk non-surgical cosmetic procedures:
Purpose and scope
- Developed by National Boards to ensure safe, honest, and responsible advertising of higher-risk non-surgical cosmetic procedures.
- Applies to registered health practitioners, non-registered individuals, and businesses that advertise these procedures.
- Focuses on protecting vulnerable consumers, given the serious and potentially irreversible risks involved in these procedures.
What counts as a higher-risk non-surgical medical procedure
Botulinum toxin, dermal fillers, PRP, thread lifts, fat-dissolving injections, and Sclerotherapy.
Advertising requirements
1. Practitioner responsibility
Advertising must not exploit insecurities or target psychologically vulnerable individuals (e.g., with body dysmorphic disorder). Practitioners must prioritise the duty of care over financial gain. Cost info must be clear and comply with TGA regulations.
2. Claims & titles
Advertising must not exaggerate qualifications or imply specialist status without appropriate registration, and registration details must be clearly displayed.
3. Testimonials
Strictly prohibited. This includes:
- Patient stories or outcomes
- Likes, reposts, or links to patient reviews
- Social media ‘stories’ with testimonials
- Practitioners must not interact with third-party testimonials
4. Influencers & ambassadors
Advertisers are responsible for content shared by influencers on their behalf, and influencers must not use testimonials or misleading claims.
5. Use of Images
No misleading, retouched, or filtered images. Before and after images must be:
- Genuine, unedited, and comparable in conditions
- Accompanied by disclaimers on the variability of results
- Not used on individuals under 18
- No sexualised, entertainment-focused, or lifestyle imagery
6. Risk & recovery
Risks must be clearly stated, not downplayed (e.g., avoid terms like “simple” or “painless”). Recovery timelines and possible lifestyle impacts must be disclosed. Procedures must not be trivialised (e.g., competitions or giveaways).
7. Body image & mental health
Advertising must not:
- Imply normal ageing or variations need fixing
- Promise improved mental health or self-esteem
- Promote unrealistic or idealised beauty standards
8. Expectations of outcomes
Claims must be objective and evidence-based. Practitioners must be clear about:
- When results will appear
- How long they will last
- Need for ongoing treatments
9. Protecting at-risk audiences
No advertising to under-18s or on youth-oriented platforms. Avoid targeting vulnerable groups through metadata, hashtags, or excessive posting.
Actionable steps you can take now:
1. Set aside dedicated time
This is not a document to skim. Block out time in your calendar to read the full guidelines without interruption. You may need to revisit it multiple times.
2. Go analogue
Print the documents or have a notebook ready. Highlight important sections and jot down notes or questions as you go. This helps you retain the content and identify what specifically applies to your clinic.
3. Audit your own platforms
Set time aside to review your social media, website, and marketing materials. We recommend doing this yourself. While some AI-driven tools or services are available, we’ve found they often miss important context or aren’t fully aligned with Australian regulations and complexities between TGA and Ahpra.
4. Budget for updates
You may need a refreshed brand photoshoot (avoiding needles or identifiable patient info), new graphic assets, or website changes. Factor this into your business plan now, and make sure any agencies or freelancers you work with are across the new rules.
5. Adjust your IG settings
Update your Instagram business profile to restrict your content to 18+ only. This is a simple step toward compliance that many overlook.
6. Focus on the law, not the norm
Don’t rely on what others in the industry are doing. Knowing and applying the actual regulations, not what appears to be common practice, is key to protecting your reputation and remaining compliant.
8. When in doubt, seek legal advice
If you’re engaging external marketers or influencers, or if you have questions around compliance for your unique business model, a qualified legal advisor can help clarify your responsibilities.
About Ahpra
The Australian Health Practitioner Regulation Agency (Ahpra) is the national body responsible for regulating health professionals across Australia. Ahpra sets the standards that ensure public safety and maintain professional conduct across 16 health professions.