Key Takeaways
- AHPRA's guidelines for performing and advertising non-surgical cosmetic procedures took effect on 2 September 2025. They apply to all registered health practitioners who perform these procedures, including nurse practitioners, registered nurses, enrolled nurses, medical practitioners, dental practitioners, podiatrists and Chinese medicine practitioners.
- Registered nurses must now have at least 12 months of full-time-equivalent general nursing experience before performing cosmetic injectables, and must hold the specific education, training and competence for the procedure.
- A real-time consultation, in person or by video, is required each time before a cosmetic injectable is prescribed. Prescribing asynchronously by text, email or an online questionnaire is no longer acceptable practice.
- Patients under 18 require a mandatory 7-day cooling-off period and additional safeguards (including screening for underlying concerns), and targeted advertising of cosmetic procedures to under-18s is banned.
- Advertising prescription-only injectables to the public is unlawful under the Therapeutic Goods Act. You cannot use brand names (such as Botox or Juvederm), category names ("anti-wrinkle injections", "dermal fillers"), nicknames ("tox", "baby botox"), related hashtags, or any price, discount or package offer.
- The prohibition on testimonials in advertising a regulated health service is reinforced, and it expressly captures social-media influencer testimonials, whether paid or gifted.
- Penalties are real: recent TGA infringement notices against a body corporate have totalled $106,560, and AHPRA can impose conditions on registration, issue cautions, or take disciplinary action against the practitioner.
AHPRA's cosmetic procedure and advertising guidelines commenced on 2 September 2025 and now govern every clinic offering injectables. The headline changes a practice manager must action are a 12-month general-experience minimum for nurses, a mandatory real-time consultation before any cosmetic prescription, strict new rules for under-18 patients, and an advertising regime where naming the medicine, showing a price, or running an influencer testimonial is a breach.
What changed under AHPRA's September 2025 cosmetic guidelines?
On 2 September 2025, AHPRA and the National Boards introduced two linked instruments: guidelines for registered health practitioners who perform non-surgical cosmetic procedures, and guidelines for advertising higher-risk non-surgical cosmetic procedures. Together they extend to nurses, dental practitioners and others the kind of safeguards the Medical Board first applied to cosmetic surgery in 2023, and they replace the Nursing and Midwifery Board's earlier position statement on nurses and cosmetic procedures.
The reform was framed by AHPRA as putting a "booming billion-dollar cosmetic industry on notice". For a clinic, the practical effect is that performing injectables and advertising them are now both regulated activities with explicit rules, and the regulator has signalled active enforcement rather than education-only grace. If your practice offers cosmetic injectables, the guidelines are not optional reading; non-compliance is a registration and a therapeutic-goods risk at the same time.
Can registered nurses perform cosmetic injectables, and what experience is required?
Yes, registered nurses can perform cosmetic injectables, but the guidelines set a clear gate. A registered nurse must have at least 12 months of full-time-equivalent general nursing experience before moving into cosmetic injecting, and must additionally hold the education, training and demonstrated competence for the specific procedure they perform. The intent is to stop newly registered nurses going straight from graduation into an injecting role without a foundation of general practice behind them.
The guidelines apply across the registered professions, so the same "qualified, trained and competent" test governs nurse practitioners, enrolled nurses (within their scope and supervision requirements), medical practitioners and the other groups named above. For a clinic, the compliance action is concrete: confirm each injector meets the experience threshold, hold evidence of their cosmetic-specific training, and do not roster anyone to inject who cannot demonstrate both. The Nursing and Midwifery Board position statement is the reference point for the nursing professions.
Do I need a consultation before prescribing cosmetic injectables?
Yes. The guidelines require a real-time consultation, conducted either in person or by video, every time a cosmetic injectable is prescribed. Prescribing a Schedule 4 cosmetic medicine on the basis of a text message, an email, or an online intake form alone is expressly not acceptable practice. This closes the "script first, assess later" model that some high-volume operators ran, where a prescriber signed off remotely on patients they never spoke to.
This sits alongside the broader scrutiny of asynchronous and online prescribing across Australian healthcare. The same direction of travel applies to telehealth prescribing generally; our AHPRA telehealth and online prescribing guide covers where questionnaire-only models fail the standard. For a cosmetic clinic, the workflow fix is to build the prescribing consultation into the booking so that a prescriber (in person or by video) assesses the patient before any injectable is supplied, and to record that consultation in the clinical notes.
How must clinics handle patients under 18?
Minors carry the strictest safeguards. For a patient under 18, the guidelines require a mandatory cooling-off period of at least 7 days between the consultation and the procedure, and a more involved assessment that screens for underlying concerns such as body image disorders, with referral where appropriate. Cosmetic procedures on minors should be the exception, approached with caution, and never driven by demand alone.
The advertising rules reinforce this: it is prohibited to target advertising of cosmetic procedures at people under 18. In practice that means reviewing where and how you advertise (platform choice, audience targeting, imagery and language that appeals to minors) and removing anything that markets injectables to a teenage audience. Adults also benefit from cooling-off and informed-consent requirements, but the under-18 settings are the bright line a clinic must not cross.
What can and cannot I say when advertising injectables?
This is where most clinics are exposed, because cosmetic injectables are prescription-only (Schedule 4) medicines, and advertising prescription-only medicines to the public is unlawful under the Therapeutic Goods Act 1989, separately from the AHPRA guidelines. The TGA's guidance on referring to cosmetic injectables in advertising and its advertising health services and cosmetic injections FAQ set out what is and is not allowed.
| Advertising element | Prohibited | Compliant approach |
|---|---|---|
| Naming the medicine | Brand names (Botox, Juvederm, Dysport), the active ingredient | Do not name or imply a specific prescription-only injectable |
| Category and nicknames | "anti-wrinkle injections", "dermal fillers", "tox", "baby botox", "lip flick", and hashtags of these | Describe the service in general, non-product terms only |
| Price and offers | Listed prices, "from $X", discounts, specials, package or bundle deals on injectables | No price or incentive advertising for prescription-only injectables |
| Testimonials | Patient or social-media influencer testimonials about the service (paid or gifted) | Factual information about the service and the practitioner only |
| Before and after images | Misleading or unqualified before/after imagery | Tightly restricted; generally avoid for injectables |
| Audience | Any targeting of people under 18 | Exclude minors from audience targeting and platforms |
The testimonial point catches many clinics off guard. Testimonials about a regulated health service are already banned under section 133 of the National Law, and the cosmetic advertising guidelines make explicit that this includes social-media influencers, whether the clinic paid them or simply gifted treatment. Reposting an influencer's review of your injectables is a breach.
What are the penalties for non-compliant cosmetic advertising in 2026?
Two regulators can act, which is what makes cosmetic advertising higher-stakes than ordinary practice marketing. The TGA enforces the prescription-medicine advertising prohibition and can issue infringement notices, accept enforceable undertakings, or take court action; recent TGA infringement notices against a body corporate have totalled $106,560, and the TGA has an active enforcement program around cosmetic injectables. Separately, AHPRA can investigate the practitioner and impose conditions on registration, issue a caution, or pursue disciplinary action through a tribunal.
For a clinic, the compounding risk is the point: a single non-compliant social-media post can expose the business to a TGA advertising penalty and the responsible practitioner to an AHPRA registration outcome at the same time. The cost of compliance (rewriting your website and socials, fixing your prescribing workflow, checking injector credentials) is trivial next to a contested infringement notice or a registration condition that limits who can inject.
What clinics should fix now
Treat this as a short remediation project with an owner and a deadline. The priorities:
- Audit your advertising. Sweep your website, Instagram, TikTok, Facebook and Google listings for medicine names, nicknames, prices, before/after images, and influencer content, and remove them. Brief whoever runs your social media, because most breaches are posted by marketing staff, not clinicians.
- Fix the prescribing workflow. Make a real-time (in person or video) consultation a mandatory step before any injectable is prescribed, and record it. Retire any questionnaire-only or remote sign-off process.
- Verify your injectors. Confirm each nurse meets the 12-month general-experience threshold and holds cosmetic-specific training, and keep the evidence. (Our guide to verifying and tracking AHPRA registration covers how to keep this current.)
- Set under-18 safeguards. Build the 7-day cooling-off and the enhanced assessment into your booking process for any patient under 18, and exclude minors from your advertising.
- Know your notification duties. If you become aware that another practitioner is injecting outside the guidelines in a way that places patients at risk, consider whether the mandatory notification threshold is met.
Frequently Asked Questions
What changed under the September 2025 AHPRA cosmetic guidelines?
From 2 September 2025, AHPRA's guidelines for performing and advertising non-surgical cosmetic procedures apply to all registered health practitioners who perform them. The main changes are a 12-month general-experience minimum for nurses before injecting, a mandatory real-time consultation before prescribing, stricter rules for patients under 18, and tighter advertising restrictions that reinforce the ban on testimonials and influencer content.
Can registered nurses perform cosmetic injectables and what experience is required?
Yes, but a registered nurse must have at least 12 months of full-time-equivalent general nursing experience before performing cosmetic injectables, and must hold the specific education, training and competence for the procedure. Clinics should confirm each injector meets the threshold and keep evidence of their cosmetic-specific training before rostering them to inject.
Is it legal to advertise cosmetic injectables on social media?
You can advertise a cosmetic service in general terms, but you cannot advertise the prescription-only medicine itself. Naming brands like Botox, using nicknames such as "tox" or "baby botox", category terms like "anti-wrinkle injections", related hashtags, or any price or discount is unlawful under the Therapeutic Goods Act, on social media as anywhere else.
Are influencer testimonials and before-and-after photos allowed?
Testimonials about a regulated health service are prohibited under the National Law, and the cosmetic advertising guidelines make clear this includes social-media influencers, whether paid or gifted. Before-and-after images are tightly restricted and are generally non-compliant for injectables because they tend to mislead, so most clinics should avoid them.
What are the penalties for non-compliant cosmetic advertising in 2026?
The TGA can issue infringement notices (recent corporate cases have totalled $106,560), accept enforceable undertakings, or take court action for unlawful advertising of prescription-only injectables. Separately, AHPRA can investigate the practitioner and impose conditions on registration, a caution, or disciplinary action, so a single breach can trigger action from both regulators at once.