Non-surgical cosmetic procedure guidelines take effect

From 2 September 2025 new Ahpra rules cover advertising and performing injectables, fillers, laser and other non-surgical cosmetic procedures.

2 September 202512 min read

From 2 September 2025, two new sets of Ahpra and National Board guidelines apply to non-surgical cosmetic procedures: the Guidelines for practitioners who perform non-surgical cosmetic procedures, and the Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures. They were published on 3 June 2025, giving the sector three months to prepare.

If you market injectables, dermal fillers, thread lifts, laser and energy treatments, PRP, hair transplants or dental veneers, the advertising guidelines change what you can post, who must be named and how images are used. They apply to businesses and non-practitioners as well as registered practitioners. The practice guidelines add rules on finance, discounts, influencer deals and prescribing that shape your offers and booking flows.

What changed

Ahpra and the National Boards released both documents on 3 June 2025, and Ahpra confirmed they took effect on 2 September 2025. They follow a public consultation that ran from 27 November 2023 to 2 February 2024, and they build on the safeguards the Medical Board introduced for doctors in 2023. The practice guidelines also replace the Nursing and Midwifery Board’s position statement on nurses and cosmetic medical procedures.

Ahpra’s stated aims were to align standards across professions and prepare for professions that may enter the cosmetic market later. It reported investigating about 360 notifications about non-surgical cosmetic procedures between September 2022 and March 2025, involving medical practitioners, nurses, midwives, dentists, psychologists and Chinese medicine practitioners. Ahpra’s CEO, Justin Untersteiner, said on 2 September 2025: “If we find practitioners prioritising profits over patient care, we will not hesitate to act.”

Who it applies to

The advertising guidelines

These apply to anyone who advertises higher risk non-surgical cosmetic procedures performed by registered practitioners. That includes registered practitioners of every profession (doctors included), non-registered individuals, and businesses, partnerships and corporate entities. A clinic company, a non-practitioner owner, a marketing agency and an influencer can all be within scope.

Higher risk non-surgical cosmetic procedures are non-surgical procedures to change appearance that usually need a registered practitioner. Ahpra lists examples including cosmetic injectables such as botulinum toxin and dermal fillers, injection lipolysis, thread lifts, sclerotherapy, platelet-rich plasma procedures, hair transplants, dental veneers, and procedures that penetrate the dermis using chemicals, light, laser, heat or cold. Botulinum toxin used for medical conditions is excluded.

The practice guidelines

These apply to registered practitioners who perform non-surgical cosmetic procedures, except medical practitioners, who continue to follow the Medical Board’s 2023 guidelines. In practice that means nurses (registered nurses, enrolled nurses and nurse practitioners), dentists, pharmacists and any other registered practitioner working in this area. The guidelines do not, by themselves, authorise any practitioner to perform these procedures.

What the advertising guidelines require

Practitioner responsibility and costs

Advertising must not exploit people’s vulnerabilities or insecurities, and must not target people with conditions such as body dysmorphic disorder. Cost and health insurance information must be clear, easily understood, accurate and honest. Price lists for procedures involving therapeutic goods or prescription-only medicines must follow TGA requirements (section 1.5).

Name the practitioner and show registration details

When a named individual is advertised, include their registration number and registration type (section 2.9). The guidelines give the example “Dr G (DEN000456789) Registered dentist, general registration”. Only registered practitioners may use protected titles, and you must not imply specialist status, for example by saying a practitioner “specialises”, without specialist registration. Acronyms must not be used alone, and taglines and hashtags must not mislead. Terms such as “doll-maker”, “magic hands”, “sculptor”, “artist” and “world renowned” are listed as examples to avoid.

No testimonials, including through influencers

Testimonials must not be used (section 3.1). Positive statements about the experience, reason for or outcome of a procedure, and linked outcome images, count. Temporary content such as stories counts. Re-sharing patient posts, liking or responding to reviews and linking to third-party testimonials all count as use. Disable reviews, comments or tagging where possible. Patients can still post reviews independently.

If you engage influencers or ambassadors, you are responsible for their content, and it must follow the guidelines, including the testimonial ban (section 4.2). Where therapeutic goods are involved, TGA rules on testimonials and endorsements also apply (section 4.3).

Images and before-and-after photos

No airbrushed, soft-filtered or otherwise modified images, and no celebrities or models unless they had the procedure (section 5.2).
Outcome images need a prominent warning that the outcomes shown are only relevant for that patient (section 5.3).
Before-and-after images must be genuine patients of that practitioner, with the “before” or a composite shown first, matching lighting, angle, background, posture, makeup and clothing, no filters, retouching or greyscaling, and the “after” image must state how long after the procedure it was taken (section 5.4).
Images of people under 18 must not be used (section 5.6).
Avoid music, dancing, singing, comedic commentary and non-informational montages (section 5.7).
No sexualised poses, lingerie, simulated undressing or gratuitous nudity, no emojis showing emotional reactions, no beach, poolside or bedroom lifestyle shots, and no captions such as “more natural”, “ideal”, “perfect” or “instant” (section 5.8).

Consent to use images in advertising must be separate from consent to the procedure (section 5.9). Patients must be told where and for how long images will be used and who may access them, be able to view them first, know they can refuse, and be able to withdraw consent at any time, with images removed promptly where possible.

Risk, recovery and trivialising

Give accurate, realistic risk information, and make full risk information easy to find, with social media posts linking to it. Minimising terms such as “safe” or “easy” should not be used without clear information about risks, and procedures must not be described as “painless”. Explain recovery time, aftercare and lifestyle changes. Procedures must not be offered as competition prizes, and you must not trivialise them through emojis, idealising terms such as “barbie” or “perfect”, or “guess the procedure” and voting contests (section 6).

Body image and realistic expectations

Do not suggest procedures are the only option for someone unhappy with their appearance. Do not use automated apps or tools that predict a person’s appearance after a procedure (section 7.2). Avoid promoting unrealistic “youthful”, “ideal” or “flawless” bodies, and phrases like “best version of yourself”. Claims about outcomes must be objective, demonstrable or provable, must make clear that results vary, and must not mislead about how quickly effects appear, how long they last or how often procedures may need repeating. Claims such as “boost confidence” need acceptable evidence (section 8).

Under-18s and vulnerable groups

Advertising must not target people under 18 and must avoid media with a significant under-18 audience. Social media advertising must be identified as “adult content”. Do not use algorithms, hashtags or metadata to reach at-risk groups, and consider posting frequency, since excessive posting may contribute to body image dissatisfaction (section 9).

What the practice guidelines require

The performing guidelines are mostly clinical, but these parts affect your marketing directly:

Training: procedures may only be provided by practitioners with appropriate training and competence, including in managing likely complications. Registered nurses must first practise for at least one year full-time equivalent after initial registration before performing these procedures.
Prescribing: prescribers must have an in-person or video consultation each time they prescribe a cosmetic injectable. Asynchronous prescribing by text, email or online form “is not acceptable practice”, and neither is bulk or batch prescribing.
Assessment: practitioners must consider underlying conditions, including body dysmorphic disorder, and decline procedures that are not appropriate.
Under-18s: botulinum toxin and dermal fillers should not be prescribed for cosmetic purposes for under-18s. Where a procedure for an under-18 does go ahead, there must be a cooling-off period of at least seven days, and no money is payable until it ends, apart from initial consultations.
Financial arrangements (section 14): no financial inducements such as commissions to recruit people; no free or discounted procedures for prospective or existing patients, including influencers, in exchange for promotion; no offering, promoting or recommending financing schemes such as loans or commercial payment plans; no additional products or services as an incentive to seek procedures; and disclosure of financial interests that could influence advice. Credit cards, buy now pay later products and non-commercial instalment arrangements may still be accepted.
Advertising: must comply with the National Boards’ advertising guidelines, the Therapeutic Goods Advertising Code and TGA guidance (section 11.1).

What it means for your marketing

Website

Add each practitioner’s name, registration type and registration number wherever they are advertised.
Rebuild before-and-after galleries: “before” first, matching conditions, time elapsed on the “after” image, prominent warning, consent on file.
Remove “safe”, “painless”, “instant” and similar wording, and link every procedure page to realistic risk and recovery information.
Remove “see your new look” simulators and appearance prediction tools.
Remove finance promotions, bundles that act as incentives, and promotional pricing on prescription treatments.
If you offer remote consultations, make sure the booking flow involves a real-time video or in-person consultation with the prescriber.

Google Business Profile and reviews

Do not reply to, share or showcase reviews that comment on results or a practitioner’s skill. Remove review feeds from your website, and disable reviews and tagging where the platform lets you.

Social media and influencers

Label paid social ads as adult content and exclude under-18 audiences.
Remove trend audio, dance or comedy reels about procedures, emoji reactions and lifestyle shots.
Stop resharing patient stories and tagged posts, even if they are positive and unsolicited.
End giveaways where a treatment is the prize, and “guess the filler” style posts.
Review ambassador and influencer agreements. Free or discounted treatment in exchange for posts is no longer permitted for practitioners covered by the practice guidelines, and you are responsible for the content.

Paid ads

Apply adult content settings, age exclusions and careful audience targeting. Check that ad copy and landing pages do not name or indirectly promote prescription-only medicines (see the TGA section below).

Email and SMS

Recall and promotional messages must follow the same rules: no discount codes for procedures, no referral rewards that act as inducements, no finance offers and no testimonials.

Printed and in-clinic material

Menus, price boards, posters, screens and brochures are advertising. Check them for prescription medicine names, offers and images.

Common mistakes we see

Assuming the rules only cover nurses. The advertising guidelines apply to every profession, including doctors, and to non-practitioner businesses.
Assuming “non-surgical” means low risk for marketing purposes. Laser, energy and skin penetrating treatments can be in scope.
Treating influencer content as the influencer’s problem.
Keeping filtered or “glow” edited after photos because they look better on Instagram.
Leaving out the time elapsed on “after” images.
Keeping “refer a friend” discounts or rewards for injectables, which can conflict with the rules on inducements and discounted procedures for promotion.
Running online questionnaire prescribing models, which the guidelines say are not acceptable practice.

A practical checklist

List every channel: website, Google Business Profile, Instagram, TikTok, Facebook, booking platforms, email, SMS, print.
Confirm which of your procedures are higher risk non-surgical cosmetic procedures.
Name each advertised practitioner with registration type and number.
Remove testimonials, reshared patient content and review feeds; disable reviews and tagging where possible.
Check every image for editing, filters, models and under-18s.
Before-and-after images: genuine, matching, “before” first, time elapsed shown, prominent warning, separate written consent stored.
Remove minimising, idealising and sexualised language and imagery.
Remove competitions, appearance prediction tools and treatment prizes.
Label social ads adult content and exclude under-18s.
Remove finance promotions, recruitment commissions and promotional free or discounted treatments.
Confirm prescribing involves an in-person or video consultation every time.
Update influencer and agency agreements and set an approval process.

How this fits with other rules

TGA. Substances used in cosmetic injectables, such as botulinum toxin type A, are generally prescription-only medicines, and the Therapeutic Goods Act prohibits advertising prescription-only medicines to the public. Since 7 March 2024 the TGA has also said generic terms such as “wrinkle reducing injections” are not permitted where a reasonable consumer would understand the content as promoting a prescription medicine. The TGA has stressed that advertising prescription cosmetic injectables, including through testimonials, claims, before-and-after photos or price lists, has never been compliant. The Ahpra guidelines do not replace any of this: you must meet both.

National Law. Section 133 still prohibits false or misleading advertising, testimonials, offering gifts or discounts without stating the terms, and creating unreasonable expectations of benefit. Ahpra states the maximum penalties are $60,000 for an individual and $120,000 for a body corporate.

Medical Board guidelines. Doctors who perform non-surgical procedures follow the Medical Board’s 2023 practice guidelines, which have similar rules on consultations for schedule 4 injectables and on financial arrangements. Doctors who advertise higher risk non-surgical procedures are covered by the new advertising guidelines.

Australian Consumer Law. Misleading claims about results, prices or offers can also breach consumer law.

Frequently asked questions

Do these guidelines apply to doctors?

The advertising guidelines do. The practice guidelines do not, because doctors already follow the Medical Board’s guidelines from 1 July 2023.

We are a clinic owned by a non-practitioner. Are we covered?

Yes. The advertising guidelines apply to businesses, partnerships, corporate entities and non-registered individuals who advertise higher risk non-surgical cosmetic procedures.

Can we still post before-and-after photos?

Yes, if they meet the conditions: genuine patients of that practitioner, no editing, matching conditions, “before” first, time elapsed shown, a prominent warning and separate consent for advertising use.

Can patients still use buy now pay later?

The practice guidelines allow credit cards, buy now pay later products and non-commercial instalment arrangements to be accepted. You must not offer, promote or recommend financing schemes such as loans or commercial payment plans.

Can patients under 18 be treated?

The guidelines say botulinum toxin and dermal fillers should not be prescribed for cosmetic purposes for under-18s. Where a procedure does go ahead, a cooling-off period of at least seven days applies, with no payment until it ends apart from initial consultations. Advertising must not target under-18s.

How often will these guidelines be reviewed?

The advertising guidelines are generally reviewed at least every five years, and earlier if required.

Need a hand?

If you need to bring a busy injectables clinic’s marketing into line quickly, start with an audit. Our AHPRA compliance audit and TGA advertising compliance reviews cover both sets of rules, and our cosmetic clinic work builds compliant galleries, booking flows and social content.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.