‘Surgeon’ becomes a protected title: what practices must change

From 20 September 2023 only doctors with specialist surgical registration can use ‘surgeon’. What to update, plus later oral and podiatric title changes.

20 September 202312 min read

From 20 September 2023, in most Australian states and territories, “surgeon” became a protected title for medical practitioners. A doctor can now only call themselves a surgeon, or a “cosmetic surgeon”, if they hold specialist registration in surgery, obstetrics and gynaecology or ophthalmology. Misusing the title is a criminal offence.

This is a change to the Health Practitioner Regulation National Law itself, not a guideline. It affects every place a doctor’s title appears: your website, Google Business Profile, social media bios, directory listings, letterheads, business cards and the window of your clinic. If you employ or promote doctors who perform cosmetic or procedural work without specialist surgical registration, it is one of the most direct marketing changes of recent years.

Later developments: the Medical Board says New South Wales, South Australia and Western Australia, which needed their own legislative steps, have also made the change, creating a consistent national rule. Separately, in other professions, an Ahpra review released on 28 February 2025 found no evidence of harm from the dental specialist title “oral surgeon”, so it remains in use while the Dental Board prepares a consultation on dental specialist titles. And in podiatry, Health Ministers approved replacing “podiatric surgeon” with “surgical podiatrist”, with practitioners unable to use the old title after 5 October 2026. We cover those changes further down.

What changed

The Queensland Parliament, which hosts the National Law, passed the Health Practitioner Regulation National Law (Surgeons) Amendment Bill in September 2023. Ahpra announced the passing on 13 September 2023. The Act inserts a new section 115A into the National Law restricting the use of the title “surgeon” by medical practitioners. The Medical Board says the changes started on 20 September 2023 in most states and territories.

The change delivered on an agreement by Health Ministers on 2 September 2022 to protect the title through legislation, so that doctors using it have the requisite training. It sits alongside the wider cosmetic surgery reforms, including the cosmetic surgery practice and advertising guidelines that took effect on 1 July 2023.

At the time, Ahpra explained that most states and territories would apply the amendment automatically, while Western Australia was expected to introduce a corresponding bill, and South Australia and New South Wales would make a regulation confirming the amendments apply. The Medical Board’s FAQ now states that NSW, SA and WA have also made the change. We could not confirm the exact commencement date in each of those three states from a primary source, so check the current position if a date matters to you.

Who it applies to

Who can use the title

Only medical practitioners with specialist registration in:

surgery
obstetrics and gynaecology
ophthalmology.

The Act describes these practitioners as a surgical class, which can also include a specialty whose specialist title includes the word “surgeon”, or a class prescribed by regulation. In practice, the Medical Board names the three specialties above.

Who cannot

Doctors with general registration, including those who perform cosmetic surgery.
Specialist GPs without specialist surgical registration. They can keep providing surgical services, including in rural and regional areas, but cannot use “GP surgeon”.
Specialist international medical graduates working under supervision with limited or provisional registration. They cannot call themselves surgeons, but they can say they are doing the surgery.
Doctors with a cosmetic surgery endorsement. The Medical Board says an endorsement does not allow a practitioner to use “cosmetic surgeon”. In any case, its endorsement page says there are no approved programs of study yet.

Who is not affected

The amendment applies to medical practitioners. It does not affect other professions that use surgical titles, such as dentists using “dental surgeon”. Podiatry titles were dealt with separately, as described below.

Combinations count

The restriction covers “surgeon” on its own and in combinations. Ahpra gives “cosmetic surgeon” and “aesthetic surgeon” as examples.

What the rules require

Remove the title everywhere it appears

The Medical Board says all references to “surgeon” must be removed from advertising for a doctor who is not in the surgical class. Its examples include websites, social media, letterheads, business cards and clinic windows. The list is not exhaustive, so treat any public-facing description of the doctor as in scope.

Penalties

Misuse of the title is a criminal offence. The maximum penalty for an individual is a $60,000 fine, three years’ imprisonment, or both. The Act also provides a penalty of up to $120,000 for a body corporate that uses the title, or claims a practitioner is a surgeon, for a practitioner outside the surgical class. That matters for clinic companies and other businesses that publish doctor profiles.

How enforcement works

The Medical Board’s FAQ explains that individuals found to be using the title unlawfully will first be advised in writing and asked to remove all references to “surgeon”. If they continue after the warning, they could face criminal prosecution by Ahpra. The Medical Board may also take disciplinary action, either alongside a prosecution or instead of it. We found no transition or grace period: the restriction applied from the commencement date.

What it means for your marketing

Website

Review every doctor bio, team page, procedure page, page title, meta title and meta description. “Cosmetic surgeon in Adelaide” style headings and SEO titles are a common hiding place.
Check image alt text, file names and schema markup, such as a job title in structured data.
Check blog posts and FAQs, including older articles that describe a doctor as “our surgeon”.
Rewrite with accurate, plain descriptions. A doctor without the right registration can be described by their actual registration and the procedures they perform, for example “Dr X, a medical practitioner with general registration, performs …”, provided it is accurate and not misleading.

Google Business Profile and directories

Business names, categories and descriptions on Google Business Profile often use “cosmetic surgeon”. Check the profile name, the primary and secondary categories, the description, the services list and posts. Then check health directories, booking platforms and medical association listings you control or can request changes to.

Social media

Update display names, handles, bios, link-in-bio pages, highlight covers and pinned posts. Hashtags such as #cosmeticsurgeon on your own posts about a doctor can easily read as using the title, so remove them. Influencer and content creator posts that call your doctor a surgeon are part of your advertising if you engaged them.

Paid ads

Check ad copy, headlines, sitelinks, landing pages and keyword-inserted headlines. Search ads that dynamically insert a keyword like “cosmetic surgeon” can apply the title to your doctor without anyone writing it.

Email and SMS

Email signatures, templates and automated appointment messages often carry titles. Update them at the same time.

Printed and in-clinic material

Letterheads, business cards, brochures, consent paperwork headers, door plates, window decals and signage all need checking. These usually take the longest to replace, so start early.

Later surgical title changes in other professions

“Oral surgeon”: no change for now

Ahpra commissioned an independent rapid review of the dental specialist title “oral surgeon” in September 2024, after a concern that it could be misleading. The review, released on 28 February 2025, found minimal risk. It recorded 19 complaints against oral surgeons from 2019 to 2024, with one leading to a caution, and one advertising offence in the same period. It found no evidence the title had caused serious physical or financial harm. Ahpra and the Dental Board accepted all recommendations, including improving public understanding of dental specialties and holding a full public consultation on all dental specialist titles, expected in 2025 to 2026. We could not find that consultation published as at October 2026, so “oral surgeon” remains a dental specialist title for practitioners with that specialist registration.

“Podiatric surgeon” becomes “surgical podiatrist”

On 6 October 2025 Ahpra announced that Health Ministers had approved, on the Podiatry Board’s recommendation, changing the specialist title “podiatric surgeon” to “surgical podiatrist”. The change followed an independent review led by Professor Ron Patterson, whose final report on 27 March 2024 made 14 recommendations, and a public consultation that drew more than 240 submissions. A 12-month transition followed, and practitioners will be unable to use “podiatric surgeon” after 5 October 2026. As at 30 June 2025 there were 42 registered podiatric surgeons, 0.7% of the 6,187 registered podiatrists. Podiatry practices need the same clean-up described above: website, Google Business Profile, directories, social media, signage and stationery.

Wording to avoid and safer alternatives

The safest approach is to describe each practitioner’s registration accurately and let their training and services speak for themselves. A few examples:

Avoid: “Adelaide’s cosmetic surgeon” for a doctor without specialist surgical registration. Instead: “Dr [Name], medical practitioner, providing cosmetic procedures”, with the registration type stated accurately.
Avoid: “Meet our surgeons” on a team page that includes doctors without qualifying specialist registration. Instead: list each practitioner with their actual registration and role.
Avoid: a practice, trading or domain name built around “surgeon” that implies a title the doctor can’t use. Instead: a name based on the practitioner’s own name, the location or the services provided.
Avoid: “Perfect results from an experienced surgeon”. Instead: “A consultation to discuss whether a procedure is suitable for you, including its risks and recovery.” The first version also risks creating unreasonable expectations under the general advertising guidelines.

Holding out is about the overall impression, not only the exact word. A domain name, logo or headline that leads people to believe a doctor is a surgeon can be a problem even if the word never appears on its own. Old page titles and meta descriptions can also keep showing in Google search results for weeks after the visible page has changed, so update them first and ask Google to recrawl the page.

If you are a specialist plastic surgeon

If you hold specialist registration in plastic surgery, the protected title works in your favour, because it makes the difference between your registration and other practitioners’ clearer to patients. It is still worth checking your own materials:

Make sure your specialist registration is stated accurately everywhere, including directories and hospital profiles.
Check that other doctors in your practice are not described with titles they can’t use, including in shared team pages and joint marketing.
Ask referrers, hospitals and directories that describe your team to keep their listings accurate.

Holding the title doesn’t exempt your content from anything else. Your cosmetic surgery pages still need to meet the Medical Board’s cosmetic surgery advertising guidelines and the general advertising rules, including those on testimonials, images and unreasonable expectations.

Common mistakes we see

Fixing visible pages but not SEO fields. Page titles, meta descriptions and old URLs with “cosmetic-surgeon” in the slug still show in search results.
Swapping to near-synonyms. Terms such as “aesthetic surgeon” are covered. Replacements must also not imply specialist status the doctor does not hold.
Forgetting third-party profiles. Directories, booking sites and old press pages you can update.
Assuming the clinic is not responsible. A body corporate can face a penalty for holding out a practitioner as a surgeon.
Thinking an endorsement or long experience fixes it. Only specialist registration in the relevant specialties allows the title.
Leaving old social posts up. Captions and hashtags from years ago remain public advertising.

A practical checklist

Check each doctor’s registration on the Ahpra public register and note whether they hold specialist registration in surgery, obstetrics and gynaecology or ophthalmology.
Search your website for “surgeon”, “surgeons” and “surgical” used as a title, including page titles, meta fields, alt text, slugs and schema.
Update Google Business Profile names, categories, descriptions and services.
Update social media names, handles, bios, highlights and recent and pinned posts.
Review paid search and social ads, including dynamic keyword insertion.
Update email signatures, templates and automated messages.
Replace letterheads, business cards, brochures and signage.
Request changes to directory and booking platform listings.
Brief staff, agencies and content creators on the correct way to describe each doctor.
For podiatry practices: replace “podiatric surgeon” with “surgical podiatrist” everywhere before 5 October 2026.
Keep a dated record of what you changed.

How this fits with other rules

National Law protected titles. Section 115A sits alongside the other protected title provisions in the National Law. It is a criminal offence provision, so it is enforced separately from the professional standards set out in guidelines.

Advertising rules. Ahpra’s Guidelines for advertising a regulated health service, and the Medical Board’s cosmetic surgery advertising guidelines from 1 July 2023, already required clear and accurate information about a practitioner’s qualifications and registration, and prohibited claims that imply specialist status without specialist registration. The surgeon title change adds a criminal offence on top. Ahpra has said its general advertising guidelines will be updated to reflect the new section when next reviewed.

Australian Consumer Law. Describing a practitioner’s qualifications in a misleading way can also be misleading or deceptive conduct under consumer law.

Frequently asked questions

Can a GP who performs skin cancer surgery call themselves a GP surgeon?

No. The Medical Board says specialist GPs without surgical specialist registration can keep providing surgical services, but cannot use “GP surgeon”.

Can we say a doctor “performs surgery”?

The Medical Board confirms that specialist international medical graduates can say they are doing the surgery without using the title. Describing what a doctor actually does, accurately and without implying they are a surgeon, is the approach we recommend for any doctor outside the surgical class. Make sure the wording is not misleading overall.

Does this affect “cosmetic surgery” as a service name?

The restriction is on the title “surgeon” used for a practitioner. It does not ban the phrase “cosmetic surgery”. However, cosmetic surgery advertising must follow the Medical Board’s cosmetic surgery advertising guidelines, including clear information about the practitioner’s registration.

Are dentists affected?

No. The amendment applies to medical practitioners. Dental surgical titles are not affected, and Ahpra’s 2025 review kept “oral surgeon” as a dental specialist title for now.

What happens if we miss something?

According to the Medical Board, individuals are first advised in writing and asked to remove references. Continued use after a warning can lead to criminal prosecution and disciplinary action. It is far better to find and fix issues yourself.

Is there a grace period?

We found no general transition period for the medical title. For podiatry, there was a 12-month transition, ending with the old title unavailable after 5 October 2026.

Need a hand?

Titles hide in more places than most practices expect, from schema markup to signage. Our AHPRA compliance audit includes a full title search across your website, profiles and social channels, and our medical SEO team can update page titles, slugs and redirects without losing search visibility. We also work with surgical and cosmetic practices on accurate practitioner profiles.

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.