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Ahpra’s new guidelines for non-surgical cosmetic procedures explicitly reaffirm that practitioners are required to work within the limits of their skills, training and experience.
The regulation of non-surgical cosmetic procedures in Australia has been strengthened with the release by Ahpra of advance copies of new Guidelines for practitioners who perform non-surgical cosmetic procedures and Guidelines for advertising higher risk non-surgical cosmetic procedures.
These guidelines are due to come into effect on 1 September 2025 and apply specifically to non-medical practitioners who work or advertise in this space.
It is pleasing to see that these new guidelines are largely in line with the Australian Society of Plastic Surgeons (ASPS) and other practitioners call for them to mirror the expectations and standards that have applied to medical practitioners following the release of updated guidelines in July 2023. By doing so, many of the disparities and inconsistencies have been removed with an emphasis on patient-centred care, and clearly written expectations for minimum qualifications and experience of practitioners conducting or transitioning to this type of practice.
ASPS has previously written that part of the concern of the regulators with the non-surgical cosmetic procedure industry was the growing sense amongst the public, and to some extent the providers, that these procedures were becoming normalised as extensions of the beauty industry, rather than respecting their origins as medical procedures, or involving the use of prescription-only medicines.
To reverse this trend, the new guidelines explicitly reaffirm that practitioners are required to work within the limits of their skills, training and experience, and that this will vary according to the nature of their profession and training.
The guidelines also note that for some practitioners the cosmetic procedure or prescribing of a cosmetic injectable may not be within the practice of their profession, highlighting that the use and advertisement of Schedule 4 products, including botulinum toxin and dermal fillers, are subject to the requirements of the Therapeutics Goods Administration. Practitioners must also know of, and comply with, state-based legislation for Schedule 4 (prescription-only) medicines that controls their use, supply, storage and prescription.
This advice is consistent with the update released by the Queensland Department of Health late last year that reminded practitioners of the legislation in regard to these Schedule 4 substances. A further clarification was released in April and again highlighted that some of the business structures and practice models in this area have evolved in a way that is inconsistent with the requirements of the legislation. In particular, these substances can only be purchased by and supplied to medical practitioners or nurse practitioners (authorised prescribers), who must also comply with the legislation in regard to possession, storage, prescription and supply of these medicines.
To minimise confusion, the document also explicitly defines what are considered the non-surgical procedures that are subject to these guidelines. The new guidelines also highlight the need for appropriate patient assessment, with guidelines and cooling off periods for patients under the age of 18, as well as guidelines regarding practitioner responsibility for appropriate informed consent, post-procedure care, and expectations regarding the knowledge and management of potential complications.
These are all consistent with the expectations and standards of good clinical care and should be accepted without question by all participants in the industry.
However, challenges remain in continuing to protect the public. Unfortunately, there are no consistent minimum training requirements or qualifications that denote that a practitioner has undertaken appropriate training, or achieved a necessary level of competence, in administering injectables or performing other forms of non-surgical cosmetic procedures.
As highlighted in the guidelines, practitioners can enter this space from a variety of professions with differing levels of exposure, experience and training in human anatomy, physiology, pharmacokinetics, and pharmacodynamics. This means that the level and type of education and training required to perform a cosmetic procedure competently and safely may vary significantly. Patients will therefore continue to find it difficult to determine who is properly trained and competent.
Furthermore, the non-surgical cosmetic procedure industry (and cosmetic surgery before it) highlight the potential negative aspects of practitioners working at the limit of their scope, experience, and training. A minor misjudgement, or a deliberate step beyond scope, can lead to circumstances that place both the practitioner and the patient at great risk.
An inaccurate assessment, a wrong diagnosis, an ill-informed treatment plan, or an unexpected complication or outcome, can all result from such a scenario and lead to potentially catastrophic and irreversible consequences.
In essence, the guidelines continue to put the onus on the practitioners to practice within their scope in order to protect the public. This has always been the case. But the financial incentives in this industry have led to some practitioners, often with less formal training and experience, to provide these services in a manner that prioritises financial rewards over their professional responsibilities.
Although these new guidelines attempt to draw firmer boundaries, these temptations remain. As such, tighter guidelines and regulations will have limited effect unless they are also introduced with a stricter monitoring, compliance, and enforcement regime.
The ASPS acknowledges the complexity of this industry and congratulates Ahpra on developing guidelines that require practitioners to put patients first and maintain the highest standards of care.
Nonetheless, appropriate oversight of all practitioners remains necessary to ensure public safety. We therefore encourage Ahpra and the various professional boards to continue to actively monitor the industry, enforce standards, and act when infractions occur by applying appropriate sanctions and penalties to discourage inappropriate practice.
Dr David Morgan is a specialist plastic surgeon and President of the Australian Society of Plastic Surgeons.
The statements or opinions expressed in this article reflect the views of the authors and do not necessarily represent the official policy of the AMA, the MJA or InSight+ unless so stated.
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