No filters! Advertising and performance guidelines for non-surgical cosmetic procedures

AHPRA has released new standards for non-surgical cosmetic procedures, introducing stricter rules on advertising and practitioner responsibilities.

Since the publication of our previous insights on the overhaul of the regulation of surgical cosmetic procedures (see The cosmetic surgery industry’s facelift: a before and after comparison of the new laws and guidelines, and Cosmetic surgery’s facelift part 2: national standards for facilities in Australia), the Australian Health Practitioner Regulation Agency (AHPRA) has implemented two new sets of guidelines relating to non-surgical cosmetic procedures.

AHPRA has drawn a distinction between surgical and non-surgical procedures, with surgical procedures defined as those involving cutting beneath the skin, such as breast augmentation, face lifts or liposuction. While non-surgical cosmetic procedures do not involve cutting beneath the skin, they may involve piercing the skin, in procedures such as laser hair removal, cosmetic injectables, mole removal procedures and hair transplants.¹

The new guidelines focus on the regulation of both the advertising and performance of non-surgical cosmetic procedures. They acknowledge the ‘unique features’ of cosmetic procedures that are not found in other areas of health practice, and the specific risks that these procedures entail.

The purpose of the guidelines is described as putting patient safety over profit, and includes preventing unsafe practices, promoting informed decision-making by consumers, and preventing trivialisation of non-surgical cosmetic procedures.

Advertising higher risk non-surgical cosmetic procedures

The advertising guidelines are directed at ‘higher risk’ non-surgical cosmetic procedures, which are defined in the guidelines and include procedures such as injectables, fillers, veneers, platelet rich plasma and hair transplants.² The guidelines apply to all registered health practitioners, persons and businesses promoting these procedures.

There are several key requirements when advertising higher risk non-surgical cosmetic procedures, including:

• Practitioner responsibility: Practitioners are responsible for advertising linked to their practice. Claims focused on practitioner experience and/or qualifications must be accurate and verifiable. Advertising must include information about the health practitioner’s registration details, including their registration number.
• Risks, recovery time, potential side effects: Risks, recovery time and potential side effects must be clearly communicated to the patient and documented comprehensively. Terms such as ‘quick and easy’ should not be used without clear information being provided to the patient regarding potential risks.

What is prohibited?

• Advertising that trivialises the risks of procedures.³
• The use of testimonials, including the use of social media influencers providing testimonials or reviews that describe recommendations, clinical outcomes or practitioners’ skill.⁴
• Use of edited or enhanced images which exaggerate or distort results, such as by the use of filters or airbrushing,⁵ and videos or images which idealise or sexualise procedures.⁶ Specific mention is made of ‘lifestyle shots’, such as beachside or poolside photographs, and the use of emojis to denote emotional reactions (such as thumbs up, or crying with happiness) following procedures.
• Advertising targeted (or designed to appeal) to individuals under the age of 18, and images of people under the age of 18.
• Misleading claims about outcomes or benefits of having a procedure.
• Use of statements which are exploitative or imply that a normal change (such as ageing) is undesirable. These include the use of phrases such as ‘youthful’ and ‘perfect’, or those that imply ‘a happier you’ if the procedure is undertaken.⁷
• The offering of financial schemes, either directly or through a third party (e.g. loans or payment plans).⁸

Guidelines for registered health practitioners who perform non-surgical cosmetic procedures

The performance guidelines are directed at registered health practitioners who are not medical practitioners (such as nurses and dentists).⁹ They are similar to those developed for medical practitioners and require non-medical registered health practitioners to meet AHPRAs standards for safe, ethical and competent performance of procedures.¹⁰

Key requirements to achieve this include:

• Ensuring practitioners are suitability qualified to perform the procedures and remain within their scope of practice.
• Additional training requirements for nurses who must now have at least one year of general or specialist practice before performing cosmetic procedures.¹¹ Enrolled nurses also have additional requirements before they can practice non-surgical cosmetic procedures.
• Undertaking an evidence-based, holistic assessment of the patient which includes the person’s history, relevant psychological, social and cultural aspects, and most importantly an assessment for any underlying psychological conditions such as body dysmorphic disorder (which would render the patient unsuitable for the procedure).¹² Practitioners must also ensure the person’s motivation and reasons for the procedure are discussed, assessed and fully documented.
• If any underlying condition or psychological condition is identified which may make the person unsuitable for the procedure, the practitioner should ensure the person is referred to and seen by an appropriate health practitioner (who is independent of the assessing practitioner) before any procedure is undertaken.¹³ If a person is deemed unsuitable for a procedure after an assessment, a health practitioner must decline treatment and/or must not prescribe a cosmetic injectable.¹⁴
• Ensuring sufficient information is provided to the person to enable an informed decision about whether to have the procedure. Both verbal and written consent is required for the procedure (as well as the financial consent). Documentation must be in plain language to ensure the procedure is understood by the patient.¹⁵
• Additional responsibilities for patients under the age of 18, including assessment of the suitability of the procedure, encouraging the patient to discuss why they want to have the non-surgical cosmetic procedure with an independent registered health practitioner,¹⁶ and a mandatory seven day cooling off period between obtaining consent and the procedure being performed.
• Requirements for prescribing Schedule 4 medications, including in-person or video consultation with the person each time they are prescribed a cosmetic injectable, and prohibition on batch prescribing (i.e. each person must have an individual prescription).

What should practitioners and providers do?

• Consult AHPRAs Cosmetic Procedures Hub to familiarise yourself with and understand the guidelines, and ensure staff are trained in the new requirements. Helpful resources include Do's and don'ts for non-surgical cosmetic procedures and The do’s and don’ts of advertising higher risk non-surgical cosmetic procedures.
• Review and, if necessary, revise your current advertising materials, social media content, and materials focused on policies and procedures, to ensure compliance.
• Ensure your advertising gives balanced and accurate information by adequately presenting the risks and recovery process, making clear that outcomes will depend on the individual, as well as describing and/or showing realistic results.¹⁷ If images have been enhanced by filters (or similar) they should be replaced with unaltered images which, in the case of ‘after’ photographs, are taken in similar conditions as the ‘before’ images.
• Exercise particular care in relation to patients under the age of 18, ensuring that the required safeguards are in place, and that all consultations are documented comprehensively.

¹ AHPRA, Guidelines for registered health practitioners who perform non-surgical cosmetic procedures, effective 2 September 2025.
² AHPRA, Guidelines for advertising higher risk non-surgical cosmetic procedures, effective 2 September 2025.
³ Above n 2, at [6.7].
⁴ See also AHPRA’s ‘Guidelines for advertising a regulated health service, December 2020 and Section 24 of the Therapeutic Goods (Therapeutic Goods Advertising Code) Instrument 2021.
⁵ Above n 2, at [5.4].
⁶ Above n 2, at [5.7].
⁷ Above n 2, at [7.3].
⁸ Above n 1, at [14.3].
⁹ Above n 1.
¹⁰ Above n 1, at [9.2].
¹¹ Above n 1, Appendix A.
¹² Above n 1, at [2.2].
¹³ Above n 1, at [2.4].
¹⁴ Above n 1, at [2.6].
¹⁵ Above n 1, at [5.1].
¹⁶ This may be, but is not limited to, a general practitioner, psychologist, psychiatrist, or nurse practitioner. The practitioner referred to should be independent of the registered health practitioner performing the cosmetic procedure and should not work in the cosmetic procedure industry (as outlined in AHPRA, Guidelines for registered health practitioners who perform non-surgical cosmetic procedures, effective 2 September 2025, pp 5).
¹⁷ Above n 2, at [p 5].