From confirmed advertising restrictions to reported reforms in nurse entry and telehealth, the non-surgical cosmetic industry enters a new phase of regulation.
For the past six months, Australia’s aesthetic medicine industry has been anticipating updated guidance from the Australian Health Practitioner Regulation Agency (AHPRA). This week, that update arrived.
While coverage in The Sydney Morning Herald and The Age highlighted reforms to telehealth protocols, cosmetic nurse entry pathways, and the use of AI-generated before-and-after imagery, AHPRA’s newly released Guidelines for Advertising Higher Risk Non-Surgical Cosmetic Procedures are focused specifically on advertising standards. These confirmed guidelines will become mandatory as of September 2, 2025, providing practitioners, marketers, and clinic teams with a three-month compliance window.
Confirmed: What’s Changing in Advertising
Although much of this was previously understood, AHPRA’s guidelines now clearly define higher-risk procedures as those involving Schedule 4 medicines, elevated clinical complexity, or the potential for serious harm, whether physical or psychological.
Examples include:
- Cosmetic injectables (including fat-dissolving treatments)
- Thread lifts
- Sclerotherapy and microsclerotherapy
- Platelet-rich plasma (PRP) injections
- Biotherapy (e.g. stem cells, growth factor injections)
- Hair transplants
- Cosmetic dental procedures (e.g. veneers)
Key confirmed changes to advertising include:
- A complete ban on the use of influencers or ambassadors to promote cosmetic procedures, whether paid or gifted
- A ban on testimonials, including reposted patient reviews or stories
- Prohibition of AI-generated or filtered before-and-after imagery
- Stricter rules for image use (e.g. matching lighting, context, and timeline) and required disclaimers
- All marketing must communicate risks, recovery periods, and the variation in outcomes
- Content must not target or be exposed to those under 18
- Frequent or excessive cosmetic procedure posting is discouraged, as it may contribute to body dissatisfaction or normalise intervention
One of the more unexpected inclusions is AHPRA’s stance on over-posting. The guidelines suggest that even fully compliant content, if shared too frequently, can contribute to harm. While not yet widely unpacked, this raises new questions for clinics about how often they can post without crossing an ethical line, adding a somewhat subjective layer to what was already a complex area of compliance.
Reported (Not Yet Confirmed): Broader Reforms Under Review
In parallel to the confirmed guidelines, The Sydney Morning Herald and The Age have reported this morning that AHPRA is reviewing broader regulatory areas, including:
Telehealth Consultations
AHPRA is reportedly set to strengthen requirements for telehealth consultations related to cosmetic procedures. The focus is on improving the quality and depth of these interactions. Practitioners may soon be expected to conduct more comprehensive assessments that include discussions of alternative treatments, evaluation of patient expectations, and the use of a formalised consent process supported by a structured checklist.
Nurse Entry Requirements
The reports also suggest that newly qualified nurses may soon be required to complete one year of full-time clinical experience in a non-cosmetic setting before entering the aesthetic sector. This would address ongoing concerns around anatomical knowledge and clinical judgment.
Patients Under 18
Another reported reform is the potential introduction of a mandatory seven-day cooling-off period after the first consultation for patients under 18 before any injectable or cosmetic procedure may proceed.
What Clinics Should Do Now
With the advertising guidelines now confirmed and enforceable from September 2, 2025, clinics and marketers are encouraged to use the next three months to:
- Audit existing marketing materials and social media content
- Reassess partnerships with influencers or brand ambassadors
- Review consent, photography, and advertising processes
- Train staff on the new compliance expectations, particularly around tone, frequency, and presentation
Additional updates, including potential changes to nurse training and telehealth, are anticipated from AHPRA as early as Tuesday, June 10.
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