Cosmetic Injectables Refresher Training and Ongoing CPD
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Navigating AHPRA’s Cosmetic Injecting Guidelines: What Practitioners Must Know
The regulation of non-surgical cosmetic procedures in Australia has changed significantly. The current AHPRA and National Board guidelines place greater emphasis on patient safety, psychological suitability, informed consent, practitioner competence, ethical advertising and ongoing maintenance of scope of practice.
The guidelines for registered health practitioners who perform non-surgical cosmetic procedures came into effect on 2 September 2025. They apply to registered health practitioners performing these procedures, other than medical practitioners, who are subject to the Medical Board of Australia’s separate cosmetic surgery and procedures guidelines.
For dentists, nurses and other registered practitioners providing cosmetic procedures, compliance is not simply an administrative exercise. Practitioners must be able to demonstrate that their education, clinical systems, documentation, advertising and day-to-day decision-making place patient welfare ahead of commercial pressure.
Key Takeaways
- The AHPRA guidelines for non-surgical cosmetic procedures have been in effect since 2 September 2025.
- The guidelines do not automatically expand a practitioner’s professional scope of practice.
- Patient assessment must include psychological suitability, motivations and realistic expectations.
- Consent must be informed, voluntary, documented and specific to the proposed procedure.
- Practitioners require appropriate education, supervised practical training and assessed competence before treating independently.
- Scope of practice must be maintained through relevant continuing professional development and recent clinical experience.
- Advertising must comply with both AHPRA requirements and the TGA prohibition on public advertising of prescription medicines.
What Changed on 2 September 2025?
AHPRA and the National Boards introduced national guidelines to clarify the standards expected of registered health practitioners who perform non-surgical cosmetic procedures. The guidelines strengthen safeguards around consultation, patient suitability, consent, training, prescribing relationships, follow-up care, complications and advertising.
These requirements should not be viewed as a one-off checklist. Cosmetic practice requires practitioners to maintain contemporary knowledge, clinical competence, accurate records and systems that support safe patient care over time.
Core Principle
Registration alone does not establish competence. A practitioner must be able to demonstrate that the procedure falls within their professional scope and that they have the education, practical training, competence and clinical systems required to perform it safely.
Scope of Practice Is Not Automatically Granted
The guidelines do not create a new or expanded scope of practice. Each practitioner remains responsible for determining whether a cosmetic procedure is permitted within their profession and whether they personally have the competence to provide it.
This assessment should consider:
- The practitioner’s profession and registration standards
- Relevant National Board codes, guidelines and position statements
- Education and supervised practical training
- Assessed clinical competence
- Recency of practice and ongoing continuing professional development
- Professional indemnity insurance
- State or territory medicines and poisons legislation
- The availability of appropriate prescribing, emergency and referral pathways
Completing a course does not, by itself, establish that every procedure is within scope. Practitioners must be able to explain how their education and experience support each procedure they perform.
Psychological Screening and Patient Suitability
One of the most important elements of the guidelines is the requirement for a thorough assessment of the patient’s suitability for a cosmetic procedure. This includes more than reviewing medical history and anatomical concerns. The consultation must also explore the patient’s motivations, expectations and psychological readiness.
Practitioners should be alert to concerns such as:
- Disproportionate distress about a minor or imperceptible feature
- Repeated procedures without satisfaction
- Unrealistic expectations of what treatment can achieve
- Pressure from a partner, employer, social media or another person
- A belief that treatment will resolve broader relationship, social or emotional problems
- Behaviour suggesting possible body dysmorphic disorder or another psychological condition
Screening should be evidence-based and integrated into a structured consultation. When concerns arise, treatment may need to be deferred or declined, with referral to an appropriately qualified health professional where indicated.
Patient Welfare Comes First
A patient requesting treatment is not automatically a suitable candidate. The practitioner’s responsibility is to recommend only what is clinically appropriate—even when that means recommending no treatment.
Consultation and Informed Consent
Consent is a process, not merely a signed form. Before treatment, the patient must receive enough information to make a voluntary and informed decision. The discussion must be tailored to the patient, the proposed procedure and the practitioner’s clinical findings.
A comprehensive consent process should include:
- The patient’s concerns and desired outcome
- The proposed procedure and why it is being recommended
- Reasonable alternatives, including no treatment
- Material risks, side effects and possible complications
- Expected recovery, limitations and likely longevity
- Costs, including potential costs associated with reviews or complication management
- The practitioner who will perform the procedure and their qualifications
- Any off-label use of a medicine or device
- Follow-up arrangements and how urgent concerns will be managed
Consent for Off-Label Use
Off-label use occurs when a medicine is used outside the indications, patient groups, dose, route or other conditions included in its approved product information. Off-label prescribing may be clinically appropriate, but it requires careful professional judgement.
Patients should be told when a proposed use is off-label, why it is being recommended, what evidence supports the decision and what alternative options are available. This discussion should be clearly documented.
Education, Practical Training and Competence
The guidelines reinforce that practitioners must have appropriate education and training before performing non-surgical cosmetic procedures. Training should be relevant to the procedure and should build both theoretical knowledge and practical clinical competence.
A defensible training pathway should include:
- Facial anatomy and physiology
- Patient assessment and treatment planning
- Pharmacology and product knowledge
- Contraindications and patient selection
- Consent and documentation
- Supervised hands-on treatment of suitable patients
- Complication prevention, recognition and management
- Formal assessment of competence
Online theory can support learning, but it cannot replace supervised practical training where hands-on clinical skills are required. Practitioners should be able to show not only that they attended training, but that their competence was assessed.
| Education Alone | Competence for Practice |
|---|---|
| Watching demonstrations | Supervised practical treatment |
| Completing online modules | Applying knowledge to real clinical decisions |
| Receiving a certificate of attendance | Documented assessment against defined criteria |
| Learning one injection pattern | Adapting treatment to anatomy, risk and patient needs |
Maintaining Scope Through CPD and Recency
Competence must be maintained. A practitioner who trained several years ago but has not updated their knowledge or practical skills may not be able to demonstrate contemporary competence.
Continuing professional development should relate directly to the procedures being performed and the risks encountered in practice. Depending on the practitioner’s needs, this may include:
- Refresher training with supervised practical components
- Advanced anatomy education
- Complication management training and simulation
- Case review and mentoring
- Updates in pharmacology, products and evidence
- Consent, advertising and regulatory education
- Clinical audit and reflective practice
CPD should not be selected simply to accumulate hours. It should address the practitioner’s actual scope, experience, identified gaps and the procedures they intend to continue performing.
Prescribing and Collaborative Care
Many cosmetic procedures involve prescription-only medicines. Practitioners must comply with their professional obligations and the medicines and poisons legislation that applies in their state or territory.
Prescribing must be based on a genuine clinical assessment. The prescriber must obtain sufficient information to determine whether the medicine is appropriate, consider contraindications and alternatives, and establish a safe plan for treatment and follow-up.
Practitioners working in collaborative models should have clear arrangements for:
- Patient assessment and prescribing
- Communication between the prescriber and treating practitioner
- Access to clinical records
- Management of adverse events
- Review and escalation of concerns
- Continuity of care
Advertising: AHPRA and TGA Rules Apply Together
Cosmetic advertising must comply with the National Law, AHPRA’s advertising guidance and the separate requirements administered by the Therapeutic Goods Administration.
AHPRA expects advertising of higher-risk cosmetic procedures to be honest, balanced, realistic and informative. Advertising must not exploit vulnerability, trivialise risk, create unreasonable expectations or encourage indiscriminate use of cosmetic procedures.
Prescription Medicines Cannot Be Advertised to the Public
The TGA prohibits public advertising of prescription medicines, including direct and indirect references to prescription-only cosmetic injectables. This can include brand names, active ingredients, abbreviations, nicknames, medicine classes and imagery or wording that clearly implies the availability or use of a prescription medicine.
The restriction can apply across:
- Websites and landing pages
- Social media posts, captions, hashtags and videos
- Booking systems and treatment menus
- Email and SMS marketing
- Price lists and package promotions
- Testimonials and user-generated content controlled by the business
- Business names, logos and visual imagery
Before-and-After Images Require Careful Context
Before-and-after photographs are not automatically prohibited under therapeutic goods legislation. However, where the image or surrounding context directly or indirectly suggests that the result was achieved using a prescription medicine, the content is likely to amount to unlawful advertising of that medicine.
Practitioners must also comply with AHPRA’s requirements for advertising cosmetic procedures, including accurate representation of results, appropriate consent and avoidance of misleading or exploitative content.
Advertising Reminder
Removing a brand name is not necessarily enough. The regulator considers the entire context, including substitute terminology, treatment outcomes, photographs, symbols, hashtags, booking categories and calls to action.
Patients Under 18
Younger patients require additional safeguards. The guidelines include restrictions relating to advertising directed at people under 18 and require a seven-day cooling-off period for non-surgical cosmetic procedures for patients under 18.
Practitioners must also consider capacity, consent, maturity, psychological suitability and whether the proposed procedure is clinically appropriate. Where concerns exist, treatment should not proceed merely because consent has been requested or provided.
Complications, Follow-Up and Continuity of Care
The practitioner’s responsibility does not end when the procedure is completed. Appropriate systems must be in place for post-treatment advice, review, complication management and escalation.
A cosmetic practice should have:
- Written aftercare instructions
- A process for patients to report urgent concerns
- Appropriate emergency medicines and equipment
- Current complication protocols
- Defined referral and escalation pathways
- Clear responsibility for follow-up care
- Accurate documentation of adverse events and management
Practitioners should rehearse emergency protocols with their team. A protocol that exists only in a folder may not be sufficient during a time-critical complication.
A Practical Compliance Checklist
| Area | Questions to Ask |
|---|---|
| Scope | Is this procedure within my profession, training, competence and insurance? |
| Training | Have I completed relevant theory, supervised practical training and assessed competency? |
| Patient suitability | Have I assessed medical, anatomical and psychological suitability? |
| Consent | Have material risks, alternatives, costs, limitations and off-label use been discussed and documented? |
| Prescribing | Is the prescribing process based on an adequate clinical assessment and compliant with local law? |
| Advertising | Could any wording, image, hashtag, price or booking option directly or indirectly promote a prescription medicine? |
| Aftercare | Can patients access timely review and complication care? |
| Ongoing competence | Does my recent practice and CPD support the procedures I continue to provide? |
Frequently Asked Questions
When did the AHPRA cosmetic procedure guidelines take effect?
The guidelines for registered health practitioners who perform non-surgical cosmetic procedures took effect on 2 September 2025.
Do the guidelines apply to medical practitioners?
Medical practitioners are covered by the Medical Board of Australia’s separate guidelines for registered medical practitioners who perform cosmetic surgery and procedures. The non-surgical cosmetic procedure guidelines discussed here apply to other registered health practitioners within their respective National Boards.
Does completing a cosmetic injecting course place the procedure within my scope?
Not automatically. Scope depends on the practitioner’s profession, registration requirements, education, competence, recent practice, insurance and relevant legislation. Training is essential, but it must be appropriate, practical and supported by assessed competence.
Is psychological screening required for every patient?
Patient suitability assessment must include psychological factors, motivations and expectations. The nature and depth of screening should be clinically appropriate, evidence-based and sufficient to identify concerns that may make treatment unsuitable.
Can cosmetic clinics advertise before-and-after photographs?
Before-and-after photographs are not automatically prohibited, but they may breach TGA requirements when the image or its context implies that a prescription medicine produced the result. They must also comply with AHPRA advertising rules and patient-consent requirements.
Can I advertise the price of prescription cosmetic injectables?
Public pricing that directly or indirectly promotes prescription medicines is generally prohibited. Cosmetic clinics should review treatment menus, booking systems, package offers and cost-per-unit advertising carefully.
Is online-only cosmetic injecting education sufficient?
Online education can provide valuable theoretical learning, but it does not replace supervised hands-on training and assessment where practical clinical competence is required.
How can I demonstrate ongoing competence?
Evidence may include relevant CPD, recent clinical practice, practical refresher training, mentoring, case review, complication education, audit and documentation showing that learning has been applied to practice.
Quick Summary
- Patient safety and suitability must come before commercial considerations.
- Practitioners must work within their professional scope and personal competence.
- Training should include theory, supervised practice, complications and competency assessment.
- Consent must include material risks, alternatives, limitations and off-label use where relevant.
- Ongoing CPD and recent clinical experience are necessary to maintain scope.
- Advertising must comply with both AHPRA and TGA requirements.
Stay Compliant, Current and Clinically Prepared
The AHPRA cosmetic procedure guidelines reinforce a simple but important message: practitioners are accountable for their education, clinical judgement, patient care and professional conduct.
Dermal Distinction Academy provides structured cosmetic injectable education for AHPRA-registered practitioners, combining comprehensive theory, small-group practical training, competency assessment and ongoing clinical support.
Official Guidance
- AHPRA: Performing non-surgical cosmetic procedures
- AHPRA: Advertising higher-risk non-surgical cosmetic procedures
- TGA: Restrictions on advertising prescription medicines to the public
This article provides general educational information and is not legal advice. Practitioners should review the current official guidance, their National Board requirements and the medicines legislation applicable in their state or territory.
