Understanding the new Guidelines for registered health practitioners performing non-surgical cosmetic procedures

The Australian Health Practitioner Regulation Agency (AHPRA) has introduced updated advertising provisions specifically for non-surgical cosmetic procedures (such as anti-wrinkle injections, dermal fillers, and skin rejuvenation treatments). These provisions aim to protect consumers by promoting truthful, responsible, and safe advertising, and apply to all advertising activities by or on behalf of registered health practitioners (including doctors, nurses, and dentists).

BROADER LEGAL CONTEXT

These advertising rules are enforceable under the Health Practitioner Regulation National Law and align with AHPRA’s general Advertising Guidelines. They also complement regulations from the Therapeutic Goods Advertising Code where relevant. Both practitioners and those publishing or distributing their advertisements can be held accountable for breaches.

KEY ADVERTISING REQUIREMENTS

Clear identification of practitioner

• Advertising must clearly state the name and registered professional title of the health practitioner performing or supervising the cosmetic procedure.

• This is to ensure consumers know exactly who is responsible for the treatment.

No targeting of minors

• Advertising must not be directed at persons under 18 years of age.

• This includes avoiding images, language, platforms, or content that appeal to or depict minors.

• Ads should not be placed on media channels where a significant proportion of the audience is under 18.

Prohibition of testimonials and influencer endorsements

• Advertisements cannot include testimonials, patient reviews, or endorsements, whether from patients or social media influencers.

• This includes any personal stories or before/after experiences shared in exchange for payment, free treatment, or any other incentive.

• Influencer marketing involving promotional exchanges is explicitly prohibited.

Restrictions on incentives and promotional offers

• It is prohibited to offer free or discounted treatments in return for advertising, promotional posts, or testimonials.

• Financial or other incentives that encourage public promotion must not be part of advertising strategies.

 Avoid misleading or exaggerated claims

• Ads must not promise or imply guaranteed or universal results (e.g., “instant,” “permanent,” “completely safe”).

• All claims must be accurate, evidence-based, and not misleading.

• Avoid hyperbolic language that may create unrealistic expectations.

Responsible use of ‘Before and After’ images

• Images must represent typical outcomes, not exceptional cases.

• Photos should be consistent in lighting, angle, and context, and must not be retouched or filtered.

• A clear disclaimer should be included noting that results vary between individuals.

Accurate representation of qualifications

• Practitioners must not misrepresent their qualifications or use titles like “cosmetic surgeon” unless they hold the correct formal accreditation.

• Advertising must not exaggerate practitioner expertise or specialist status beyond what is registered with AHPRA.

IMPLICATIONS FOR PUBLISHERS AND ADVERTISERS

• Publishers must carefully review cosmetic procedure advertisements for compliance before acceptance or publication.

• Editorial and sales teams should be aware that accepting non-compliant ads can risk legal consequences and damage reputations.

• Sponsored content, advertorials, and social media promotions must also adhere strictly to these rules.

• If there is any uncertainty, publishers should request written confirmation from practitioners that their advertising materials have been reviewed for compliance.