Health practitioners, employer fined for illegally working when unregistered

03 Mar 2026

Three recent criminal cases have emphasised the importance of registration in signifying to the public that health practitioners have the skills, experience and training to practice in Australia.

Radiographer Dean Brockdorff pleaded guilty and was sentenced in the Local Court of NSW to four counts of holding himself out as a registered practitioner while providing mobile radiography services at four aged care facilities.

Mr Brockdorff was convicted of three of the offences and fined $5,500, and for one offence he was convicted with no further penalty. Mr Brockdorff was also ordered to pay $6,500 in legal costs to Ahpra. 

Charges were also laid against Mr Brockdorff’s employer, Mobile X- Ray Services Pty Ltd, for holding Mr Brockdorff out as a registered health practitioner in contravention of Section 116 of the National Law.

The business pleaded guilty to four counts of holding Mr Brockdorff out as a registered radiographer. On 6 February this year, the business was fined $4,150 and ordered to pay costs of $6,500. 

Ahpra CEO Justin Untersteiner said patient safety depends on practitioners meeting the requirements for registration and employers ensuring that registration is current.

‘Working while unregistered is not a paperwork error, it can be a criminal offence,’ Mr Untersteiner said.

‘Registration signals that a practitioner has the skills, experience and training to practice in Australia and is meeting the highest safety and quality standards.

‘It is unacceptable for any health practitioner to engage in work when they are not registered. We expect employers to also hold their employees to account to help protect the public.'

Mr Brockdorff’s registration lapsed in April 2021. Despite receiving multiple reminders from Ahpra he did not renew and continued to perform radiography services as an employee of Mobile X-Ray Services over the next two years.

While Mr Brockdorff was registered when he started working for Mobile X-Ray Services in 2020, he provided his employer with a copy of an expired registration certificate from a previous year and an expired radiation user licence. His employer failed to identify the expired registration certificate when employing Mr Brockdorff and then failed to check at any time during the following three years.

An anonymous tip-off to the aged care facilities in May 2023 brought the issue to a head. Mobile X-Ray Services stood down Mr Brockdorff.

There is no suggestion that Mr Brockdorff caused any harm to patients during the period he worked without registration.

In sentencing Mr Brockdorff, Magistrate Danielle Mansour said the offences were serious and involved services provided to vulnerable patients.

‘They deserved and should have had the benefit of the oversight, the licensing and the protection that the associated insurance would have provided,’ Magistrate Mansour said.

‘I have to send a message to everyone that non-compliance with these very strict licensing regimes will not be tolerated because there needs to be the protection of the community.  The community has to trust in there being this oversight, this regime, so they can ensure that they are safe from both injury and also financial consequences.’

Chair of the Medical Radiation Practice Board of Australia, Cara Miller, said this was the first prosecution involving a medical radiation practitioner providing health services while unregistered.

‘Registration as a health practitioner brings both significant privileges and clear obligations. Holding yourself out as a registered practitioner when you are not is a serious breach of the law. It is deceptive and undermines public trust in the profession,’ Ms Miller said.

‘This decision reinforces that National Boards, Ahpra and the courts take registration requirements very seriously.

'Patients and the community rely on registration as a key assurance that health practitioners are qualified, competent and continuously maintain standards of practice when providing safe healthcare services.'

In an unrelated case, a nurse who worked unregistered at two regional health services in NSW has been sentenced to a 12-month community corrections order and ordered to pay $9,000 in legal costs.

The woman had previously been registered as an enrolled nurse but failed to renew her registration, which lapsed in July 2023. Despite receiving multiple renewal reminders, she continued working unregistered.

In August 2023, the woman contacted Ahpra seeking information about how to regain registration. However, she failed to act on the advice and worked for a further 16 months. Her employer identified the lapse during a routine audit in January 2025 and stood her down.

There is no suggestion the woman caused harm to any patients during this period. Due to personal circumstances, the woman is not being named.

In January this year, the woman pleaded guilty in the Dubbo Local Court to one count of holding herself out as a registered health practitioner.

In sentencing the woman, Magistrate Brett Shields said: ‘You became aware that your registration had lapsed and while knowing you were unregistered you continued to work. This was not simply an oversight.’

‘People need to understand the obligation to be registered. The whole point of (the registration scheme) is the maintenance of standards,’ Magistrate Shields said.

Nursing and Midwifery Board of Australia Chair, Adjunct Professor Veronica Casey AM, said the decision sends a strong message that failing to maintain your registration can have serious consequences.

‘Nursing is a trusted profession and holding yourself out as a nurse when you are not registered damages its reputation and undermines the tireless work all nurses do to care for the public,’ Ms Casey said.

‘People place their trust in nurses, and the Nursing and Midwifery Board of Australia makes sure that trust is met.

‘The communities we serve rely on nurses to provide safe and appropriate care and this case provides a timely reminder to patients that they can check the register of practitioners to see if the person they are receiving treatment from is registered.’

Anyone with concerns about whether a health provider is registered can check the online Register of practitioners maintained by Ahpra or call 1300 419 495.