Advertising higher risk non-surgical cosmetic procedures

The guidelines set out the types of advertising of higher risk cosmetic procedures performed by registered health practitioners that will breach section 133 of the National Law.

Higher risk non-surgical procedures may be advertised by:

• registered health practitioners
• individuals who are not registered health practitioners, and
• business, partnerships and corporate entities.

For registered health practitioners, the guidelines also establish professional expectations of National Boards in relation to advertising higher risk non-surgical cosmetic procedures.

The guidelines apply to higher risk cosmetic procedures which are defined in the guidelines.

Examples of higher risk cosmetic procedures include but are not limited to dental veneers, the administration of cosmetic injectables such as botulinum toxin¹ and dermal fillers, (also known as soft tissue fillers), injection lipolysis, thread lifts, sclerotherapy and microsclerotherapy, procedures involving platelet rich plasma, biotherapy or injections of any products derived from the patient’s blood and hair transplants.

No. The Guidelines for registered medical practitioners who advertise cosmetic surgery apply to the advertising of cosmetic surgery.

No. It is not possible to provide an exhaustive list of higher risk cosmetic procedures. The cosmetic procedures industry is constantly evolving. As this innovation continues to transform the cosmetic procedures space new higher risk cosmetic procedures may also be developed and performed by registered health practitioners.

To decide whether a procedure is a higher risk non-surgical cosmetic consider the following factors:

• is the dominant purpose of the procedure to achieve a more desirable appearance?
• is a registered health practitioner required to perform the procedure or an aspect of the procedure?
• is the procedure restricted to a particular profession², does it require an authorisation only available to certain registered health practitioners³ or does it require a level of anatomical, physiological and/or pharmacological knowledge which mean that the cosmetic procedure can usually only be safely performed by a registered health practitioner?
• does the procedure require the use of a prescription-only medication, significant alteration of bodily structures, involve the injection of medicines and/or products into and under the skin or does it involve penetration of the deeper dermis?

Registered health practitioners advertising higher risk non-surgical cosmetic procedures need to review their existing advertising, including their website and their social media accounts to ensure that from 2 September 2025, all advertising (including past posts) complies with the new guidelines.

You may need to amend or remove content that does not comply and/or add content to ensure all the requirements for information on registration details, professional memberships, risks, recovery outcomes, and relevant warnings outlined in the guidelines is included.

The guidelines only apply to higher risk non-surgical cosmetic procedures because:

• the guidelines take a risk-based approach in relation to the advertising of a cosmetic procedure and are focused on those more likely to be advertised by or on behalf of registered health practitioners
• we recognise that other cosmetic procedures are lawfully provided and advertised by non-registered individuals. However, the public are likely to have greater expectations of a registered health practitioner performing a cosmetic procedure
• higher risk procedures have unique features and specific risks both in the performing and advertising of them
• higher risk cosmetic procedures may be invasive and can cause complications or harm to the patient which may be irreversible
• higher risk cosmetic procedures are often sought by people experiencing vulnerability.

No. Testimonials are not permitted in any advertising of a regulated health service.

A testimonial is a positive recommendation or statement about a clinical aspect of a regulated health service, whether expressed by a patient, a social media influencer or any other person.

In advertising of higher risk cosmetic procedures, any statement or recommendation about the experience of, reason for, or outcome of a higher risk cosmetic procedure, and/or the skills or experience of the registered health practitioner would be considered a reference to a clinical aspect of the higher risk cosmetic procedure and therefore is considered a testimonial. This is because the dominant purpose of a higher risk cosmetic procedure is a revision or change to appearance.

Comments that do not refer to clinical aspects of a regulated health service (e.g. customer service) are not considered testimonials.

Do not include testimonials in your advertising.

If a social media platform is used to promote a regulated health service, such as a clinic’s Facebook page, it is considered advertising and must not include testimonials or purported testimonials.

Specific tips to help make sure your advertising is compliant with the requirements around testimonials include:

• removing any testimonial that is part of your advertising. This includes removing any testimonials a person may post on your social media page
• not linking to testimonials on third party sites or review platforms
• not sharing, liking or re-tweeting any images or comments made by a person about a non-surgical cosmetic procedure provided by you on a third-party website. Sharing or re-tweeting the comment could be considered advertising as it may promote you and your service
• not interacting with a review, such as liking a patient’s social media post.

Yes. Social media can be used for advertising higher risk cosmetic procedures as long as you comply with the Guidelines for advertising a regulated health service, and from 2 September 2025, the Guidelines for advertising higher risk non-surgical cosmetic procedures.

Any of the below would be considered advertising:

• a registered health practitioner, or their business posts content on their own social media accounts
• a registered health practitioner authorises someone to post content on their behalf (e.g. staff member, a third party or marketing agency) on the registered health practitioner’s, or their business’s social media accounts
• a registered health practitioner or their business pays for posts on a third-party account, and
• a registered health practitioner or their business compensates an influencer to post on social media.

For more information about social media see the Ahpra and National Boards’ guidance on social media.

Yes.

It may not be possible to provide full details about risks or potential risks of higher risk non-surgical cosmetic procedures. In this case the advertising should direct the public to the location of the information about risks or potential risks, for example, through a link or directions to the section of the website that contains the information.

While the guidelines do not prohibit the use of influencers, there are a number of things to consider before using an influencer to advertise higher risk non-surgical cosmetic procedures.

• The Guidelines for registered health practitioners who perform non-surgical cosmetic procedures state that health practitioners must not provide free or discounted procedures to patients, including influencers, for promotion of cosmetic procedures or services.
• Registered health practitioners or other advertisers who enter into any arrangements with influencers, or similar individuals are responsible for the advertising content they deliver and must ensure that any advertising produced complies with the Guidelines for advertising a regulated health service, and from 2 September 2025, the Guidelines for advertising higher risk non-surgical cosmetic procedures.
• In advertising higher risk non-surgical cosmetic procedures, any statement or recommendation about the experience of, reason for, or outcome of the cosmetic procedure, or the skills or experience of the health practitioner would be considered a reference to a clinical aspect of the higher risk cosmetic procedure, and therefore is considered a testimonial and is not allowed.

No. By tagging the clinic the post will become visible on the clinic’s social media pages and therefore become part of the clinic’s advertising. In advertising of higher risk non-surgical cosmetic procedures, any statement or recommendation about the experience of, reason for, or outcome of the cosmetic procedure, or the skills or experience of the registered health practitioner would be considered a reference to a clinical aspect of the higher risk cosmetic procedure, and therefore is considered a testimonial and is not allowed. Learn more about testimonials.

No. Ahpra cannot give you advice or an opinion about advertising and cannot check or pre-approve your advertising.

This is because as a statutory regulator our role is to enforce the law and we cannot provide legal advice to advertisers about how to advertise.

The guidelines are intended to support you to comply with your obligations by making expectations clearer and providing examples of unacceptable advertising.

Ahpra and National Boards have also developed resources to help advertisers comply with the advertising requirements. These resources can be found in the Advertising hub.

If you need advice about whether your advertising complies with the National Law, you may wish to seek advice from your professional association, an independent legal adviser or professional indemnity insurer.

‘Before and after’ images must:

• not feature images of people under 18 years of age
• be used responsibly to provide only realistic information about the outcome of the higher risk cosmetic procedure performed
• be actual patients who have had a higher risk cosmetic procedure performed by the registered health practitioner advertising
• not present the ‘after’ image as the most prominent image as this may create unrealistic expectations.

There is also more guidance in the Guidelines for advertising a regulated health service for the requirements for ‘before and after’ images.

Registered health practitioners also need to comply with the Therapeutic Goods Administration (TGA) requirements. See the TGA guidance on advertising a health service for additional information.

Stock photos will only be suitable in advertising when it is clear that the image is not an outcome of a higher risk non-surgical cosmetic procedure.

Advertisers need to be careful that images used do not give the impression they show the outcome of a higher risk non-surgical cosmetic procedure when this is not the case.

Examples of misleading images include airbrushed, soft-filter or modified images where these modifications remove wrinkles, smooth complexions or otherwise attempt to portray a ‘perfect’ outcome, and the use of models or celebrities where it is not established that the model or celebrity had undertaken the higher risk cosmetic procedure.

To avoid being misleading or deceptive, advertising should be factual and accurate. Advertisers should consider the overall impression of their advertising, including:

• who the audience is
• what the advertisement is likely to say or mean to them, and
• how easy it is for the audience to understand the advertising.

Any person or organisation can make a complaint to Ahpra if they have concerns about the advertising of a regulated health service. When we receive a complaint, we will review the advertising, complete a risk assessment and take appropriate action to protect the public. See how we manage advertising complaints for more information about the complaints process for breaches of the advertising requirements.

No, National Boards regulate registered health practitioners so the guidelines only apply to the parts of the beauty industry which involve registered health practitioners.

No. Ahpra and the National Boards can only regulate registered health practitioners performing procedures in Australia and advertisers advertising a regulated health service provided in Australia.