Cosmetic law changes for 2025 and what they mean for clinics

Australia’s cosmetic sector has been reshaped over the past two years. The Medical Board of Australia has tightened the standards for cosmetic surgery, the TGA has clarified how injectables can be advertised, and AHPRA has introduced national guidance for higher risk non-surgical cosmetic procedures. For clinics and marketing teams in Victoria, this is now the everyday rulebook for assessment, consent, prescribing, aftercare and advertising.

The purpose behind the reforms is patient safety and truthful communication. Regulators want decision-making that is clinically led, consent that is informed rather than rushed, and advertising that avoids hype or ambiguity about risks. Taken together, the changes raise the floor for practice across the board and reduce the chance that marketing gets out ahead of clinical governance.

Key expectations for non-surgical cosmetic procedures

AHPRA’s 2025 guidance sets a single national baseline for higher risk non-surgical services such as cosmetic injectables, threads and platelet-rich plasma. Practitioners are expected to assess the whole person, not just a body part or a photo. That includes screening for body image concerns and referring for independent evaluation when red flags appear. Consent should be a genuine conversation that explains benefits, limits and risks in plain language, supported by written information the patient can take away.

For minors, the threshold is higher again. Cosmetic use of botulinum toxin or dermal fillers is inappropriate for people under eighteen, and cooling-off expectations apply to other non-surgical procedures. Records should clearly show who assessed the patient, who prescribed, who treated and how escalation will work if complications occur.

Prescribing is now tighter. Each time a prescription-only injectable is used, there must be a real-time consultation with the prescriber in person or by video. Asynchronous tick-and-flick approvals are not acceptable, and batch prescribing is out. The prescriber is responsible for coordinating care and for ensuring that complications can be recognised early and managed quickly.

Nursing roles are clarified. Registered and enrolled nurses must work within their education, competence and supervision arrangements. Clinics should document how competence is assessed and maintained, rather than assuming that a short course equals readiness. The supervising prescriber remains responsible for clinical governance and timely handover paths if a case needs escalation.

What the TGA expects in advertising for injectables

Since 2024 the TGA has treated indirect references to prescription-only medicines as advertising those medicines. That means familiar phrases that point the audience to Schedule 4 products, such as anti-wrinkle injections or dermal fillers, are not safe to use in ads, price menus, websites or social posts. Testimonials about clinical outcomes and influencer promotions that directly or indirectly promote prescription medicines are also off limits. The safest approach is to advertise the service in general terms, provide balanced information about risks and recovery, and keep medicine names and implied references out of your consumer-facing copy.

Cosmetic surgery standards still apply

The Medical Board’s 2023 standards continue to govern surgery done for cosmetic reasons. A GP or specialist referral is required and should be independent of the operating doctor. There is a stronger consent pathway, mandatory psychological screening to identify concerns such as body dysmorphic disorder, and a cooling-off period before booking or taking a deposit. Surgery must occur in appropriately accredited facilities, and your advertising must be realistic and clinically balanced.

Titles and truth in marketing

Only certain specialist doctors can describe themselves as surgeons. Using the title without the approved specialist registration can attract regulatory or legal action. The simplest way to reduce risk is to describe qualifications precisely, list the issuing body and year, and avoid titles that suggest accredited surgical training where that training has not occurred.

How a healthcare lawyer can help

This mix of AHPRA, TGA and Medical Board obligations sits at the intersection of medical law and marketing law. A healthcare lawyer can review your patient journey from first enquiry to aftercare, check your prescribing and supervision protocols, and align your website, socials and paid media with the current rules. If you need local support, our health law firm can help you translate the guidelines into workable clinic routines. If you prefer to speak to a practitioner who lives and works locally, you can ask for a healthcare lawyer Melbourne based. We also advise practitioners who want a lighter touch review and prefer a practical medicolegal lawyer or medico-legal lawyer lens over a purely technical one.

Practical next steps for clinics

Begin by mapping your services so you know which guidance applies where. Build a simple intake script that captures referral and screening steps for surgery and ensures that every prescription-only non-surgical treatment links to a same-day prescriber consultation. Refresh your aftercare handouts and escalation plan so everyone on the roster knows what to do if a patient calls in distress. Finally, rewrite your web pages and ad templates to remove implied references to S4 medicines, identify the registered practitioner who will provide the service, and avoid content that trivialises or sexualises procedures or targets people under eighteen.

The takeaway is straightforward. The sector is moving toward a safety-first model with consistent national expectations. Teams that treat the guidelines as a design brief for their patient journey will adapt quickly and reduce regulatory risk. Teams that try to fit the old model into the new rules will find that both their copy and their clinical processes work against them.

If you are unsure which rule applies to your service mix or how to bring your marketing into line, get tailored advice from NorthBridge Legal your Health & Medical Law Lawyer before you publish another post or place another ad.