What you really need to know about new cosmetic guidelines
The health regulator’s attempt to crack down on the cosmetics industry has made a glaring omission, according to industry insiders who describe it as a missed opportunity.
The Australian Health Practitioner Regulation Agency has released long-awaited and overdue updated guidelines for accredited health professionals who work in non-surgical aesthetics, in a move it says is designed to put the “cosmetic industry on notice”.
But many who work in aesthetics are viewing the updated guidance as a missed opportunity.
The most notable changes appear to be around training and advertising. Registered nurses will be required to complete 12 months’ general nursing experience before being able to practise in cosmetics.
They also will need to undertake further practical and theoretic training specific to cosmetics to prove they have an understanding of facial anatomy and how to deal with complications from cosmetics gone wrong. The changes will come into effect in September.
Currently, a health practitioner such as a nurse has been able to work in cosmetics so long as they graduate and gain their registration. It means some people have gone from university straight to injecting with perhaps only a two-day training course that is not accredited and they have no practical experience dealing with medical emergencies.
However, the new guidelines stop well short of what many working in aesthetics say is desperately needed: recognised minimum training standards and quality assurance of training.
Australasian Society of Aesthetic Plastic Surgeons president Dr Lily Vrtik describes it as alarming.
“A critical area for urgent improvement is continuing professional development,” she says.
“These new guidelines now stipulate that CPD should be in the area of their practice but, alarmingly, there is no minimum quality standard for the CPD educational activity and no plan for enforcement.”
It essentially means that while health practitioners must now undertake more training, as of yet there is no way to check if the training is adequate.
Dr Ritu Gupta, a specialist medical and cosmetic dermatologist who works in aesthetics, shares Vrtik’s concerns.
“There’s actually no guidelines around what that training should look like,” she says.
“It just says it should be determined by the people working in this sector and it should apply to their specialty.
“It does not seem clear as to how these changes are going to be enforced or how they are going to be checked. I think it falls short of what the public could hope that the regulator would provide. There needs to be a minimum training standard.”
Another doctor summed up the guidelines as being “business as usual”, with a couple of small exceptions.
As the regulator notes, aesthetic medicine is now a multibillion-dollar industry. Often it is the pharmaceutical companies that also happen to sell nurses or injectors the restricted injectables, and offer paid prescribing services via telehealth, that also then offer them the training.
Sheri-lee Knoop is a registered nurse and president of the Cosmetic Nurses Association. She says change has been needed for a long time.
“There’s not a lot in these guidelines that have changed,” she says. “There are a couple of changes in scope of practice that need more clarification, I believe, but in time that may become more clear.”
She says the guidance could have gone further and provided clarity on recognised training standards.
“The missed opportunity is this mention of appropriate training,” she says.
“The CNA believes that training is the essence of increasing patient safety, so increasing the opportunity for drilling down into what that is, really is what was needed. However, we understand what a mammoth task that really is.”
Part of the complication is that cosmetics is not a recognised medical specialty, so there is no particular medical college or group responsible for it. That makes setting minimum training standards complicated. It also makes regulating the training being offered next to impossible and is why so many are sceptical of these guidelines.
“There are still little grey areas and I understand why, because it’s very difficult in terms of education,” Knoop says. “However, there’s always going be someone who steps into the grey.”
Her group was not consulted before the release of the guidelines, nor was it told the guidelines would be released on Tuesday. It has left the association scrambling to help nurses understand the changes.
Knoop does say the guidelines, more broadly, are a step in the right direction because they do better align cosmetics to the medical standards already in place for doctors practising in aesthetics. It creates a more even playing field, which is something doctors have been advocating to happen for years.
The other main changes are to advertising. From September, nurses will have to adhere to the same rules and guidelines that doctors working in cosmetics and plastics have had to abide by for the past two years.
As part of that, a ban on the use of testimonials from social media influencers has been tightened and there are new measures to stop the trivialisation or sexualisation of a cosmetic procedure.
The guidelines have been welcomed by the Australian Society of Plastic Surgeons.
“We have been deeply concerned about the risks associated with underqualified practitioners undertaking non-surgical procedures, including dermal fillers and injectables on unsuspecting patients,” society president Dr David Morgan says.
“While AHPRA has established stringent guidelines for medical practitioners, including ASPS members, similar regulations for other health practitioners offering these services have been lacking. The release of these new guidelines will help to address this gap and ensure greater protection for patients seeking non-surgical cosmetic treatments.”
The Australian College of Nursing says the guidelines are a critical step in reinforcing public safety and provide long overdue clarity to nurses.
“Not only can cosmetics sector advertising prey on the insecurities of vulnerable people but it can also create unrealistic expectations,” ACN director of leadership and transformation Jen Harland says.
“It is vital that consumers are fully aware that the administration of injections for cosmetic purposes are medical procedures with attendant risks and dangers.”
Gupta says she too welcomes anything that improves patient safety.
“The difficulty with the aesthetic industry is we’re talking about a lot of money at stake, particularly with corporate clinics,” she says.
“I see patients who perhaps have not had the result that they were hoping for or, even worse, had side effects or issues. The people who are most vulnerable are the young, say 30 or 35. They’re often from a non-English-speaking background who perhaps are less aware about the intricacies of the Australian healthcare system.”
In a statement, AHPRA says it investigated about 360 notifications related to non-surgical cosmetic procedures between September 2022 and March 2025. About 300 of those cases are now closed.
“There have been complaints about medical practitioners, nurses, midwives, dentists, psychologists and Chinese medicine practitioners,” the regulator says in a statement.
“Over 1500 calls have also been made to the cosmetic surgery hotline, informing AHPRA’s regulatory intelligence work, with concerns escalated where necessary.”
This is the latest crackdown on the aesthetics industry and follows a series of changes in Queensland. The drug regulator also has sent a series of warning letters to people who have breached existing advertising rules.
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