The rules that govern an Australian aesthetic clinic come from four different regulators. Here is what each one actually requires, in plain English, with a link to the source.
Most breaches are not deliberate. They are a busy clinic repeating something that was fine two years ago, or copying a post from an overseas practice. The rules moved materially in March 2024 and again in September 2025, and they change again in New South Wales on 5 November 2026. This page summarises what applies today and points to the primary source for every rule, so you can check it yourself rather than take anyone's word for it.
Clinic owners tend to hear "compliance" as a single thing. It is four, with four different regulators, and a change that satisfies one may do nothing for another.
The TGA, under the Therapeutic Goods Act 1989, governs what you may say in public about prescription-only products. AHPRA and the National Boards govern two separate things: how a procedure is assessed, consented and recorded, and separately how it may be advertised. State medicines and poisons law governs who may hold stock, how it is stored, and what has to be written down. Privacy law sits across all of it and sets how long you keep records.
The practical consequence: an advertisement can be perfectly fine under AHPRA and still breach the Therapeutic Goods Act, and a clinic can have immaculate clinical records and still be advertising unlawfully.
Prescription-only medicines cannot be advertised to the public in Australia. That has always covered brand names and the active ingredient. What changed in March 2024 is that the TGA stopped permitting the indirect terms most clinics had settled on.
In the TGA's own words, advertising must not refer to prescription-only goods "including by referring to these in generic terms", and this "includes through acronyms, nicknames, abbreviations and hashtags". Business names and signage are caught by the same reasoning. Adding a disclaimer that the content is educational does not discharge the obligation.
Public price lists and bookable service menus that name these products are the most commonly enforced version of this. The compliant pattern is to advertise the consultation rather than the product, and to let the specific product be named only inside the consultation and the clinical record.
One nuance worth knowing: the restriction attaches to prescription-only substances, so it does not apply to treatments that contain none.
Read the TGA's own FAQAHPRA's advertising guidelines for higher-risk non-surgical cosmetic procedures took effect on 2 September 2025 and apply to every profession, including doctors.
Testimonials are not permitted at all in advertising these procedures. That extends further than most clinics expect: you may not link to testimonials on third-party sites, re-share a patient's post, or even like or reply to a positive review. The guidelines suggest disabling reviews, comments and tagging on your own pages. If you work with influencers or ambassadors, their content is your responsibility.
Before-and-after images must be of your own patients, unedited, with matched lighting, angle, framing, posture and makeup, and must state how long after the procedure the image was taken. The first or most prominent image must be the "before", or a composite. A prominent warning that outcomes shown apply only to that patient is required. Images of anyone under 18 may not be used, and advertising must not be directed at under-18s.
Where an advertisement names the practitioner performing the procedure, it must include their registration details, including the registration number.
Read the AHPRA advertising guidelinesThe companion guidelines, for practitioners performing non-surgical cosmetic procedures, also took effect on 2 September 2025. Medical practitioners have had equivalent obligations under the Medical Board's guidelines since 1 July 2023.
Assessment must be holistic and evidence-based, and must screen for underlying psychological conditions including body dysmorphic disorder. If a red flag appears, the patient should be referred to an independent practitioner before anything proceeds. For nurses, that suitability assessment sits with registered nurses and nurse practitioners only.
A prescriber must have an in-person or video consultation with the patient each time they prescribe. Prescribing by text, email or online form is explicitly not acceptable practice, and every patient needs their own prescription.
Consent must be both a verbal discussion and written information in plain language, documented, with a copy of the signed form given to the patient. Consent to use images in advertising has to be separate from consent to the procedure.
For anyone under 18 there must be a cooling-off period of at least seven days between informed consent and the procedure, and no money should be payable until after it, beyond an initial consultation. The Boards' position is that these products should not be prescribed for cosmetic purposes to under-18s at all.
Read the AHPRA procedure guidelinesThis is the part that varies most by state, and the part that has caught the most clinics out recently.
In Queensland, health authorities clarified in 2025 that a registered or enrolled nurse cannot buy or hold stock of Schedule 4 cosmetic injectables, and that a prescriber who buys stock must have exclusive custody and control of it at the clinic where it is used. Stock cannot be lent to a clinic the prescriber does not practise from. Queensland Health describes this as a clarification of existing law rather than a new rule, which is precisely why it caught people by surprise.
On scope of practice, enrolled nurses must work under the supervision of a registered nurse, and supervision by a doctor does not satisfy that requirement. Enrolled nurses must not inject dermal filler into the very high-risk areas, and may only treat other high-risk areas with immediate on-site access to the prescriber or a registered nurse. Registered nurses need at least one year of full-time equivalent practice after registration, in something other than cosmetic procedures, before working in this area.
Queensland Health on cosmetic injectablesThe Medicines, Poisons and Therapeutic Goods Regulation 2026 commences in NSW on 5 November 2026 and introduces a dedicated regime for what it calls cosmetic use substances. It names eight Schedule 4 substances, which between them cover the standard injectables menu.
A medical practitioner or nurse practitioner giving a direction must have personally reviewed the patient, in person or by audiovisual link, and must give that direction in writing and sign it. A written direction has effect for no more than six months from the date of that review. The direction itself has a prescribed field list, including the premises where the substance will be administered and, for each administration, the substance, the area of the face or body, the route and the quantity.
The part most clinics will feel is the administration record. For each administration the nurse must record their own name, the date, the batch number of the substance, and a set of details carried over from the direction, then give a copy to the prescriber and to the business responsible for the premises. Stock must be stored in a room the public cannot access and kept apart from other goods.
If you operate in NSW, this is the single change worth preparing for now rather than in November.
Read Part 9 of the NSW regulationThe AHPRA guidelines require the record of a procedure to be detailed enough that another practitioner could take over post-procedure care and understand what was done. Written post-procedure instructions given to the patient must name the prescriber and the products used.
Retention is set by state law, not by AHPRA. New South Wales, Victoria and the Australian Capital Territory each have a health records Act that binds private clinics, and the commonly applied rule is seven years from the last service for an adult, or until the patient turns 25 for a minor. In Queensland, Western Australia, South Australia, Tasmania and the Northern Territory there is no equivalent private-sector statute, so the Commonwealth Privacy Act applies and the seven-year convention is professional best practice and insurer expectation rather than a fixed legal minimum.
Recording batch and expiry against the individual patient is, outside NSW from November, best practice rather than a general legal requirement. It is still worth doing: if a product is recalled or an adverse event is reported, the batch number is the first thing anyone will ask for.
Guidance changes, and secondary summaries go stale quickly, including this one. These are the sources worth bookmarking and checking directly.
The TGA's advertising FAQ covers what may and may not be said. AHPRA's cosmetic surgery hub holds both sets of guidelines, for performing and for advertising. Your state health department publishes the poisons rules that decide who may hold and administer stock. For a specific question about your clinic, a medical indemnity insurer or a health law practitioner will give you an answer you can rely on; this page will not.
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