The New AHPRA Prescribing Rules for Cosmetic Injectables: What Every Injector and Prescriber Must Know
Hi Facecoachers,
The prescribing expectations around cosmetic injectables have changed, and the practical message is straightforward:
Every prescription must be individualised, clinically justified and supported by a real-time consultation.
That means no script generated from an online questionnaire when the prescriber has never spoken with the patient. No one prescription covering a clinic list. No “set and forget” repeats without a proper review.
The AHPRA guidelines for non-surgical cosmetic procedures were issued on 2 September 2025 by all National Boards except the Medical Board of Australia.
A useful distinction is important here.
Medical practitioners are not covered by this particular multi-board document. Doctors must follow the Medical Board of Australia’s equivalent guidelines for registered medical practitioners who perform cosmetic surgery and procedures.
For nurses and other registered health practitioners, the 2025 AHPRA guidelines apply directly. For doctors, the equivalent Medical Board requirements apply.
Section 3: A real-time consultation is required every time
Section 3 is the part most likely to affect day-to-day clinic workflows.
A prescriber authorised to provide prescription-only cosmetic injectables must conduct either:
An in-person consultation; or
A live video consultation
each time they prescribe a cosmetic injectable.
This is not limited to the first consultation.
A patient completing a form, uploading photographs or answering an online questionnaire does not replace a real-time consultation where the prescriber has never spoken with them.
AHPRA describes this as asynchronous prescribing. Prescribing by text, email, online questionnaire or equivalent, without a real-time consultation, is not acceptable practice.
What this means for your clinic
If your clinic still uses an online questionnaire to generate a script before the patient has ever spoken with the prescriber, that process needs to stop.
We suggest building a scheduled, real-time consultation into the workflow for every prescription, including repeat treatments.
You also need to understand the rules around repeat prescriptions in your state or territory. Section 3 specifically requires prescribers to know and comply with relevant drugs and poisons legislation.
There is another clear prohibition:
Bulk or batch prescribing is not acceptable.
One prescription cannot cover multiple people on a clinic list. Every patient must have an individual prescription based on their own assessment and consultation.
Section 2: Patient suitability comes before the prescription
A prescription is only one part of the decision. Before that, the patient must be assessed for suitability.
Section 2 requires an evidence-based and holistic assessment. This should consider:
Relevant medical and treatment history
Psychological factors
Social and cultural factors
The person’s reasons and motivation
Their expectations of the procedure
Any condition that may make the procedure unsuitable, including body dysmorphic disorder
Alternative options, including not having the procedure
This is interesting because the assessment is not simply a checklist of contraindications.
You need to understand why the person is requesting treatment. Is the motivation internal, such as strong feelings about appearance? Is it external, such as pressure from a partner, family member, workplace or social media?
Expectations must also be realistic. If the likely outcome will not align with what the patient expects, the correct clinical decision may be to decline treatment.
The guidelines are clear: a practitioner must decline to perform a cosmetic procedure or prescribe a cosmetic injectable if, following assessment, they believe it is not appropriate.
Where there are concerns about a significant psychological issue or other underlying condition, the patient must be referred to an appropriate registered health practitioner before treatment.
That referral must be genuinely independent of the person intending to perform the procedure or prescribe the injectable. The referred practitioner should not work in the cosmetic industry.
For nurses, there is an important boundary: only registered nurses or nurse practitioners can undertake the patient suitability assessment outlined in Section 2.
Section 7: The prescriber remains responsible for post-procedure care
A common clinic arrangement is for one practitioner to prescribe and another practitioner to administer.
That arrangement does not remove the prescriber’s responsibility.
Under Section 7, where a prescription-only cosmetic injectable is administered by someone other than the authorised prescriber, the prescriber remains responsible for the management of the person, including appropriate post-procedure care.
The administering practitioner must inform the prescriber of any concerns relating to the administration or post-procedure care.
If the prescriber or administering practitioner will not be personally available, alternative arrangements must be:
Made in advance
Documented
Assigned to a suitably qualified and supervised registered health practitioner
Explained to the patient
Communicated to relevant treating practitioners
Your written aftercare instructions should include:
The prescriber’s contact details
The injector’s contact details
The contact details of the practitioner coordinating care, if different
A nominated back-up contact
The product name and relevant details
The procedure performed
The usual range of post-procedure symptoms
Escalation points for unusual pain or symptoms
Medication, activity and self-care instructions
Follow-up dates and details
We suggest mapping this responsibility before the day of treatment, not during an emergency.
For all botulinum toxin treatments, consent and aftercare materials should also include a clear four-week symptom window for iatrogenic botulism, along with written instructions about symptoms that require urgent escalation. Written aftercare must be provided for every botulinum toxin treatment.
Section 6: Schedule 4 and TGA compliance
Cosmetic injectables are not outside the usual medicines framework simply because they are used for aesthetic purposes.
Practitioners must comply with the relevant state or territory drugs and poisons legislation, including requirements relating to:
Prescribing
Supply
Storage
Transport
Records
Permits and authorisations
Administration
The Therapeutic Goods Administration also regulates therapeutic goods in Australia.
Section 6 makes it clear that administering or advertising unapproved or unregistered products is unlawful unless an exemption applies. Practitioners need to verify the status and lawful supply pathway of every product used.
In practical terms, clinics should use TGA-approved or otherwise appropriately authorised substances, maintain clear product documentation and ensure staff understand the difference between approved, compounded, exempt and unregistered products.
Section 9: Education, experience and cosmetic injector compliance training
Section 9 sets a minimum expectation for education and competence.
Training should include:
Relevant anatomy and physiology
Assessment of patient suitability
Theoretical education in the specific procedure
Hands-on training in the specific procedure
Demonstration and assessment of competence
Recognition and management of side effects and complications
Post-procedure care
This applies to both prescribing and performing cosmetic procedures.
A certificate alone does not automatically establish competence. You need to be able to demonstrate that your education, training, experience and scope of practice support the procedures you provide.
All registered health practitioners whose scope includes cosmetic procedures must also undertake CPD related to cosmetic procedures.
We suggest keeping cosmetic-specific CPD in a dedicated portfolio. General nursing or medical CPD is valuable, but it does not replace education directly related to cosmetic procedures, complications, patient suitability and governance.
The third edition of the National Prescribing Competencies Framework
The third edition of the National Prescribing Competencies Framework was published in September 2025 following a review of the 2021 second edition.
It applies to all prescribers, regardless of their professional background or practice setting.
The most significant addition is a new competency addressing the prescribing of:
Unapproved therapeutic goods
Compounded products
Medicines for unregistered indications, commonly referred to as off-label use
The updated framework also expands on:
Shared decision-making
Person-centred care
Capability and limited capacity
Transitions of care
Cultural safety
A prescriber using an off-label, compounded or unapproved product must be able to justify the decision, understand the evidence and risks, communicate appropriately with the patient and document the reasoning.
This aligns closely with the AHPRA cosmetic guidelines. Prescribing is not simply the act of writing a script. It is a dynamic process of assessment, decision-making, communication, monitoring and review.
NSW compliance: prepare before 5 November 2026
NSW’s new Medicines, Poisons and Therapeutic Goods Regulation 2026 commences on 5 November 2026.
It reinforces several principles relevant to cosmetic medicine, including:
Prescribers must personally review patients before issuing a written direction, either in person or by video
Clinics must use TGA-approved substances
Batch-level administration records must be retained for two years
Products must be stored securely and not in public areas
Clinic owners and prescribers share accountability for clinic governance
If you practise in NSW, now is the time to review your prescribing, storage, records, delegation and emergency arrangements.
A practical compliance checklist
Before your next clinic list, check that you have:
A real-time in-person or video consultation for every prescription
Individual prescriptions for every patient
A documented suitability assessment
A process for identifying BDD and unrealistic expectations
Independent referral pathways outside the cosmetic industry
A clear prescriber-injector responsibility matrix
Documented back-up arrangements for post-procedure care
Written aftercare naming the prescriber, injector and back-up practitioner
Consent materials covering risks, alternatives and the four-week botulism symptom window
TGA and state or territory product compliance checks
Batch-level administration records
Cosmetic-specific CPD evidence
Current training and competence records
Correct RN and EN supervision arrangements
Building stronger governance through education
For practitioners who want a structured approach, the Monash University course Patient Suitability, Governance, Compliance and Ethics of Non-Surgical Cosmetic Medicine is designed for AHPRA-registered doctors and nurses.
It is a 12-week, fully online intensive involving 144 notional hours and Monash University certification.
The eight modules cover:
Advertising legislation
AHPRA and NMBA guidelines
Body dysmorphia assessment
State, council and poisons legislation
Patient consent
Ethics
National governance frameworks
Basic clinical assessment of suitability for lasers, botulinum toxins and soft tissue fillers
The next intake begins on 1 February 2027.
You can review the course details here. Use the code FIRST50STUDENTS where applicable.
The aim is not to make cosmetic practice more difficult. It is to make patient selection, prescribing, treatment and follow-up more defensible, consistent and safe.
That is good for patients, good for practitioners and good for the future of cosmetic medicine.
Mike Clague
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