7 minute read
An Industry in Turmoil: A Turning Point for Cosmetic Medicine in Australia
By Nicole Montgomery, Guest Editor.
I’ve had the unique privilege of working in the aesthetic industry for over two decades—first as a registered nurse, and now as a marketing strategist supporting clinics and brands nationwide. But nothing I’ve experienced quite compares to the seismic regulatory shifts we’re currently facing.
As I write this, the cosmetic medicine landscape is undergoing the biggest transformation in its history. The combined force of recent AHPRA and TGA regulatory changes has left many clinic owners, injectors, and even patients feeling uncertain, overwhelmed, and in some cases, angry.
At the most recent Aesthetic Business Masters event, we were fortunate to hear from Robin Curran, a compliance consultant and expert who delivered an eye-opening session titled “Compliance in Action.” It was Robin’s presentation that inspired this article. This feature is not a rant. Nor is it an endorsement of any one point of view. It is a clear-eyed look at the reality we face, an exploration of the rules reshaping our work, and a call for collaboration, education, and adaptation.
AHPRA Guidelines: Redefining Cosmetic Medicine
On 3 June 2025, AHPRA released two critical documents:
• Guidelines for registered health practitioners who perform non-surgical cosmetic procedures
• Guidelines for advertising higher risk non-surgical cosmetic procedures These guidelines represent the most extensive compliance reform the industry has seen. Here’s what you need to know:
Comprehensive Patient Consultations
Practitioners are now required to:
• Conduct real-time suitability assessments (no text or asynchronous consults)
• Screen for psychological conditions, including Body Dysmorphic Disorder (BDD)
• Ensure decisions are based on informed motivations—not external pressures
• Allow cooling-off periods for minors and high-risk treatments
• Asynchronous Prescribing is Banned
All prescribing for Schedule 4 medications must be done via real-time video or in-person consults—no emails, DMs, or batch prescribing.
Tightened Scopes of Practice
• Enrolled nurses must be directly supervised by RNs and complete relevant upskilling
• Midwives and dental nurses must not work beyond their general registration scope
• Only doctors and nurse practitioners may prescribe S4s—and only after consults
Documentation & Training
• All practitioners must undergo training in complications management, scope of practice, and ethical advertising
• Post-procedure care plans must include emergency contacts, batch numbers, and medication logs
These requirements are designed to elevate clinical standards, reduce adverse outcomes, and enhance patient safety through rigorous assessment and oversight. Importantly, the guidelines make clear distinctions between elective cosmetic enhancement and therapeutic medical care—urging practitioners to maintain transparency in their patient interactions and promotional activities.
TGA Advertising Changes: What You Can and Can’t Say
The TGA’s crackdown on cosmetic advertising has left marketers scrambling to remove thousands of social media posts. Here’s what’s now prohibited:
• Mentioning brand names of prescription-only injectables
• Referring to “anti-wrinkle” or “dermal filler” in promotions
• Using before-and-after images linked to prescription treatments
• Offering discounts, giveaways, or influencer promotions tied to scheduled medicines
• Advertising price promotions for these treatments
The TGA reinforced that prescription medicines are not consumer goods and must not be presented as such.
Some clinics have had to pause their marketing entirely while legal counsel and compliance teams review their operations. Several practitioners I’ve spoken to have deactivated websites and social accounts altogether to avoid breaching the guidelines.
Robin Curran’s “Compliance in Action”: A Reality Check
Robin’s presentation was a wake-up call. Her clear, legally grounded session mapped out what ethical, compliant practice looks like in 2025— and it’s not as simple as updating a consent form. She explained how regulations intersect with:
• NSQHS National Standards
• Health Practitioner Regulation National Law (2012)
• State-based Medicines and Poisons Acts
• Cold Chain Compliance
• Privacy Law, Advertising Law, and even flooring requirements
Her biggest message? “Compliance is foundational. You must audit everything.”
One of the most striking comparisons Robin drew was between nurse-led clinics and clinics with medical oversight. It’s not about ego or hierarchy—it’s about future-proofing your clinic against regulatory breaches and risk.
Robin emphasized that the shift is from ‘nice-to-have’ policies to ‘must-have’ frameworks. Every clinic must now act like a mini health service—tracking every medication, documenting every protocol, and recording every patient interaction to ensure traceability and safety.
Case Study: Queensland’s Strict Enforcement
Queensland has become ground zero for compliance enforcement.
Under the Medicines and Poisons Act 2019 and the MPMR 2021, nurse-led clinics face serious limitations:
• S4 products must be prescribed under direct authority and administered under real-time guidance
• Clinics cannot ‘stock and store’ S4s unless they hold an appropriate authorisation
• Dispensing from a pharmacy to a nurse for cosmetic use is considered “selling”—a breach of the law
Several Queensland clinics have already received cease and desist notices, with enforcement actions underway. Robin’s advice? If you’re in Queensland, “review your prescriber arrangements and facility compliance immediately.”
The Practitioner Perspective
In my day-to-day work, I speak with many clinic owners, and they’ve expressed a mix of frustration and determination:
• “I want to be compliant, but I don’t know who to trust for the right information.”
• “I’m worried about patient retention with these new consult restrictions.”
• “It’s hard to rebuild my website from scratch without saying anything clinical.”
It’s hard. But this industry is resilient.
Many are seeking legal advice, hiring compliance consultants, rewriting SOPs, and attending training seminars to ensure their teams are aligned.
I asked Sheri-lee Knoop the president of the Cosmetic Nurses Association her thoughts on the recent updates on the 3rd of June 2025. Here is what Sheri-lee had to say;
“The latest update to guidelines come after a long wait since the last consultation process. The CNA welcomes the clarity around required waiting times before entering the Aesthetics area of medicine and of required formal education for all health care professionals. The lack of clarity around what education that is exactly, is disappointing but understandable.
It will take time to clarify some points around scope of practise, but the CNA feel that these guidelines provide sensible frameworks in which all Nurses can work compliantly for safer practice for their patients and themselves. It is time as a community to lift our standards across all specialties and stand together for community over competition and patient safety over profits.”
Sheri-lee Knoop, Registered Nurse Board President of the Cosmetic Nurses Association of Australia
From Confusion to Leadership: Where Do We Go From Here?
Robin closed her presentation with the mantra: “Compliance can feel daunting—but it’s not impossible.”
So what’s next? Education
Bookmark the AHPRA, TGA, and state health websites. Stay current. Subscribe to industry newsletters. Attend compliance seminars.
Collaboration
Nurses need accessible prescribers. Clinics need transparent protocols. Partner wisely.
Communication
Educate your patients on why things are changing. Use TGA-compliant language. Trust is built through transparency.
Audit Everything
Start with marketing. Then review policies, scripts, consent forms, and storage protocols.
The Bottom Line
This isn’t just a tough moment—it’s a turning point. We can resist change or lead with integrity.
Let’s choose to lead. Let’s build businesses and brands that thrive because they are ethical, not in spite of it.
By Nicole Montgomery, Registered Nurse and Marketing Consultant
A special thank you to Robin Curran for her leadership and for helping this industry elevate its standards. Thank you to all the professionals pushing through this transition with courage, clarity, and community.
For further reading and full regulatory details, visit:
• AHPRA Guidelines (2025)
• TGA Statement on Cosmetic Advertising
• Queensland Health Factsheet
