What do AHPRA's September 2025 cosmetic-procedure guidelines require of a clinic's marketing?
From 2 September 2025, two AHPRA cosmetic-procedure guidelines sit on top of s.133 — one for advertising, one for performance. They require real, unedited imagery with a results-may-vary warning, ban influencer testimonials and endorsements, ban advertising aimed at under-18s, mandate total-price disclosure, require a pre-procedure consultation, and impose a seven-day cooling-off period for under-18s undergoing non-surgical procedures. Compliance is policed by the standing Cosmetic Surgery Enforcement Unit.
Reviewed 2026-05-03AHPRA — Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures (in force 2 September 2025).
Advertising must … only use real images, and not airbrush or edit images in a way that misleads the public … include a warning that results may vary for other patients … not include testimonials from social media influencers … not be aimed at people under 18 years … include the total price for the procedure, not just initial costs.
Source: AHPRA — Advertising higher risk non-surgical cosmetic procedures
The substance, in plain English.
Imagery rules harden. Every image used to advertise a cosmetic procedure must be real and unedited — no airbrushing, no filters that change the apparent outcome, no AI-generated composites. Where images depict an outcome, a results-may-vary warning must appear with the image. Before-and-after imagery sits on top of these rules and the existing s.133 authenticity conditions (contemporaneous, similarly lit, similarly posed). The intent is that a viewer sees what the procedure actually produced, not a marketing-render of it.
Influencer testimonials and endorsements are banned outright. The prohibition applies whether the post is paid, gifted or unpaid, and applies to social-media creators of any size. Sharing, reposting or quoting an influencer's content about a cosmetic procedure carries the same exposure as commissioning it directly. The ban targets the testimonial-economy infrastructure that the cosmetic sector built between 2018 and 2024.
Advertising aimed at people under 18 is prohibited. "Aimed at" is read on the substance of the creative, the platform, the placement and the offer — not just the literal targeting flag. A TikTok Spark Ad showing a 17-year-old voice-overing a lip-filler journey breaches the rule even if the ad-set targeting is set to 18-plus. The companion performance guideline imposes a mandatory seven-day cooling-off period between consultation and procedure for under-18s, with no money payable until after the cooling-off period (initial consultations excepted).
Total-price disclosure is mandatory. Pricing in advertising must be clear, accurate, and include the total price for the procedure — not just the initial consultation fee or a from-price for one component. Where a procedure is priced per syringe, per area or per session, the advertisement must make the basis of the price obvious enough that a consumer can compute their likely total.
A pre-procedure consultation is mandatory before any higher-risk non-surgical cosmetic procedure. Marketing that implies same-day procedure availability ("walk-in injectables", "book and treat in 30 minutes") breaches the performance guideline. The cosmetic-surgery hub specifies GP referral as a prerequisite for cosmetic surgery; the September 2025 overlay extends the consultation discipline to higher-risk non-surgical procedures.
Maximum penalty: Breach of the guidelines is enforced through s.133 (max $60,000 individual / $120,000 corporate per offence) and registration conditions imposed by the Medical Board on individual practitioners..
Recent enforcement under this provision:
- 2025
Guidelines published — 3 June 2025
AHPRA and the Medical, Nursing and Midwifery, Chinese Medicine and Dental Boards jointly published the new cosmetic-procedure advertising and performance guidelines on 3 June 2025, with a 90-day implementation window. They came into force on 2 September 2025.
AHPRA — Booming billion-dollar cosmetic industry on notice with new cosmetic procedures guidelines
- 2024
Cosmetic Surgery Enforcement Unit — standing program
The $4.5M standing enforcement unit had closed 200+ notifications and resolved 147 non-surgical cosmetic notifications by April 2024 — 9 with registration restrictions, 6 formal cautions, 86 closed without action. The unit's hotline received 514 calls in 2023–24.
AHPRA — Cosmetic surgery crackdown closes 200th notification
- 2022
Cosmetic surgery review — recommendations accepted
The Independent Review of the Regulation of Medical Practitioners who perform Cosmetic Surgery delivered 16 recommendations in August 2022, all accepted by AHPRA and the Medical Board. The September 2025 guidelines are the operationalisation of those recommendations on the advertising and performance side.
A worked example.
A Sydney injectables clinic runs a paid Instagram Reel from a creator with 80,000 followers walking through her lip-filler appointment, captioned "Lips from $295 — DM to book today". The clinic's homepage carousel uses lightly airbrushed before-and-after photos, no results-may-vary statement, and the booking flow allows same-day appointments. From 2 September 2025 every element of this campaign is non-compliant: the creator post breaches the influencer-testimonial ban; the from-price breaches the total-price rule; the airbrushed imagery breaches the real-and-unedited rule; the same-day booking breaches the mandatory-consultation rule. The clean version: an unedited gallery with the results-may-vary warning, a total-price-per-area disclosure (e.g. "$595–$895 per 1mL syringe of dermal filler, including consultation"), and a booking flow that enforces a separate consultation before any procedure.
The questions that come next.
Do the September 2025 guidelines apply to surgical cosmetic procedures or only injectables?
The advertising guideline applies to higher-risk non-surgical cosmetic procedures (injectables, certain energy-based procedures, threads). Surgical cosmetic procedures are governed by the existing cosmetic-surgery hub guidelines and the title-protection regime. The performance guideline applies to non-surgical procedures and includes the seven-day cooling-off rule for under-18s and the minimum experience thresholds for nurses.
Can we still post before-and-after photos on Instagram from 2 September 2025?
Yes, with the new conditions. The image must be real and unedited (no airbrushing or filters that change apparent outcome), accompanied by a results-may-vary warning, and the broader s.133 authenticity conditions (contemporaneous, similarly lit, similarly posed) still apply. Caption restrictions remain — no testimonial-style claims about the patient's experience or the clinic's quality.
Does the influencer ban cover all creator content, or only paid posts?
All creator content. The guideline does not turn on whether money changed hands. A gifted treatment in exchange for a post, an unpaid client who happens to have a following, or a reposted user-generated piece all fall inside the prohibition. The legal exposure sits on the practitioner and the clinic, not the creator.
What does "advertising aimed at under-18s" mean in practice?
It is read substantively. The platform mix (TikTok / Snapchat over LinkedIn), the creative (under-18 talent, school-themed seasonality, prom or formal references), the language (younger-coded copy), and the offer (entry-tier pricing, payment plans of a kind that appeal to school-aged audiences) all contribute. Setting the targeting age floor at 18 does not, on its own, take the campaign outside the rule.
How does total-price disclosure interact with per-syringe injectables pricing?
The advertisement must make the basis of the price obvious enough that a consumer can compute their likely total. "From $295" is unlikely to satisfy the rule on its own; "$595–$895 per 1mL syringe (most patients use 1–2 syringes per area)" with the consultation fee disclosed is closer. The intent is to remove the bait-priced front end that the regulator has flagged repeatedly.
Read it for yourself.
Brief us with the regulator already in line one.