AHPRA’s 2025 Cosmetic Reforms: What Doctors Must Know

September 2025 = new AHPRA guidelines which means doctors offering cosmetic procedures are facing a wave of regulatory change; stricter advertising rules, enhanced consent requirements, and cooling-off periods that demand more than just good clinical judgement. For many practitioners, it’s not just about compliance, it’s about safeguarding trust, professionalism, and patient care. At times like these, having the right legal support isn’t optional — it’s essential.

What’s Changing?

Consent and Cooling-Off Periods

  • Mandatory 7-day cooling-off period for all patients (previously only under-18s)

  • Patients must be offered a second consultation before proceeding

  • Strengthened informed consent requirements, including detailed explanation of risks, benefits, and alternatives

  • Enhanced documentation obligations for consent discussions

These changes protect patients from wanting impulsive or emotionally driven procedures, allowing informed decision making during the process of cosmetic changes.

Advertising & Marketing Restrictions

  • Ban on before-and-after photos, testimonials, and time-sensitive promotions

  • Prohibition on language that glamorises results or pressures patients

Misleading advertisement and unrealistic expectations can cause harm for patients and providers. By ensuring advertisement is consistent with medical professionalism it reduces the risks involved in false advertisement surrounding cosmetic procedures. Doctors will remain responsible for third-party marketing content, creating legal risk.

Training & Competence

  • Doctors may only perform procedures within their formal training and proven competence

  • Emphasis on ongoing professional development in cosmetic medicine

Enhancing training requirements protects patient safety and reduces the risk of complications. APHRA requires that only appropriately qualified practitioners perform cosmetic procedures and that practitioners without specialised training are under increased scrutiny.

Treating Patients Under 18

  • Must conduct a mandatory psychological assessment.

  • Must involve parent or guardian in the consent process.

  • Longer cooling-off period required.

  • Treatment must be clearly justified.

Younger patients are more vulnerable to body image and social pressures. Safeguarding minors is a priority to prevent unnecessary or harmful procedures. The legal obligations are strict; non-compliance poses a high legal risk.

Documentation and Compliance Monitoring

  • Practitioners must maintain detailed records of consultations, treatment rationale, risk and consent discussions treatment rationale

  • AHPRA and the Medical Board may audit practitioners for compliance

  • Doctors are responsible for ensuring clinic-wide and third-party compliance

Competent recordkeeping is a practitioner’s first form of protection against any complaints or investigation. APHRA’s emphasis on transparency, continuity of care and audit readiness is a response towards growing customer complaints. Doctors and clinics have a shared legal accountability that shouldn’t end at the procedure.

What Cosmetic Doctors Should Be Doing Now

Preparation is the best way to avoid issues when the reforms come into effect. Practical steps to take include:

  • Audit your current practices: Review your consent processes, patient onboarding forms, and advertising content. This helps identify breaches before they become compliance issues.

  • Train your team: Receptionists, nurses, and marketing staff must understand the new rules too. Doctors are ultimately accountable for staff conduct.

  • Review advertising content: Remove before-and-after photos, testimonials, and time-sensitive promotions from your website and social media.

  • Update patient resources: Brochures, FAQs, and pre-treatment documents should reflect new consent and cooling-off obligations.

  • Document everything: Ensure all consultations, assessments, and consent processes are recorded in patient files.

  • Check your qualifications: Confirm your CPD, training, and documented competencies align with the procedures you’re offering.

How You Legal Can Support You

At You Legal, we partner with medical practitioners to make compliance manageable. Our team can:

  • Prepare a framework for your clinic’s external communications to ensure you do not fall foul of the advertising and marketing restrictions

  • Draft or review consent forms, treatment protocols, and staff training checklists

  • Provide tailored legal guidance if you’re unsure whether a procedure falls within your scope of practice (including common non-surgical procedures such as injectables, laser treatments, and skin therapies)

We understand that every clinic is unique. Our advice is practical, tailored, and designed to protect both your patients and your practice.

Proactive Compliance is Good Business

Compliance is more than just ticking boxes. When done well, it can:

  • Build patient trust and loyalty

  • Reduce the risk of regulatory action, complaints, or litigation

  • Demonstrate that your practice is committed to safe, ethical, patient-centred care

  • Differentiate your clinic in a competitive cosmetic industry

  • Create a culture of compliance to ensure you never receive an unwanted communication from AHPRA.

Final Thoughts

The cosmetic industry is rapidly evolving and these reforms show AHPRA’s intent to place patient safety and professionalism at the centre of practice.

While these changes may feel overwhelming, you don’t have to manage them alone. With the right legal guidance and systems in place, your practice can not only remain compliant but thrive under the new laws.

At You Legal, we specialise in medical law and have helped hundreds of practitioners navigate regulatory changes with confidence. If you’d like tailored advice on preparing your clinic for these reforms, get in touch with our team today.

Our team has extensive experience in providing advice and insights into best practices for cosmetic clinics. We have assisted in many practices setting themselves up for success. To discuss the next steps for your clinic contact our team here, and we will put you in touch with the best professional for your needs

Sarah Bartholomeusz