A major shift is coming for psychologists in Australia. On 1 December 2025, the Psychology Board of Australia (PsyBA) will replace the APS Code of Ethics with its own Code of Conduct for Psychologists.

This isn’t just a change in name. The new Code embeds far more detailed expectations about informed consent, cultural safety, professional boundaries, records, and supervision. Compliance won’t happen automatically, every psychology practice, whether solo or group, will need to take deliberate steps now to be ready.

So, what’s changing? Below, we translate what this transition means in practical terms.

What the New Code Changes

First we will summarise what’s new and different between the current APS Code of Ethics and the new PsyBA Code of Conduct (the Code).

The Code will be a regulatory code (not just aspirational), meaning not following its standards and requirements may lead to regulatory consequences.
It sets more concrete and practice-oriented expectations (for example, around informed consent, physical contact and cultural safety).
The Code explicitly embeds cultural safety for Aboriginal and Torres Strait Islander peoples, including obligations of self-reflection, anti-racism, partnership and respect.
The Code aligns with updated professional competencies (also commencing December 2025) so that supervision, assessment of registrars, and ongoing development must reflect those competencies.
Because the Code is more descriptive, it requires more demanding documentation and processes. For example, consent is no longer a one-off; it must be revisited under each “material change or time lapse.”

In short, every practice must audit its existing policies, forms, and processes, and rebuild many of them to reflect these increased expectations of the Code.

Where to Focus First

We know these terms and expectations may be confusing and may also seem like a lot of work. The broad changes to consider are:

1) Update Core Documents

Every practice should review or redraft:

Client Agreement / Terms of Service (including fees, cancellations, boundaries, and informed consent)
Privacy Policy and Intake Privacy Notice
Informed Consent Form (covering purpose, risks, withdrawal, and financial consent)
Telehealth and Electronic Communication Policy
Complaints & Open Disclosure Procedure
Cultural Safety Statement and Practice Procedure
Records Management and Supervision Agreements

This is where the Code’s expectations are applied in everyday situations.

2) Re-consent Clients

At each client's next visit, obtain updated consent acknowledging:

Privacy and Date Use
Telehealth
Any clinically indicated physical contact (with written consent each time)

3) Website and Public Materials

Ensure your website reflects transparency and compliance:

Remove clinical testimonials
Add clear summaries of privacy and consent
Display fees and cancellation rules

4) Data Breach Response

Adopt a proper Notifiable Data Breach Plan – including an OAIC-aligned checklist and timeline for client notification. You Legal has a solution for this on our website to get you compliant in this area: Notifiable Data Breach Package

Above is the broad spectrum of changes, including the why and what of the Code, the how is where legal expertise helps. At You Legal we tailor specialised templates, policies and plans for psychology practices, so you don’t feel like you have to start from scratch.

Cultural Safety and Records

These two areas are no longer optional, cultural safety and compliant record management are a part of the new requirements for psychology practices.

Cultural Safety

The Code requires psychologists to provide culturally safe, reflective care that promotes self-determination and partnership. This means you must begin;

Recognising power imbalances and addressing systemic racism
Embedding cultural consultation into practice design
Documenting ongoing staff training and reflection

Your cultural safety statement should be more than words; it should show measurable and truthful commitment.

Records Management

Record-keeping must now meet both ethical and operational standards listed within the new code:

Objective, factual, respectful entries
Secure digital and physical storage with restricted access
Clear transfer and closure procedures
Audit trails for electronic access

Good records protect both clients and practitioners. The Code expects transparency and care in every entry your psychologists write.

Boundaries, Consent & Physical Contact

Sections of the new Code speak directly to maintaining professional boundaries and seeking informed consent. Consent is often something practitioners and practice managers assume is there, but this new code enforces heightened requirements for ensuring it is. This means revisiting;

How you describe physical contact during assessments or interventions
How you manage dual or multiple relationships
What you do when continuity of care is disrupted

Consent also now extends to financial clarity, meaning clients should know fees, rebates, third-party involvement, and cancellation terms before treatment begins.

The new standard also calls for a documented process when clients withdraw consent or when the material/purpose of the service changes

Complaints and Open Disclosure

The Code promotes a culture of honesty and accountability. Every practice should have a clear procedure outlining:

How clients can raise concerns internally
When and how you disclose incidents or harm
External escalation pathways (AHPRA or PsyBA)

This isn’t just about compliance; it’s about building trust through transparency, for practitioners, patients and the practice.

Feeling Overwhelmed? You’re Not Alone

If this all feels like a lot, that’s completely understandable.

Many psychologists entered the profession to help people, not to write and rewrite policy manuals. Reading through 60 pages of regulatory language can feel daunting.

Here’s what to remember:

You’re already doing most of it. Many practices already meet these expectations in spirit; the task now is aligning documentation and procedures.
You can get help. Legal experts who specialise in health-practice compliance can translate the Code into practical templates, checklists, and procedures that reflect your practice.
This is about better care. The Code’s intention isn’t to burden practitioners; it’s to protect clients, improve transparency, and strengthen public trust in psychology.

Think of this update as an opportunity to bring your practice policies up to the same high standard as your clinical care you already provide.

Practical Next Steps

If you’re not sure where to begin, start with these:

Audit your existing documents and website content.
Prioritise privacy, consent, and cultural safety first: those are most visible to clients.
Update supervision agreements to align with the new professional competencies.
Train your team on new procedures and record-keeping expectations.
Seek guidance from a legal expert familiar with health-sector compliance.

Our team at You Legal has the experience to guide you through these changes, such as:

Review or draft compliant policies and forms
Design rollout plans and client re-consent strategies
Ensure alignment with the new PsyBA Code and Privacy Act
Provide ongoing advice as the 2025 changes take effect

Moving Forward with Confidence

The shift to the PsyBA Code of Conduct marks a massive change for Australia’s psychology practices, practitioners and clients. It’s about fostering respect, accountability, and cultural awareness into the way psychologists operate not highlighting a few red flags.

By starting early and getting the right guidance, your practice can approach this transition with calm and clarity rather than stress.

If you’d like help reviewing your documents or creating a compliant policy suite, our team at You Legal can guide you through the process step-by-step; so, you can focus on what matters most: providing safe, effective care for your clients.

Our team works closely with health and medical professionals to ensure their practice documents, policies, and procedures align with the latest regulatory requirements. If you’d like tailored guidance on updating your templates or ensuring your practice meets the new standards, get in touch with our team today.

From Consent to Complaints; How Psychologists Can Get Legally Ready for the New Code