Cosmetic injectables are very different from ordinary beauty treatments.

Although cosmetic injectable services are frequently offered from beauty and aesthetic clinics, treatments involving prescription medicines and regulated therapeutic goods operate within Australia’s healthcare and medicines regulatory framework.

This means that owning or operating a beauty clinic does not, by itself, give a person authority to prescribe or administer cosmetic injectable treatments.

The practitioner performing the treatment must have the appropriate professional registration, scope of practice, competence and legal authority for the particular procedure and medicine involved.

Australian requirements have also changed significantly in recent years. New guidelines for registered health practitioners performing non-surgical cosmetic procedures came into effect on 2 September 2025.

For beauty and aesthetic clinic owners, understanding these requirements is essential before introducing cosmetic injectable services.

Cosmetic Injectables Are Healthcare Procedures

Cosmetic injectables can include treatments involving:

• botulinum toxin products
• dermal or soft-tissue fillers
• fat-dissolving injections
• other injectable products used for cosmetic purposes.

Different products have different regulatory classifications.

Some cosmetic injectable products are prescription-only medicines. Their prescribing, supply, storage and administration are therefore subject to medicines and poisons legislation as well as professional regulation.

A beauty therapy qualification or cosmetic injectable training certificate does not, by itself, authorise someone to prescribe or administer a medicine where the law requires additional authority.

Ahpra and the National Boards

The Australian Health Practitioner Regulation Agency (Ahpra) works with Australia’s National Boards to regulate registered health practitioners.

From 2 September 2025, new Guidelines for registered health practitioners who perform non-surgical cosmetic procedures came into effect.

These guidelines cover procedures including cosmetic injectables and establish important expectations concerning patient safety and professional practice.

However, the guidelines make an important distinction:

The guidelines do not themselves authorise a registered health practitioner to perform cosmetic procedures or expand a profession’s scope of practice.

A practitioner must still be legally authorised and appropriately qualified and competent to perform the particular procedure.

This is particularly important for clinic owners. Simply establishing that someone is an Ahpra-registered health practitioner does not automatically establish that they can perform every cosmetic injectable treatment.

Who Can Prescribe Cosmetic Injectable Medicines?

Whether a practitioner can prescribe a particular cosmetic medicine depends on their profession, registration, endorsement where relevant, scope of practice and applicable Commonwealth and state or territory legislation.

For example, appropriately authorised medical practitioners and nurse practitioners may have prescribing authority within their respective scopes of practice.

Prescribing pathways for other registered health practitioners may also exist where the practitioner holds the necessary endorsement or authority.

Clinic owners should therefore verify the actual prescribing authority of the individual practitioner rather than relying solely on their professional title.

The rules applying to the particular medicine and the state or territory in which the service is provided must also be considered.

What About Registered Nurses?

Registered nurses work extensively within Australia’s cosmetic medicine sector, but being an RN does not automatically provide unrestricted prescribing or cosmetic injectable authority.

The nurse must work within:

• their registration
• their scope of practice
• applicable National Board standards and guidelines
• their individual education and competence
• applicable medicines and poisons legislation
• the requirements applying to the medicine being administered.

Where a prescription or other lawful medicines authority is required, the appropriate prescribing and supply arrangements must be established.

Clinic owners should not assume that a generic arrangement such as having a doctor “associated with” or “supervising” the clinic automatically satisfies every legal requirement.

The actual treatment and prescribing model needs to comply with the requirements applying to the practitioners, medicines and jurisdiction involved.

Enrolled Nurses

The role of an enrolled nurse differs from that of a registered nurse.

An enrolled nurse must practise within the requirements of their registration, applicable standards, scope of practice and supervision arrangements.

Beauty businesses should therefore obtain appropriate professional and regulatory advice before establishing a cosmetic injectable service involving enrolled nurses.

The fact that an individual has completed cosmetic injectable training does not override restrictions arising from professional registration or medicines legislation.

Dentists and Other Registered Health Practitioners

Some other registered health practitioners may perform particular cosmetic procedures where doing so falls within their professional scope and they possess the necessary competence and legal authority.

This should not be interpreted as a blanket permission for all registered health practitioners to provide cosmetic injectables.

Ahpra’s cosmetic procedure guidelines specifically state that they do not expand a profession’s scope of practice.

Each practitioner’s authority must therefore be assessed according to their profession, registration, scope of practice, training and applicable legislation.

Training and Competence

Legal authority is only one component of safe cosmetic injectable practice.

Registered health practitioners must also have appropriate education, training and competence for the procedures they perform.

Relevant education may include:

• facial anatomy and physiology
• pharmacology
• product knowledge
• injection techniques
• patient assessment
• contraindications
• infection prevention and control
• recognising and managing complications
• emergency response
• informed consent
• aftercare and follow-up.

Practitioners should also maintain their competence through appropriate continuing professional development.

A short course certificate should never be represented as giving someone a legal right to perform cosmetic injectables where they do not otherwise have that authority.

Patient Suitability Must Be Properly Assessed

Cosmetic injectable treatment should begin with an appropriate patient assessment.

The 2025 cosmetic procedure guidelines place considerable emphasis on patient suitability.

Assessment should consider relevant matters such as:

• the person’s reasons for requesting treatment
• medical history
• medications
• allergies
• previous cosmetic procedures
• contraindications
• expectations
• potential risks
• psychological considerations where relevant
• whether the proposed treatment is appropriate for that individual.

Treatment should not proceed simply because a person requests it or is willing to pay for it.

The treating practitioner has a professional responsibility to determine whether treatment is appropriate.

Informed Consent

Consent is more than obtaining a signature immediately before an injection.

Patients need sufficient information to make an informed decision.

Depending on the treatment, this should include discussion of:

• the proposed procedure
• expected outcomes
• limitations
• material risks
• possible complications
• alternative options where appropriate
• recovery and aftercare
• costs
• the practitioner’s role
• who will prescribe and administer the treatment where different practitioners are involved.

Patients should also have an appropriate opportunity to ask questions.

Consent must be obtained before treatment and appropriately documented.

Cosmetic Procedures for People Under 18

The 2025 guidelines introduced important protections relating to cosmetic procedures involving people under 18.

Practitioners must pay particular attention to patient capacity, suitability and the additional requirements applying to minors.

The National Boards state that botulinum toxin and dermal fillers should not be prescribed for cosmetic purposes for people under 18.

Beauty and aesthetic clinics should therefore have clear policies concerning age restrictions and should not assume that parental consent alone makes a cosmetic injectable treatment appropriate or permissible.

Prescribing and Remote Consultations

The use of telehealth and remote prescribing does not remove a prescriber’s professional responsibilities.

A cosmetic injectable prescription should not be treated as a simple administrative step required to enable another practitioner to perform a treatment.

Prescribers remain responsible for complying with applicable professional standards, medicines legislation and patient-assessment requirements.

Clinic owners using remote prescribing models should ensure that their systems comply with current Ahpra and National Board requirements and the medicines legislation applying in their state or territory.

Businesses should be particularly cautious about arrangements that appear designed primarily to provide rapid prescriptions without adequate individual patient assessment.

The TGA and Cosmetic Injectable Products

The Therapeutic Goods Administration regulates therapeutic goods supplied in Australia.

Cosmetic clinics should ensure that therapeutic goods used in treatment are lawfully supplied in Australia and comply with applicable regulatory requirements.

However, clinic advertising should also be careful with terminology.

Statements such as “TGA approved” should not be used casually as a general marketing claim.

Depending on the product, the relevant regulatory concept may involve registration, listing, inclusion in the Australian Register of Therapeutic Goods (ARTG) or another regulatory pathway.

Businesses should accurately describe the regulatory status of products rather than using “TGA approved” as a blanket term.

Advertising Cosmetic Injectables

Advertising cosmetic injectable services is a particularly important compliance area.

Several regulatory frameworks can potentially apply, including:

• the Health Practitioner Regulation National Law
• Ahpra advertising requirements
• the 2025 guidelines for advertising higher-risk non-surgical cosmetic procedures
• Therapeutic Goods Administration advertising requirements
• Australian Consumer Law.

Businesses should be particularly cautious about advertising prescription-only medicines.

Using alternative wording or euphemisms does not necessarily avoid therapeutic-goods advertising requirements.

Marketing should also avoid:

• unrealistic treatment expectations
• trivialising treatment risks
• misleading before-and-after images
• inappropriate inducements
• misleading professional titles
• claims that cannot be substantiated.

Clinic owners should review both the content they publish themselves and advertising created by staff, contractors, influencers or marketing agencies on their behalf.

Before-and-After Images and Social Media

Before-and-after photography is common in cosmetic practice, but registered practitioners must comply with applicable advertising requirements.

Images should not create a misleading impression of treatment outcomes.

Factors such as lighting, angle, makeup, expression and image manipulation can materially affect how results appear.

Consent to receive treatment should also be distinguished from consent to use a patient’s photograph or video for advertising.

Businesses should maintain appropriate written consent processes for marketing material.

Financial Incentives and Promotions

The 2025 guidelines also introduced important restrictions relating to financial arrangements associated with cosmetic procedures.

Registered health practitioners covered by the guidelines must comply with requirements concerning incentives, discounted or free procedures, financing arrangements and financial interests.

This means cosmetic clinics should not treat injectable services in the same way they might market ordinary beauty services.

Promotions such as giveaways, influencer treatments, bundled incentives or aggressive discount campaigns require careful regulatory consideration.

Infection Prevention and Clinical Safety

Cosmetic injections penetrate the skin and must be performed using appropriate infection-prevention and clinical safety procedures.

Clinics should maintain procedures addressing matters such as:

• hand hygiene
• aseptic technique
• treatment-area preparation
• single-use equipment
• sharps handling
• sharps disposal
• clinical waste
• product storage
• environmental cleaning
• exposure incidents.

Applicable state or territory health legislation and local requirements must also be considered.

Complication Management

Cosmetic injectable procedures can result in complications, some of which require urgent intervention.

Practitioners must be able to recognise complications and respond appropriately.

A clinic should have documented systems for:

• identifying adverse reactions
• escalating care
• obtaining medical assistance
• emergency response
• follow-up
• documenting incidents
• reporting adverse events where required.

Practitioners should also understand when a complication is outside their competence and requires referral or emergency medical treatment.

Professional Indemnity Insurance

Registered health practitioners must meet the professional indemnity insurance requirements applying to their profession.

Clinic owners should also ensure their business insurance appropriately covers cosmetic injectable services.

Insurance should be checked for:

• the individual practitioners
• specific injectable procedures
• products used
• clinic premises
• complications
• employees and contractors where relevant.

Never assume that ordinary salon public liability insurance automatically covers cosmetic injectable services.

What Beauty Salon Owners Need to Understand

A beauty salon owner does not necessarily have to personally perform injectable treatments in order for a clinic to offer them.

However, introducing registered health practitioners into a beauty business creates additional compliance responsibilities and risks.

Before introducing cosmetic injectable services, salon owners should establish:

• exactly who will prescribe
• exactly who will administer
• each practitioner’s registration and authority
• the patient-assessment process
• medicine ordering and storage procedures
• consent procedures
• clinical record systems
• infection-control procedures
• complication and emergency protocols
• insurance arrangements
• advertising controls
• privacy and confidentiality procedures.

These arrangements should be established before treatments commence rather than after a problem occurs.

Training Does Not Equal Legal Authority

This is one of the most important principles for beauty businesses considering cosmetic injectable services.

A person may complete extensive cosmetic injectable training and still not have the legal authority to prescribe or administer a particular medicine.

Likewise, professional registration alone does not automatically demonstrate competence to perform every cosmetic procedure.

Four separate questions should therefore be considered:

Is the practitioner legally authorised?

Is the treatment within their professional scope of practice?

Are they appropriately trained and competent?

Does the clinic’s treatment model comply with applicable medicines, professional and state or territory requirements?

All four need to be considered.

Before Offering Cosmetic Injectables in Your Clinic

Beauty and aesthetic clinic owners should verify:

1. the Ahpra registration of each health practitioner
2. the practitioner’s scope of practice
3. prescribing authority where prescription medicines are involved
4. authority to administer the relevant medicine
5. state or territory medicines and poisons requirements
6. practitioner education and competence
7. patient assessment and consent procedures
8. product procurement and storage arrangements
9. infection-control systems
10. emergency and complication-management procedures
11. professional indemnity and business insurance
12. advertising compliance
13. clinical record and privacy systems
14. requirements applying to clients under 18.

If there is uncertainty about a particular treatment model, obtain advice from the relevant regulator, professional body, insurer or appropriately qualified legal adviser before commencing treatment.

Where to Check Current Requirements

Because cosmetic medicine regulation continues to evolve, clinics should use current primary sources.

These include:

• Australian Health Practitioner Regulation Agency (Ahpra)
• the practitioner’s relevant National Board
• Therapeutic Goods Administration (TGA)
• relevant state or territory health department
• relevant state or territory medicines and poisons regulator
• Australian Competition and Consumer Commission (ACCC)
• professional indemnity insurer.

Businesses should not rely solely on information supplied by training companies, product suppliers or social media when determining whether a treatment model is legally compliant.

Conclusion

Cosmetic injectable services sit at the intersection of the beauty and healthcare industries, but legally they should not be treated as ordinary beauty services.

The ability to offer a cosmetic injectable treatment depends on the practitioners involved, the medicine or product being used, professional scope of practice, prescribing and administration authority, practitioner competence and applicable Commonwealth and state or territory requirements.

For salon and clinic owners, the safest approach is to build the service around appropriately authorised registered health practitioners and robust clinical governance rather than assuming that a course certificate, prescription arrangement or professional title automatically makes a treatment model compliant.

Most importantly, training and accreditation should never be confused with legal authority.

A professional training course can contribute to a practitioner’s knowledge and competency development, but it cannot override restrictions imposed by professional regulation or Australian law.

Important Disclaimer

This article provides general educational information for beauty and aesthetic businesses in Australia. It does not constitute legal, medical or regulatory advice.

Requirements can vary according to practitioner profession and registration, the medicine or product used, the procedure performed and the Australian state or territory.

Businesses and practitioners should verify current requirements with Ahpra, the relevant National Board, the TGA and relevant state or territory authorities before offering cosmetic injectable procedures.