Regulatory and Ethical Considerations for Doctors and Dentists Performing Cosmetic Injectables

Key Takeaways

  • Regulatory Compliance Is Crucial: Doctors and dentists must follow national and state regulations when offering cosmetic injectables. This includes prescribing, patient management, and advertising, all of which are governed by entities such as the TGA, ACCC, AHPRA, and National Boards.
  • Ethical Responsibility in Cosmetic Medicine: Practitioners must be prepared to say no to clients when requested treatments are unsafe, unethical, or unnecessary. Understanding when to decline is both an ethical obligation and a regulatory requirement.
  • Advertising Must Be Transparent: Advertising cosmetic injectables is tightly regulated. Practitioners, businesses, and influencers must ensure ads are honest, accurate, and free from misleading promises. No references to natural aging as flaws or unrealistic results are allowed.
  • Mandatory Cooling-Off Period for Minors: A new regulation requires a 1-week cooling-off period for clients under 18. Practitioners must ensure that young clients are making informed, healthy decisions before undergoing cosmetic treatments.
  • Informed Consent Is Required: Obtaining informed consent is a legal and ethical obligation. Practitioners must provide full details about the treatment, including risks, costs, qualifications, and the fact that cosmetic injectables are not covered by Medicare.
  • Mental Health Considerations: Practitioners must be vigilant for signs of mental health conditions, such as body dysmorphia, that may influence a patient’s decision to pursue cosmetic treatments. Ethical practice involves assessing whether treatments are appropriate.
  • Adhering to Ethical and Legal Standards: Practitioners must familiarise themselves with both regulatory frameworks and the ethical considerations surrounding cosmetic injectables to ensure safe, responsible practice and to protect both clients and their professional standing.

When deciding to offer cosmetic injectables within a practice, doctors and dentists must abide by a slew of regulations. Some of these regulations are national, while others differ from state to state. It is set out in legislation and guidelines how to manage the prescribing of medications to be administered, how to manage the client (even if they’re being seen by another medical practitioner), and how to conduct their practice, even down to advertising their services. 

Along with these considerations, there are ethical concerns that form part of being a medical practitioner, as well as extras that relate specifically to the field of aesthetic medicine. To practice safely and legally, it is best to be mindful of the regulatory and ethical considerations for doctors and dentists who administer cosmetic injectables in their clinics. 

Learning to say no

In a dental or medical practice, a practitioner would have experience with patients making requests that aren’t safe, practical, or ethical. A good doctor or dentist will have had situations where they must decline a client’s wish, and while never easy, it is imperative that it is handled gently and honestly. In aesthetic medicine, a client isn’t always right, and knowing when to say no is as crucial as knowing how. Recognising when a request isn’t safe is covered not only by an ethical code but also by regulations. 

Advertising correctly

The advertising of cosmetic injectables, classed as “higher risk non-surgical cosmetic procedures”, was an unregulated side of the profession that risked unhappy clients and deregistered practitioners. Now, advertising is tightly controlled, and penalties can be severe if regulations are ignored. 

Those beholden to the new rules include: 

  • the practitioners administering the injectables,
  • business, corporate and partnership entities,
  • those responsible for the advertising,
  • all people advertising the service,
  • contractors or employees of the service. 

Further, registered medical practitioners are subject to additional regulations governing their practice. 

Regulations and guidelines are published by a range of professional bodies, and it is the responsibility of those listed above to ensure they are aware of all guidelines and legislation. The Therapeutic Goods Administration (TGA), the Australian Competition and Consumer Commission (ACCC), the relevant National Boards governing the practice of the doctor or dentist (the Medical Board of Australia), and the Australian Health Practitioner Regulation Agency (AHPRA) set guidelines that dovetail with state and national legislation. 

If using social media to promote a business, dentists and doctors must ensure that the person advertising is likewise abiding by the regulations. That means an influencer marketing a business must follow the rules. Stipulations include frank, no-frills outlining of the costs and side effects; no words or phrases that target natural ageing processes or a person’s vulnerabilities and do not pathologise a person’s normal appearance; and treatments not being a “prize” in a competition. Cosmetic injectables must not be advertised using lifestyle or holiday backdrops, and “predicted results” are not permitted. 

A little bit of both

Some considerations overlap with ethical and regulatory. In the raft of new changes that came into effect on the 2nd of September 2025, a mandatory cooling-off period for clients under the age of 18 is now in place. A practitioner who sees a client under 18 years old must now advise that any procedure will be at least a week after an initial consultation. This is both an ethical aspect and a regulatory aspect. A good doctor or dentist will ensure that a potential client under 18 years of age is making a healthy decision about a treatment. In the same vein, advertisements should not target people under 18, and photos of this age group should not be used in advertising. 

Doctors and dentists must be further aware of a potential client presenting with mental illness that could be influencing their decision to pursue cosmetic injectables, such as body dysmorphia. 

When administering any treatments, doctors and dentists must ensure they obtain informed consent. As the person who is prescribing the drugs being administered, a medical practitioner must provide enough information so that the client can make an informed decision – this includes (but is not limited to) information about the cost of the procedure; the medical practitioner’s registration type, training and experience; and that cosmetic injectables are not covered by Medicare. 

Conslusion

Doctors and dentists are highly respected members of society and hold a responsibility towards those seeking higher-risk non-surgical cosmetic procedures. It is imperative that they familiarise themselves not only with the regulations governing the field of aesthetic medicine but also with the ethical considerations. They will encounter potential clients who ask for treatments that are unsafe or unwarranted, and they will need to abide by guidelines governing many aspects of their practice and advertising. 

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