Enrolled nurses and cosmetic injectables

What AHPRA’s 2 September 2025 cosmetic guidelines mean in practice

Australia’s non-surgical cosmetic industry is highly commercial, fast-moving, and increasingly complex. In that context, AHPRA and the National Boards published the Guidelines for registered health practitioners who perform non-surgical cosmetic procedures dated 2 September 2025.

These guidelines are designed to clarify expectations of professional conduct and safe practice. They do not authorise or expand any profession’s scope of practice.

What the guidelines cover

The guidelines apply to registered health practitioners under the National Law who perform non-surgical cosmetic procedures, excluding medical practitioners (who are directed to the Medical Board’s separate cosmetic guidelines).

They describe “non-surgical cosmetic procedures” broadly as procedures undertaken to change appearance and include examples such as prescription-only cosmetic injectables (botulinum toxin and dermal fillers), fat dissolving injections, thread lifts, sclerotherapy, CO2 laser skin resurfacing, cryolipolysis, laser hair removal, dermabrasion, chemical peels and hair transplants.

For nurses specifically, the document states that these guidelines replace the NMBA position statement “Nurses and cosmetic medical procedures”.

Patient suitability and informed decision-making expectations

A central theme is that clinics must prioritise patient wellbeing over commercial drivers. The guidelines require an evidence-based, holistic suitability assessment, including screening for psychological factors such as body dysmorphic disorder (BDD).

The guidelines also address prescribing safeguards for prescription-only cosmetic injectables. They state that authorised prescribers must have an in-person or video consultation each time they prescribe, and that asynchronous prescribing by text/email/online is not acceptable.  They also state that “bulk” or “batch” prescribing is not acceptable, and that every person must have an individual prescription.

Enrolled nurses: what they are and how they differ from RNs and NPs

In Australia, enrolled nurses (ENs) are nurses who practise with a diploma-level qualification and work as part of a nursing team. ENs provide patient care within a defined scope and are required to practise under the supervision of a registered nurse (RN).

Registered nurses (RNs) have broader preparation and accountability for assessment, care planning, delegation, and supervision of ENs.

Nurse practitioners (NPs) are experienced RNs with advanced practice endorsement, typically including extended assessment and (depending on authorisations) prescribing and referral functions.

Can enrolled nurses undertake cosmetic injectables?

Yes, within strict boundaries and governance.

The guidelines note that the EN foundational entry requirement is not at a level that adequately prepares ENs for the risk and complexities associated with non-surgical cosmetic procedures, including the administration of cosmetic injectables.

Where ENs do practise in this field, the guidelines set minimum expectations including:

• At least one year full-time equivalent post-initial registration to consolidate foundational EN skills.
• At least one year full-time equivalent experience in a related area prior to practising in non-surgical cosmetic procedures.
• Relevant education and training completed prior to undertaking practice.
• Ongoing requirement that ENs work under RN supervision (see supervision section below).

Clinics should ensure ENs have documented competence in facial anatomy, aseptic technique, complication recognition/escalation, informed consent processes, and emergency response, with a structured competency sign-off pathway and audit trail.

What is direct supervision?

Direct supervision is where the RN is physically present and personally observes, works with, and directs the EN.

For enrolled nurses, the guidelines specify the following requirements (noting that enrolled nurses practise under registered nurse supervision, and the guideline describes direct and indirect RN supervision):

• Laser skin resurfacing: ENs may only perform laser skin resurfacing under direct supervision of an RN, and the RN must check the laser settings before use.
• Dermal fillers (restricted areas):
  • ENs must not administer dermal fillers to very high-risk areas, including the glabella, nose and forehead.
  • ENs may only administer dermal fillers to specified high-risk areas (temples, nasolabial folds, peri-orbital and medial cheek) in a clinical setting with immediate onsite access to the prescriber and/or an RN.

What is indirect supervision?

Indirect supervision is where the RN works in the same state/territory-based organisation, is readily available, but does not constantly observe the EN’s activities.

The guidelines also note it is generally expected the RN and EN have the same company, and if not, there must be clearly documented arrangements (including insurance and access expectations) to ensure timely direction and public safety.

Under indirect supervision (with a registered nurse readily available within the same state or territory-based organisation), where an enrolled nurse is appropriately trained, assessed as competent, and working within clinic governance and escalation arrangements, indirect supervision may be applied to lower-risk cosmetic services such as:

• Hyaluronic acid dermal fillers to lower-risk areas such as lips, cheeks and chin (noting the guideline’s specific restrictions for very high-risk and high-risk facial areas)
• Botulinum toxin type A treatments delivered under a valid, patient-specific prescription and prescriber-authorised treatment plan
• Deoxycholic acid treatments, where permitted by the clinic’s protocols and prescribing arrangements
• Laser hair removal and laser tattoo removal, where the enrolled nurse has documented competency and the clinic’s supervision model is appropriate
• Dermatological and skin treatments (for example, low-to-moderate intensity device-based or topical treatments) performed in accordance with training, protocols and escalation pathways.

How Yooli supports enrolled nurses to practise safely within scope

Yooli is designed to help clinics integrate enrolled nurses into cosmetic services in a way that is structured, auditable, and aligned to regulatory expectations. We do not treat scope of practice as a branding exercise. We treat it as a patient safety system.

1. Training pathways with certified providers

Yooli can support enrolled nurses through structured training pathways delivered by certified training providers. This allows clinics to evidence that education and training has been completed before an enrolled nurse undertakes non-surgical cosmetic procedures, and to maintain clear training records over time.

2. Credentialing that reflects scope and competence

Yooli can credential enrolled nurses within the boundaries of their role and demonstrated competence. This means access and permissions can be aligned to what the enrolled nurse is trained and authorised to do, rather than what a clinic might prefer commercially. Credentialing controls can also be updated as competence develops or where conditions, restrictions, or supervision settings change.

3. Safe supervision allocation and oversight

Yooli can allocate supervising registered nurses to enrolled nurses to support safe practice, including defining whether supervision is direct or indirect for specific procedures and contexts. This helps clinics operationalise supervision arrangements rather than leaving them informal or dependent on ad hoc decisions.

4. Escalation pathways for complications and adverse events

Yooli can provide structured escalation pathways for complications and adverse events, including clear triggers for escalation, defined response roles, and documentation prompts. This supports timely clinical decision-making, consistent communication, and reliable records when patient risk increases.