Dentists need to be aware of their obligations and risks when providing this treatment, as well as the recent regulatory changes. Key facts and links to more detailed information are provided here.
Expectations of the Dental Board of Australia
The Dental Board of Australia (DBA) has specific expectations for dentists who choose to provide this treatment. Dentists must maintain a high level of professional competence and conduct in line with all DBA Policies, Codes, and Guidelines such as the Code of Conduct.
Treatment must constitute the definition of the practise of dentistry:
“Dentistry involves the assessment, prevention, diagnosis, advice, and treatment of any injuries, diseases, deficiencies, deformities or lesions on or of the human teeth, mouth or jaws or associated structures.”
Treatment must fall within the individual Scope of Practice (SOP) of the dentist i.e. treatment for which they have been educated and trained, and are competent to provide, with appropriately selected CPD. If treatment falls outside the personal SOP of the practitioner, the patient must be referred to a dental practitioner if it is within the definition of dentistry, or to a medical practitioner if outside the definition of dentistry.
See more detail at https://www.dentalboard.gov.au/Codes-Guidelines/Practitioner-resources/botulinum-toxin-and-dermal-fillers.aspx.
Release of new Guidelines from Ahpra (Sept 2025)
The guidelines are mandatory and specify what can and cannot be done. There are guidelines about performing non-surgical cosmetic procedures, as well as advertising guidelines regarding this treatment.
Performing non-surgical cosmetic procedures
https://www.ahpra.gov.au/Resources/Cosmetic-surgery-hub/Cosmetic-procedure-guidelines
This page contains the complete guidelines as well as FAQs. Members are advised to pay particular attention to the expectations around:
- Case selection – including assessment of a patient’s suitability and referral if issues are identified e.g. psychological, managing patient expectations, and so on.
- Informed consent – must be detailed and specific.
- TGA requirements – regarding advertising, “off-label” use, TGA-approved products, etc.
- Documentation – needs to be detailed for both the patient and the clinical records.
Advertising higher risk non-surgical cosmetic procedures
This page contains the complete guidelines and FAQs. Members are advised to pay particular attention to:
- What is considered advertising (e.g. social media is included).
- Stricter advertising rules apply to cosmetic procedures compared with the more general Advertising Guidelines.
- Testimonials – “Advertising of higher risk cosmetic procedures must not use testimonials due to their potential to create unrealistic expectations of beneficial treatment.”
- Use of images including ‘before and after’
- See the guidelines for a prescriptive list of what can and cannot be included in advertising.
Professional Indemnity Insurance
Dental professional indemnity (PI) policies cover you for the “Practice of Dentistry”. If you are found to be working outside your SOP, you risk NOT being indemnified for the procedures you perform. It is best to check with your insurer. Guild Insurance PI policy covers dentists for claims arising from the practice of dentistry, including the use of botulinum toxin and dermal fillers, within your individual SOP.
Other FAQs
- Item number 927: Provision of medication/medicament, is the applicable number in The Australian Schedule of Dental Services and Glossary. Ensure your treatment matches the item code descriptor.
- Private health insurers (PHIs) – each PHI has different policies and rules regarding payment of benefits, and patients need to contact their PHI to determine their circumstances.
If you require more information, please do not hesitate to email Advisory Services at advisory@adansw.com.au or call 8436 9944.