If your clinic's website, social media, or Google Ads describes your doctor as a "cosmetic surgeon", this article is important.
In 2023, the Health Practitioner Regulation National Law was amended to introduce section 115A. This section restricts the use of the title "surgeon" in the medical profession.
What the law now says
The only medical practitioners who can use the title "surgeon" are those holding specialist registration in:
- Surgery
- Obstetrics and gynaecology
- Ophthalmology
Every other medical practitioner, including general practitioners who perform cosmetic procedures, cannot use the title "surgeon" in any advertising. This includes the term "cosmetic surgeon."
What this means in practice
A general practitioner who performs cosmetic procedures, however experienced or well-trained, cannot be described as a "cosmetic surgeon" in any advertising. Not on the website. Not on social media. Not on Google Ads. Not on the Google Business Profile. Not on business cards. All references to "surgeon" must be removed from all advertising, including past social media posts.
How common is this breach?
Extremely common. The amendment came into effect in 2023 but many clinics have not updated their advertising. The majority of cosmetic clinics that use a general practitioner to perform procedures are still describing that practitioner as a "cosmetic surgeon" somewhere in their advertising.
What to use instead
The practitioner's correct title is their actual registration type. For a general practitioner: Dr [Name], General Practitioner. You can describe their experience accurately: "Dr [Name] has performed cosmetic procedures for [X] years" or "Dr [Name] works primarily in cosmetic medicine." You cannot imply a level of registration that does not exist.
The exposure
Misuse of a protected title under the National Law can result in financial penalty, imprisonment, or both for an individual. For a body corporate, a financial penalty applies. False or misleading use of a title may also constitute a breach of section 133, a further offence at up to $10,000 per piece of non-compliant content.
What to do now
Search your website, social media profiles, Google Business Profile, and active ad copy for the word "surgeon." If it appears anywhere and your practitioner does not hold specialist registration in surgery, obstetrics and gynaecology, or ophthalmology, remove it.
Skin Marketing audits clinic advertising against the complete AHPRA and TGA framework and produces a written report showing every breach found and the compliant fix. Request a free audit.
Related articles
AHPRA compliance: a plain-English guide for practice managers
An overview of the three regulatory frameworks that apply to every Australian cosmetic, skin cancer, and dermatology clinic.
TGA banned terms: what your agency is probably still using
The full list of terms prohibited by the TGA in cosmetic clinic advertising, and what is permitted instead.