What Australian and New Zealand Regulators Actually Say About Overseas Cosmetic Surgery

Ahpra, ASPS, ASAPS, Smartraveller, NZAPS and the Better Health Channel on surgery abroad, quoted at length, with a Bangkok surgeon's reply to each of them.

By Dr. Rushapol Sdawat, MD — Thai Board-certified Plastic and Reconstructive Surgeon, Medical Licence No. 17689
Last reviewed: 28 AUG 2026

You have already read the clinic pages, and probably the warnings too, and noticed that the two sets of documents do not appear to describe the same world. One is full of smiling people and package inclusions. The other uses words like disfigurement, evacuation and death. Neither reads as though it was written by someone who expected you to read the other.

I am a plastic surgeon in Bangkok. Almost every commercial incentive I have points towards not showing you the second set of documents. I am going to show them to you anyway, in their own words, because a decision made on half the evidence is not a decision — it is a purchase. Then I answer each one, conceding what is fair. Some of it is fair.

What Ahpra actually regulates, and what it cannot reach

Ahpra and the Medical Board of Australia introduced a cosmetic surgery reform package that took effect on 1 July 2023. The Medical Board's then-Chair, Dr Anne Tonkin, said it was intended "to stop patients being exploited and reduce the risk of harm." Ahpra's then-CEO Martin Fletcher said the aim was to "raise standards, improve consent about surgery and raise the bar in advertising."

For patients in Australia, the practical effects include:

  • "From 1 July 2023, anyone considering cosmetic surgery must first get a referral from their GP."

  • "There must be a cooling-off period (of at least seven days) after you give consent, before you book the surgery (or pay)."

  • A requirement that the practitioner tells you "the risks and possible complications", the "total cost" including deposits, refunds and "payments for follow-up care", and "the complaints process and how to make a complaint".

  • "All cosmetic surgery must be performed in a facility that is appropriate for the level of risk involved."

  • An endorsement for cosmetic surgery, which Ahpra says "will help consumers know who is trained and qualified to perform cosmetic surgery safely."

Ahpra also warns, about its own register, that "searching the register may not be enough to tell you whether they are qualified and experienced in the specific procedure." That is unusually candid for a regulator describing its own tool.

Here is the part that matters to you. Ahpra registers and regulates practitioners in Australia. I am registered by the Medical Council of Thailand, not by Ahpra. If you are unhappy with my care, Ahpra has no power over me and no register on which to record a finding against me. That is not a criticism of Ahpra; it is what national regulation is. Any facilitator who implies otherwise, or who waves at "international standards" as though they were a regulator, is misleading you.

What the Australian Society of Plastic Surgeons says

The Australian Society of Plastic Surgeons (ASPS) is blunt. It calls cosmetic tourism "a price-driven practice where patients travel overseas to undergo cosmetic surgery procedures", and states:

"Cosmetic surgery is real surgery and like all forms of surgery carries inherent risks."

"Australia holds very high medical standards which are often not met in other countries."

"In the event of post-operative complications, follow-up care is essential."

"ASPS does not recommend combining surgery with having a holiday."

"ASPS strongly advises against overseas cosmetic surgery tourism."

I agree with four of those five without qualification, including the one about holidays: combining an operation with sightseeing is the most common reason I see wounds break down. The fifth is a position, not a finding.

What ASAPS asked the government for after the 60 Minutes programme

On 9 August 2026, Australia's 60 Minutes aired "Destination Disaster," about Australian women left disfigured after cosmetic surgery at a large Bangkok operator. Two days later the Australasian Society of Aesthetic Plastic Surgeons (ASAPS) called for government action, naming the marketing practice it holds responsible: "heavily curated patient stories, before-and-after content and positive recovery experiences [that] can create an impression of safety that may not show complications, recovery difficulties or longer-term outcomes." That criticism is correct, and describes most of the industry I work in.

The statement did not ask for overseas surgery to be banned. It asked for "a review of the regulation of Australian businesses that advertise, facilitate or sell overseas cosmetic surgery to Australians, with a view to ensuring they are subject to equivalent cosmetic surgery-specific advertising safeguards", and "a Federal Government-funded national public education campaign on the risks of cosmetic surgery tourism."

I support both. An Australian company selling you an operation in Bangkok should face the same advertising rules as one selling you an operation in Sydney. There is no principled reason for the gap, and the gap is where the worst marketing lives.

ASAPS's patient guidance is worth reading in full. It states that "the risks of having cosmetic surgery overseas can be serious, and in some cases, life-threatening"; that "overseas facilities often lack the strict safety standards, accreditation, and hygiene protocols required in Australia"; that "in some countries, surgeon titles aren't protected"; and that "in some countries, the surgeon you meet may not be the one who performs your operation." It estimates roughly 15,000 Australians travel overseas for cosmetic procedures each year, spending about $300 million, with revision needed in up to 7 per cent of cases, and advises that "in Australia and New Zealand, patients are advised not to fly for 6–8 weeks post-surgery" because of the risk of deep vein thrombosis and pulmonary embolism.

What Smartraveller tells you before you fly

The Australian Government's Smartraveller service does not soften anything:

"There are always risks with medical procedures. You could suffer from complications, or you could die."

"If you have complications they can't treat overseas, you may need medical evacuation back to Australia. This can cost hundreds of thousands of dollars."

"Basic travel insurance policies rarely cover medical tourism."

Its advice is to talk to your doctor in Australia and get a health check at least six weeks before you go. I would add only this: bring that doctor's letter and your medication list with you.

What the Better Health Channel says about Thailand specifically

Victoria's Better Health Channel names Thailand first among destinations, and puts the saving at "as much as 80 per cent off the cost of the same procedure at home." It lists the risks as "lower quality surgical skills and practices that can lead to infection or disfigurement", "antibiotic resistant bacteria that can cause complications after surgery and may not be treatable", and "lack of follow-up after the operation."

On money it says "Medicare Australia is unlikely to cover overseas medical treatment, and private health insurance may not cover it either", and notes Australia has reciprocal healthcare agreements with only "11 countries, and these are mostly for emergency treatment only." Thailand is not one of them.

Its sharpest sentence is about liability: "The person having the procedure carries all the risk."

What NZAPS tells New Zealanders about ACC

The New Zealand Association of Plastic Surgeons states that "long flights and changes in altitude and pressure can complicate recovery from surgery, increasing the risk of blood clots, deep vein thrombosis (DVT), and other complications", and that "once they return home after their operation, the patient is essentially on their own."

On accident compensation it says:

"ACC does not cover injuries sustained from surgery overseas. New Zealanders needing care will have their emergent needs (eg. infection, wounds opening up) met through the public hospital system, but there is no guarantee that any treatment beyond this will make it through the public hospital waiting list system."

Where these bodies are right, and I will not argue

They are right that cosmetic surgery is real surgery. Augmentation, abdominoplasty and rhinoplasty all carry haematoma (blood collecting under the wound), seroma (fluid collecting), infection, wound breakdown, necrosis (tissue death at the edges of long incisions), nerve injury with numbness or weakness that is sometimes permanent, venous thromboembolism, unpredictable scarring, asymmetry, and the outcome hardest to talk about — a result that is technically sound and that you are nonetheless disappointed by. Distance adds the flight, and the fact that if something goes wrong in week three you are 7,000 kilometres from the person who operated on you.

They are right that follow-up is the weak point of the model, that titles are not protected everywhere, that ghost surgery happens, and that curated marketing creates a false impression of safety.

And some people should simply have their surgery at home, whatever the price difference: anyone with a significant clotting history, anyone whose cardiac or respiratory reserve makes a long-haul flight a risk in itself, anyone with poorly controlled diabetes or a BMI that materially raises wound and anaesthetic risk, anyone travelling alone, anyone whose expectations do not match their anatomy, and anyone who cannot comfortably absorb the cost of a revision. If that is you and a clinic is still encouraging you to book, that tells you something about the clinic.

Where the wording is broader than the evidence

Conceding the fair criticisms does not oblige me to accept imprecise ones. Several widely repeated statements are true as general warnings but wrong as absolute rules.

The statement, as commonly readWhat the source actually supportsWhat I would do about it"ACC does not cover injuries from surgery overseas"NZAPS states this flatly. Jonathan Wheeler's 2020 analysis in the Australasian Journal of Plastic Surgery (3(2), doi:10.34239/ajops.v3n2.204) found ACC "will accept a treatment injury only if the surgery has been performed by an appropriately qualified doctor," and that ACC "may cover some patients who have complications as a result of surgery undertaken overseas." Of claims lodged 2014–19, 76 related to overseas procedures.Cover turns on the surgeon's qualifications, not geography. Ask ACC in writing before you book — not the clinic, and not me."Overseas facilities often lack the strict safety standards, accreditation, and hygiene protocols required in Australia"ASAPS's word is "often," not "always." Accreditation is a checkable fact for any named hospital.Ask for the accreditation certificate number, and verify it with the certifying body rather than the clinic."Revision is needed in up to 7% of cases"ASAPS gives this as an upper bound, not a point estimate.Budget for a revision you may not need."The surgeon you meet may not be the one who performs your operation"Correct, and a real practice in parts of the industry.Get the operating surgeon's name and licence number in writing before paying a deposit, and verify it yourself."Medicare does not cover overseas treatment"Correct — and Australia has no reciprocal agreement with Thailand.It does not follow that you are uninsurable at home. A GP consultation in Australia attracts its normal rebate whatever prompted it."Cosmetic tourism costs the Australian hospital system heavily"An audit at the Royal Brisbane and Women's Hospital found that of 331 breast implant removals, 8 (2.4%) involved overseas-inserted devices, costing that department above AU$110,000 — about 4 per cent of its explantation spending.The burden is real and worth naming, and smaller than "cosmetic tourism crisis" implies. Both can be true.

The one claim I contest directly is the implicit one: that "overseas" is itself the risk factor. It is not. The risk factors are an unqualified operator, an unaccredited facility, an unrealistic timeline, and a patient who was never properly assessed — all four available in Sydney, Auckland and Bangkok alike. Distance makes each harder to detect and much harder to fix, which is a serious argument for caution. It is an argument about diligence, not about latitude.

When to seek care

In a Bangkok hotel room, on a plane, or at home: chest pain, breathlessness, coughing blood, or a hot, swollen, painful calf means an emergency department immediately, by ambulance if you cannot walk. Do not contact your surgeon or clinic first. Pulmonary embolism is the complication most likely to kill you, and it does not announce itself politely.

Also emergency, same hour: bleeding soaking through dressings, a breast or abdomen swelling rapidly and becoming tight and painful (an expanding haematoma), fever above 38.5°C with shaking chills, spreading redness with dusky, blistered or numb skin, or sudden confusion or collapse.

Same-day review, not tomorrow: a wound edge going from pink to grey or black, discharge that has turned cloudy or foul-smelling, pain escalating rather than settling after day three, one-sided calf discomfort, or a temperature creeping up over 24 hours.

Back in Australia or New Zealand, go to a public hospital emergency department for anything in the first two groups. Do not fly, do not wait for a Bangkok appointment, and do not let embarrassment cost you time. Take your operation report and medication list, and send me the notes afterwards; I would rather be woken at 3am than read about it three weeks later.

What I would actually do in your position

I would read the ASPS and ASAPS pages in full rather than in the quotes I have selected. I would ask Ahpra's questions of any overseas surgeon exactly as Ahpra frames them for Australian ones — total cost, refund terms, who pays for follow-up, what the complaint process is — and refuse to proceed with anyone who answered vaguely. I would verify the surgeon's registration myself, and ask in writing who will operate, who will assist, and who reviews me on day one, day three and day seven. I would confirm what is covered with ACC or my insurer, in writing, before paying anything.

If, having done all that, you decide to have your surgery in Australia or New Zealand, you will have made a good decision and I will have helped you make it. That is an acceptable outcome for me. What is not acceptable is that you make it on the basis of a page that only ever shows you half the file.

Dr. Rushapol Sdawat (known to international patients as Dr. Dominic) is a Thai Board-certified plastic and reconstructive surgeon practising at Intrarat Hospital, Bangkok, Medical Licence No. 17689. He holds Thai Board certification in General Surgery (Phramongkutklao Hospital) and in Plastic and Reconstructive Surgery (Ramathibodi Hospital, Mahidol University), has been a member of ISAPS since 2008 and is an international member of the American Society of Plastic Surgeons. Dr. Rushapol holds Thai specialist certification; he is not registered with Ahpra and does not hold Australian or New Zealand specialist registration. His registration can be verified on the Medical Council of Thailand register at checkmd.tmc.or.th.

This article is provided for general information and education. It is not medical advice and cannot substitute for individual assessment by a qualified practitioner who knows your history. Surgery carries risk, including risk of serious complications and of outcomes that do not meet expectations. Results vary between patients.

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Can You Use Your Superannuation for Cosmetic Surgery? The ATO and Ahpra Warning Explained

Compassionate release rarely covers cosmetic surgery. What the ATO requires, what the ATO and Ahpra warned in October 2025, and why we won't help you apply.

By the MedSanctuary Team
Medically reviewed by Dr. Rushapol Sdawat, MD — Thai Board-certified Plastic and Reconstructive Surgeon, Medical Licence No. 17689 · Last reviewed: 28 AUG 2026

Somebody has told you it is possible. Possibly a clinic, possibly a Facebook group, possibly a company that describes itself as helping with "early release applications" and takes a fee for the paperwork. The pitch is always the same shape: the money is yours, you are unhappy now, retirement is decades away, and there is a form.

There is a form. There are also two conditions attached to it that most cosmetic procedures do not meet, a regulator that has been actively looking for practitioners who sign it anyway, and — as of March 2026 — a doctor who lost three months of his registration over one such form.

This page explains the rules accurately, quotes the October 2025 joint warning from the Australian Taxation Office and Ahpra precisely, and tells you plainly where MedSanctuary stands. We do not assist with superannuation applications. We will not write, review, support or refer you for one. The reason is set out below, and it is not modesty.

What compassionate release actually is

Superannuation is preserved money. You cannot normally touch it until you reach preservation age and meet a condition of release. Compassionate release is one of a small number of exceptions, administered by the ATO, which lets you withdraw a limited amount for specific unpaid expenses — including medical treatment for you or a dependant.

Two things follow. The first is that the ATO decides, not your doctor and not a clinic: a medical report is evidence submitted in support of an application, not an approval.

The second is that this is a last-resort provision. ATO Deputy Commissioner Emma Rosenzweig put it directly in October 2025: compassionate release of super "should only be considered as a last resort, where all other options of paying for the eligible expenses have been exhausted."

The two conditions the ATO applies to medical treatment

For medical treatment to be an eligible expense, the ATO requires that both of the following are satisfied.

Condition one. The treatment must do one of three things:

  • "treat a life-threatening illness or injury"

  • "alleviate acute or chronic pain"

  • "alleviate an acute or chronic mental illness"

Condition two. The treatment must be "not readily available through the public health system."

You then need two medical reports: one from a specialist in the area you are applying about, and one from either another registered medical specialist or a general practitioner. Between them, the reports must explain the condition, why the treatment is necessary, and why the public system cannot provide it. If the treatment is to happen overseas, the practitioner must also explain "why you or your dependant can't have the treatment in Australia."

That last requirement is the one people skate past. It is not enough to want the operation done in Bangkok, or to prefer the price. The report has to explain why it cannot be done in Australia at all.

Does a purely cosmetic procedure qualify?

Generally, no.

The ATO's position is that cosmetic treatment is ineligible unless it directly treats one of the qualifying conditions, and that a practitioner should only certify treatment that is "absolutely necessary to treat the eligible condition" — including where a costlier option with cosmetic benefits exists alongside a simpler one that would treat the condition. The ATO gives, as an example of inappropriate practitioner conduct, "preparing inaccurate medical reports to support patients access their super where they are ineligible (for example, for cosmetic purposes)."

Run an ordinary cosmetic request against the two conditions and you can see why it fails.

The situationCondition one: life-threatening, acute/chronic pain, or acute/chronic mental illness?Condition two: not readily available in the public system?Realistic outcomeBreast augmentation for size and shapeNoNot applicableDoes not meet the criteriaAbdominoplasty for loose skin after pregnancy or weight loss, without symptomsNoNot applicableDoes not meet the criteriaRhinoplasty for appearanceNoNot applicableDoes not meet the criteriaLiposuction described as treatment for obesityObesity is a serious condition, but liposuction is not a treatment for it. The Perth case below turned on exactly thisWeight management services exist in the public systemDoes not meet the criteria, and certifying otherwise has ended a registrationDocumented, symptomatic condition with genuine functional or psychiatric impact, assessed independentlyPossibly — this is a clinical judgement, made by treating practitioners with no financial interest in the answerMust be argued on its factsSometimes eligible. Decided by the ATO on the evidence, and nothing on this page changes that

If your situation genuinely sits in that last row, the people to speak to are your GP and a specialist who is not selling you the procedure. Not us.

What the ATO and Ahpra said together in October 2025

On 16 October 2025 the ATO and Ahpra issued a joint warning. The sentence that matters most is this one, from Deputy Commissioner Emma Rosenzweig:

"some health practitioners and registered agents are inappropriately supporting individuals to access their superannuation on compassionate grounds, particularly for cosmetic procedures that aren't aligned to compassionate release requirements."

Read what that sentence actually says, and what it does not. It does not say cosmetic procedures can never be funded this way. It says that practitioners are inappropriately supporting access for cosmetic procedures that are not aligned to the requirements. The qualifier is doing real work, and anyone who quotes the sentence with the qualifier trimmed off — in either direction — is misleading you.

Ahpra's CEO Justin Untersteiner was quoted in the same release:

"There is an inherent trust that the community places in their practitioners and taking advantage of people in need is never acceptable. Any advice on what procedure is necessary should be based on the patients' best interest and not influenced by financial gain or incentives."

The warning named dental services, cosmetic procedures, weight loss treatment and IVF, and noted that dental requests had more than doubled in two years. It flagged consequences for practitioners including cautions, conditions on registration and referral to a tribunal, plus penalties for false or misleading statements to the Commissioner.

This built on a joint statement issued on 30 May 2025 by Ahpra and the Medical and Dental Boards of Australia, reminding practitioners to "put their patients' best interests first, providing treatment options that are based on the best available information and are not influenced by financial gain or incentives", and to "be honest and not misleading when writing reports to support the release of superannuation."

The Perth case: what happened when a doctor certified liposuction

In March 2026 the Western Australian State Administrative Tribunal decided a case that puts flesh on all of the above. It was reported publicly in April 2026.

A Perth doctor had, in 2018, completed an early release of superannuation declaration form for a patient who had asked for it so she could pay for liposuction. On the form he indicated the patient was accessing her superannuation early because of life-threatening obesity. His clinical notes recorded no weight, no body mass index, and no assessment supporting a life-threatening condition. The patient obtained $18,500.

The tribunal found professional misconduct on the basis of false and misleading information. The doctor's registration was suspended for three months and he was ordered to pay $5,000 towards the Medical Board of Australia's costs.

Two figures reported alongside the decision are worth noting. Ahpra received 95 complaints about health practitioners involved in compassionate superannuation releases between 2019 and 2025. And the regulators are not treating this as a paperwork issue: ATO Deputy Commissioner Ben Kelly said "it is unacceptable for anyone to pressure Australians into accessing their superannuation savings early to pay for overpriced or unnecessary treatments," while Super Members Council chief executive Misha Schubert observed that "super is not designed to be a bandage for the health system."

Notice who carried the consequence. The doctor lost three months of his livelihood. The patient had the liposuction and lost the compounding on $18,500 for the rest of her working life. Nobody in that story came out ahead.

What about surgery performed overseas?

The rules do not change because the operating theatre is in Bangkok, but two of them bite harder.

The report must explain why the treatment cannot be had in Australia. Cost is not that explanation — if it were, the provision would swallow the preservation rule entirely. And an application that is essentially "I want this procedure, at this price, in this country" is precisely the pattern the ATO says it is looking for.

There is also a quieter problem. Medicare does not cover treatment you receive overseas, Australia has no reciprocal health care agreement with Thailand, and Australian private health insurance generally does not cover procedures performed overseas. So the money you released early has gone on the operation, and the cost of fixing anything that goes wrong lands on a bank account that has just been emptied.

Why MedSanctuary does not help with superannuation applications

We do not assist with superannuation applications of any kind. We will not prepare a letter, provide a quotation formatted for an application, review a draft report, or recommend an "early release specialist." If you ask us to, the answer will be no, and we would rather explain why than quietly decline.

The reason is that we have a financial interest in your answer, and the ATO's rules exist precisely to keep people with a financial interest away from the certification. A provider who helps you unlock the money that pays them is not helping you. They are removing the last obstacle between you and a transaction, and calling it service.

So take this as a practical test you can apply to any clinic, facilitator or agent, anywhere:

  • If a provider offers to help you access your superannuation, that is a warning sign about that provider, not a service they are offering you.

  • If a provider recommends a doctor who "understands the process," treat that as the same warning sign with an extra step.

  • If a provider's payment plan, deposit schedule or booking timeline assumes the release will be approved, they are pricing in a decision the ATO has not made.

What it actually costs you to take the money out early

Even where an application is legitimate and approved, the money is not free. Amounts released on compassionate grounds are generally taxed as a superannuation lump sum when they are paid out, with the rate depending on your age and the components of your balance — check that with the ATO or a financial adviser, never with a clinic. And a withdrawal in your thirties or forties removes not just the amount but every year of compounding it would have earned.

Here is the part that does not help us sell anything. If you cannot fund an elective operation without touching preserved retirement money, you almost certainly cannot fund the complication either. Elective surgery has a failure mode that costs more than the surgery: a haematoma returning you to theatre the same night, an infection requiring weeks of intravenous antibiotics, wound breakdown, tissue necrosis along a long incision, a seroma drained repeatedly, a venous thromboembolism, or a revision procedure twelve months later. Any one of those can cost as much again as the original operation, and none of them can be scheduled.

Being unable to absorb that is not a reason to find creative financing. It is a reason to wait. That is not the answer a clinic is supposed to give, and it is still the right one.

What to do instead if you cannot afford surgery right now

Wait and save, on a real timeline with a real number, including a contingency for revision. Get the assessment done anyway — a proper consultation will tell you whether you are even a candidate, and there is no point saving for an operation Dr Rushapol would decline to perform. If your concern has a functional or medical component, see your GP about it on its own merits: some conditions attract a Medicare rebate under strict criteria, and some are managed in the public system. And if the driver is distress rather than anatomy, say so out loud to your GP. That is a legitimate reason to seek help, and surgery is not always the help that works.

When to seek care

If you have already had surgery — funded however it was funded — the thresholds are the same for everyone.

Emergency, immediately, by ambulance if you cannot walk — in a Bangkok hotel, in transit, or back home: chest pain, breathlessness, coughing blood, or a hot, swollen, painful calf. That is possible deep vein thrombosis or pulmonary embolism. Also: bleeding soaking through dressings, a breast or abdomen swelling rapidly and becoming tight and painful, fever above 38.5°C with shaking chills, spreading redness with dusky, blistered or numb skin, or sudden confusion or collapse.

Same-day review, not tomorrow: a wound edge turning grey or black, discharge that has become cloudy, thick or foul-smelling, pain escalating rather than settling after day three, one-sided calf discomfort, or a temperature climbing over 24 hours.

In Australia, go to a public hospital emergency department for anything in the first group. Emergency care is provided on clinical need, and no one will ask how the procedure was paid for. Take your operation report, medication list and surgeon's contact details, and send the notes to your surgeon afterwards.

The one-line version

Compassionate release exists for treatment that is life-threatening, that relieves acute or chronic pain, or that treats acute or chronic mental illness, and that is not readily available in the public system. Most cosmetic surgery is none of those things. The ATO decides, your treating practitioners provide evidence, and anybody with a commercial interest in the outcome — including us — belongs nowhere near the paperwork.

Dr. Rushapol Sdawat (known to international patients as Dr. Dominic) is a Thai Board-certified plastic and reconstructive surgeon practising at Intrarat Hospital, Bangkok, Medical Licence No. 17689. He holds Thai Board certification in General Surgery (Phramongkutklao Hospital) and in Plastic and Reconstructive Surgery (Ramathibodi Hospital, Mahidol University), has been a member of ISAPS since 2008 and is an international member of the American Society of Plastic Surgeons. Dr. Rushapol holds Thai specialist certification; he is not registered with Ahpra and does not hold Australian or New Zealand specialist registration. His registration can be verified on the Medical Council of Thailand register at checkmd.tmc.or.th.

This article is provided for general information and education. It is not medical advice and cannot substitute for individual assessment by a qualified practitioner who knows your history. Surgery carries risk, including risk of serious complications and of outcomes that do not meet expectations. Results vary between patients.

Read More

What Australian and New Zealand Regulators Actually Say About Overseas Cosmetic Surgery

Ahpra, ASPS, ASAPS, Smartraveller, NZAPS and the Better Health Channel on surgery abroad, quoted at length, with a Bangkok surgeon's reply to each of them.

By Dr. Rushapol Sdawat, MD — Thai Board-certified Plastic and Reconstructive Surgeon, Medical Licence No. 17689
Last reviewed: [SET DATE ON PUBLISH]

You have already read the clinic pages, and probably the warnings too, and noticed that the two sets of documents do not appear to describe the same world. One is full of smiling people and package inclusions. The other uses words like disfigurement, evacuation and death. Neither reads as though it was written by someone who expected you to read the other.

I am a plastic surgeon in Bangkok. Almost every commercial incentive I have points towards not showing you the second set of documents. I am going to show them to you anyway, in their own words, because a decision made on half the evidence is not a decision — it is a purchase. Then I answer each one, conceding what is fair. Some of it is fair.

What Ahpra actually regulates, and what it cannot reach

Ahpra and the Medical Board of Australia introduced a cosmetic surgery reform package that took effect on 1 July 2023. The Medical Board's then-Chair, Dr Anne Tonkin, said it was intended "to stop patients being exploited and reduce the risk of harm." Ahpra's then-CEO Martin Fletcher said the aim was to "raise standards, improve consent about surgery and raise the bar in advertising."

For patients in Australia, the practical effects include:

  • "From 1 July 2023, anyone considering cosmetic surgery must first get a referral from their GP."
  • "There must be a cooling-off period (of at least seven days) after you give consent, before you book the surgery (or pay)."
  • A requirement that the practitioner tells you "the risks and possible complications", the "total cost" including deposits, refunds and "payments for follow-up care", and "the complaints process and how to make a complaint".
  • "All cosmetic surgery must be performed in a facility that is appropriate for the level of risk involved."
  • An endorsement for cosmetic surgery, which Ahpra says "will help consumers know who is trained and qualified to perform cosmetic surgery safely."

Ahpra also warns, about its own register, that "searching the register may not be enough to tell you whether they are qualified and experienced in the specific procedure." That is unusually candid for a regulator describing its own tool.

Here is the part that matters to you. Ahpra registers and regulates practitioners in Australia. I am registered by the Medical Council of Thailand, not by Ahpra. If you are unhappy with my care, Ahpra has no power over me and no register on which to record a finding against me. That is not a criticism of Ahpra; it is what national regulation is. Any facilitator who implies otherwise, or who waves at "international standards" as though they were a regulator, is misleading you.

What the Australian Society of Plastic Surgeons says

The Australian Society of Plastic Surgeons (ASPS) is blunt. It calls cosmetic tourism "a price-driven practice where patients travel overseas to undergo cosmetic surgery procedures", and states:

"Cosmetic surgery is real surgery and like all forms of surgery carries inherent risks."

"Australia holds very high medical standards which are often not met in other countries."

"In the event of post-operative complications, follow-up care is essential."

"ASPS does not recommend combining surgery with having a holiday."

"ASPS strongly advises against overseas cosmetic surgery tourism."

I agree with four of those five without qualification, including the one about holidays: combining an operation with sightseeing is the most common reason I see wounds break down. The fifth is a position, not a finding.

What ASAPS asked the government for after the 60 Minutes programme

On 9 August 2026, Australia's 60 Minutes aired "Destination Disaster," about Australian women left disfigured after cosmetic surgery at a large Bangkok operator. Two days later the Australasian Society of Aesthetic Plastic Surgeons (ASAPS) called for government action, naming the marketing practice it holds responsible: "heavily curated patient stories, before-and-after content and positive recovery experiences [that] can create an impression of safety that may not show complications, recovery difficulties or longer-term outcomes." That criticism is correct, and describes most of the industry I work in.

The statement did not ask for overseas surgery to be banned. It asked for "a review of the regulation of Australian businesses that advertise, facilitate or sell overseas cosmetic surgery to Australians, with a view to ensuring they are subject to equivalent cosmetic surgery-specific advertising safeguards", and "a Federal Government-funded national public education campaign on the risks of cosmetic surgery tourism."

I support both. An Australian company selling you an operation in Bangkok should face the same advertising rules as one selling you an operation in Sydney. There is no principled reason for the gap, and the gap is where the worst marketing lives.

ASAPS's patient guidance is worth reading in full. It states that "the risks of having cosmetic surgery overseas can be serious, and in some cases, life-threatening"; that "overseas facilities often lack the strict safety standards, accreditation, and hygiene protocols required in Australia"; that "in some countries, surgeon titles aren't protected"; and that "in some countries, the surgeon you meet may not be the one who performs your operation." It estimates roughly 15,000 Australians travel overseas for cosmetic procedures each year, spending about $300 million, with revision needed in up to 7 per cent of cases, and advises that "in Australia and New Zealand, patients are advised not to fly for 6–8 weeks post-surgery" because of the risk of deep vein thrombosis and pulmonary embolism.

What Smartraveller tells you before you fly

The Australian Government's Smartraveller service does not soften anything:

"There are always risks with medical procedures. You could suffer from complications, or you could die."

"If you have complications they can't treat overseas, you may need medical evacuation back to Australia. This can cost hundreds of thousands of dollars."

"Basic travel insurance policies rarely cover medical tourism."

Its advice is to talk to your doctor in Australia and get a health check at least six weeks before you go. I would add only this: bring that doctor's letter and your medication list with you.

What the Better Health Channel says about Thailand specifically

Victoria's Better Health Channel names Thailand first among destinations, and puts the saving at "as much as 80 per cent off the cost of the same procedure at home." It lists the risks as "lower quality surgical skills and practices that can lead to infection or disfigurement", "antibiotic resistant bacteria that can cause complications after surgery and may not be treatable", and "lack of follow-up after the operation."

On money it says "Medicare Australia is unlikely to cover overseas medical treatment, and private health insurance may not cover it either", and notes Australia has reciprocal healthcare agreements with only "11 countries, and these are mostly for emergency treatment only." Thailand is not one of them.

Its sharpest sentence is about liability: "The person having the procedure carries all the risk."

What NZAPS tells New Zealanders about ACC

The New Zealand Association of Plastic Surgeons states that "long flights and changes in altitude and pressure can complicate recovery from surgery, increasing the risk of blood clots, deep vein thrombosis (DVT), and other complications", and that "once they return home after their operation, the patient is essentially on their own."

On accident compensation it says:

"ACC does not cover injuries sustained from surgery overseas. New Zealanders needing care will have their emergent needs (eg. infection, wounds opening up) met through the public hospital system, but there is no guarantee that any treatment beyond this will make it through the public hospital waiting list system."

Where these bodies are right, and I will not argue

They are right that cosmetic surgery is real surgery. Augmentation, abdominoplasty and rhinoplasty all carry haematoma (blood collecting under the wound), seroma (fluid collecting), infection, wound breakdown, necrosis (tissue death at the edges of long incisions), nerve injury with numbness or weakness that is sometimes permanent, venous thromboembolism, unpredictable scarring, asymmetry, and the outcome hardest to talk about — a result that is technically sound and that you are nonetheless disappointed by. Distance adds the flight, and the fact that if something goes wrong in week three you are 7,000 kilometres from the person who operated on you.

They are right that follow-up is the weak point of the model, that titles are not protected everywhere, that ghost surgery happens, and that curated marketing creates a false impression of safety.

And some people should simply have their surgery at home, whatever the price difference: anyone with a significant clotting history, anyone whose cardiac or respiratory reserve makes a long-haul flight a risk in itself, anyone with poorly controlled diabetes or a BMI that materially raises wound and anaesthetic risk, anyone travelling alone, anyone whose expectations do not match their anatomy, and anyone who cannot comfortably absorb the cost of a revision. If that is you and a clinic is still encouraging you to book, that tells you something about the clinic.

Where the wording is broader than the evidence

Conceding the fair criticisms does not oblige me to accept imprecise ones. Several widely repeated statements are true as general warnings but wrong as absolute rules.

The statement, as commonly read What the source actually supports What I would do about it
"ACC does not cover injuries from surgery overseas" NZAPS states this flatly. Jonathan Wheeler's 2020 analysis in the Australasian Journal of Plastic Surgery (3(2), doi:10.34239/ajops.v3n2.204) found ACC "will accept a treatment injury only if the surgery has been performed by an appropriately qualified doctor," and that ACC "may cover some patients who have complications as a result of surgery undertaken overseas." Of claims lodged 2014–19, 76 related to overseas procedures. Cover turns on the surgeon's qualifications, not geography. Ask ACC in writing before you book — not the clinic, and not me.
"Overseas facilities often lack the strict safety standards, accreditation, and hygiene protocols required in Australia" ASAPS's word is "often," not "always." Accreditation is a checkable fact for any named hospital. Ask for the accreditation certificate number, and verify it with the certifying body rather than the clinic.
"Revision is needed in up to 7% of cases" ASAPS gives this as an upper bound, not a point estimate. Budget for a revision you may not need.
"The surgeon you meet may not be the one who performs your operation" Correct, and a real practice in parts of the industry. Get the operating surgeon's name and licence number in writing before paying a deposit, and verify it yourself.
"Medicare does not cover overseas treatment" Correct — and Australia has no reciprocal agreement with Thailand. It does not follow that you are uninsurable at home. A GP consultation in Australia attracts its normal rebate whatever prompted it.
"Cosmetic tourism costs the Australian hospital system heavily" An audit at the Royal Brisbane and Women's Hospital found that of 331 breast implant removals, 8 (2.4%) involved overseas-inserted devices, costing that department above AU$110,000 — about 4 per cent of its explantation spending. The burden is real and worth naming, and smaller than "cosmetic tourism crisis" implies. Both can be true.

The one claim I contest directly is the implicit one: that "overseas" is itself the risk factor. It is not. The risk factors are an unqualified operator, an unaccredited facility, an unrealistic timeline, and a patient who was never properly assessed — all four available in Sydney, Auckland and Bangkok alike. Distance makes each harder to detect and much harder to fix, which is a serious argument for caution. It is an argument about diligence, not about latitude.

When to seek care

In a Bangkok hotel room, on a plane, or at home: chest pain, breathlessness, coughing blood, or a hot, swollen, painful calf means an emergency department immediately, by ambulance if you cannot walk. Do not contact your surgeon or clinic first. Pulmonary embolism is the complication most likely to kill you, and it does not announce itself politely.

Also emergency, same hour: bleeding soaking through dressings, a breast or abdomen swelling rapidly and becoming tight and painful (an expanding haematoma), fever above 38.5°C with shaking chills, spreading redness with dusky, blistered or numb skin, or sudden confusion or collapse.

Same-day review, not tomorrow: a wound edge going from pink to grey or black, discharge that has turned cloudy or foul-smelling, pain escalating rather than settling after day three, one-sided calf discomfort, or a temperature creeping up over 24 hours.

Back in Australia or New Zealand, go to a public hospital emergency department for anything in the first two groups. Do not fly, do not wait for a Bangkok appointment, and do not let embarrassment cost you time. Take your operation report and medication list, and send me the notes afterwards; I would rather be woken at 3am than read about it three weeks later.

What I would actually do in your position

I would read the ASPS and ASAPS pages in full rather than in the quotes I have selected. I would ask Ahpra's questions of any overseas surgeon exactly as Ahpra frames them for Australian ones — total cost, refund terms, who pays for follow-up, what the complaint process is — and refuse to proceed with anyone who answered vaguely. I would verify the surgeon's registration myself, and ask in writing who will operate, who will assist, and who reviews me on day one, day three and day seven. I would confirm what is covered with ACC or my insurer, in writing, before paying anything.

If, having done all that, you decide to have your surgery in Australia or New Zealand, you will have made a good decision and I will have helped you make it. That is an acceptable outcome for me. What is not acceptable is that you make it on the basis of a page that only ever shows you half the file.


Dr. Rushapol Sdawat (known to international patients as Dr. Dominic) is a Thai Board-certified plastic and reconstructive surgeon practising at Intrarat Hospital, Bangkok, Medical Licence No. 17689. He holds Thai Board certification in General Surgery (Phramongkutklao Hospital) and in Plastic and Reconstructive Surgery (Ramathibodi Hospital, Mahidol University), has been a member of ISAPS since 2008 and is an international member of the American Society of Plastic Surgeons. Dr. Rushapol holds Thai specialist certification; he is not registered with Ahpra and does not hold Australian or New Zealand specialist registration. His registration can be verified on the Medical Council of Thailand register at checkmd.tmc.or.th.

This article is provided for general information and education. It is not medical advice and cannot substitute for individual assessment by a qualified practitioner who knows your history. Surgery carries risk, including risk of serious complications and of outcomes that do not meet expectations. Results vary between patients.

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Can You Use Your Superannuation for Cosmetic Surgery? The ATO and Ahpra Warning Explained

Compassionate release rarely covers cosmetic surgery. What the ATO requires, what the ATO and Ahpra warned in October 2025, and why we won't help you apply.

By the MedSanctuary Team
Medically reviewed by Dr. Rushapol Sdawat, MD — Thai Board-certified Plastic and Reconstructive Surgeon, Medical Licence No. 17689 · Last reviewed: [SET DATE ON PUBLISH]

Somebody has told you it is possible. Possibly a clinic, possibly a Facebook group, possibly a company that describes itself as helping with "early release applications" and takes a fee for the paperwork. The pitch is always the same shape: the money is yours, you are unhappy now, retirement is decades away, and there is a form.

There is a form. There are also two conditions attached to it that most cosmetic procedures do not meet, a regulator that has been actively looking for practitioners who sign it anyway, and — as of March 2026 — a doctor who lost three months of his registration over one such form.

This page explains the rules accurately, quotes the October 2025 joint warning from the Australian Taxation Office and Ahpra precisely, and tells you plainly where MedSanctuary stands. We do not assist with superannuation applications. We will not write, review, support or refer you for one. The reason is set out below, and it is not modesty.

What compassionate release actually is

Superannuation is preserved money. You cannot normally touch it until you reach preservation age and meet a condition of release. Compassionate release is one of a small number of exceptions, administered by the ATO, which lets you withdraw a limited amount for specific unpaid expenses — including medical treatment for you or a dependant.

Two things follow. The first is that the ATO decides, not your doctor and not a clinic: a medical report is evidence submitted in support of an application, not an approval.

The second is that this is a last-resort provision. ATO Deputy Commissioner Emma Rosenzweig put it directly in October 2025: compassionate release of super "should only be considered as a last resort, where all other options of paying for the eligible expenses have been exhausted."

The two conditions the ATO applies to medical treatment

For medical treatment to be an eligible expense, the ATO requires that both of the following are satisfied.

Condition one. The treatment must do one of three things:

  • "treat a life-threatening illness or injury"
  • "alleviate acute or chronic pain"
  • "alleviate an acute or chronic mental illness"

Condition two. The treatment must be "not readily available through the public health system."

You then need two medical reports: one from a specialist in the area you are applying about, and one from either another registered medical specialist or a general practitioner. Between them, the reports must explain the condition, why the treatment is necessary, and why the public system cannot provide it. If the treatment is to happen overseas, the practitioner must also explain "why you or your dependant can't have the treatment in Australia."

That last requirement is the one people skate past. It is not enough to want the operation done in Bangkok, or to prefer the price. The report has to explain why it cannot be done in Australia at all.

Does a purely cosmetic procedure qualify?

Generally, no.

The ATO's position is that cosmetic treatment is ineligible unless it directly treats one of the qualifying conditions, and that a practitioner should only certify treatment that is "absolutely necessary to treat the eligible condition" — including where a costlier option with cosmetic benefits exists alongside a simpler one that would treat the condition. The ATO gives, as an example of inappropriate practitioner conduct, "preparing inaccurate medical reports to support patients access their super where they are ineligible (for example, for cosmetic purposes)."

Run an ordinary cosmetic request against the two conditions and you can see why it fails.

The situation Condition one: life-threatening, acute/chronic pain, or acute/chronic mental illness? Condition two: not readily available in the public system? Realistic outcome
Breast augmentation for size and shape No Not applicable Does not meet the criteria
Abdominoplasty for loose skin after pregnancy or weight loss, without symptoms No Not applicable Does not meet the criteria
Rhinoplasty for appearance No Not applicable Does not meet the criteria
Liposuction described as treatment for obesity Obesity is a serious condition, but liposuction is not a treatment for it. The Perth case below turned on exactly this Weight management services exist in the public system Does not meet the criteria, and certifying otherwise has ended a registration
Documented, symptomatic condition with genuine functional or psychiatric impact, assessed independently Possibly — this is a clinical judgement, made by treating practitioners with no financial interest in the answer Must be argued on its facts Sometimes eligible. Decided by the ATO on the evidence, and nothing on this page changes that

If your situation genuinely sits in that last row, the people to speak to are your GP and a specialist who is not selling you the procedure. Not us.

What the ATO and Ahpra said together in October 2025

On 16 October 2025 the ATO and Ahpra issued a joint warning. The sentence that matters most is this one, from Deputy Commissioner Emma Rosenzweig:

"some health practitioners and registered agents are inappropriately supporting individuals to access their superannuation on compassionate grounds, particularly for cosmetic procedures that aren't aligned to compassionate release requirements."

Read what that sentence actually says, and what it does not. It does not say cosmetic procedures can never be funded this way. It says that practitioners are inappropriately supporting access for cosmetic procedures that are not aligned to the requirements. The qualifier is doing real work, and anyone who quotes the sentence with the qualifier trimmed off — in either direction — is misleading you.

Ahpra's CEO Justin Untersteiner was quoted in the same release:

"There is an inherent trust that the community places in their practitioners and taking advantage of people in need is never acceptable. Any advice on what procedure is necessary should be based on the patients' best interest and not influenced by financial gain or incentives."

The warning named dental services, cosmetic procedures, weight loss treatment and IVF, and noted that dental requests had more than doubled in two years. It flagged consequences for practitioners including cautions, conditions on registration and referral to a tribunal, plus penalties for false or misleading statements to the Commissioner.

This built on a joint statement issued on 30 May 2025 by Ahpra and the Medical and Dental Boards of Australia, reminding practitioners to "put their patients' best interests first, providing treatment options that are based on the best available information and are not influenced by financial gain or incentives", and to "be honest and not misleading when writing reports to support the release of superannuation."

The Perth case: what happened when a doctor certified liposuction

In March 2026 the Western Australian State Administrative Tribunal decided a case that puts flesh on all of the above. It was reported publicly in April 2026.

A Perth doctor had, in 2018, completed an early release of superannuation declaration form for a patient who had asked for it so she could pay for liposuction. On the form he indicated the patient was accessing her superannuation early because of life-threatening obesity. His clinical notes recorded no weight, no body mass index, and no assessment supporting a life-threatening condition. The patient obtained $18,500.

The tribunal found professional misconduct on the basis of false and misleading information. The doctor's registration was suspended for three months and he was ordered to pay $5,000 towards the Medical Board of Australia's costs.

Two figures reported alongside the decision are worth noting. Ahpra received 95 complaints about health practitioners involved in compassionate superannuation releases between 2019 and 2025. And the regulators are not treating this as a paperwork issue: ATO Deputy Commissioner Ben Kelly said "it is unacceptable for anyone to pressure Australians into accessing their superannuation savings early to pay for overpriced or unnecessary treatments," while Super Members Council chief executive Misha Schubert observed that "super is not designed to be a bandage for the health system."

Notice who carried the consequence. The doctor lost three months of his livelihood. The patient had the liposuction and lost the compounding on $18,500 for the rest of her working life. Nobody in that story came out ahead.

What about surgery performed overseas?

The rules do not change because the operating theatre is in Bangkok, but two of them bite harder.

The report must explain why the treatment cannot be had in Australia. Cost is not that explanation — if it were, the provision would swallow the preservation rule entirely. And an application that is essentially "I want this procedure, at this price, in this country" is precisely the pattern the ATO says it is looking for.

There is also a quieter problem. Medicare does not cover treatment you receive overseas, Australia has no reciprocal health care agreement with Thailand, and Australian private health insurance generally does not cover procedures performed overseas. So the money you released early has gone on the operation, and the cost of fixing anything that goes wrong lands on a bank account that has just been emptied.

Why MedSanctuary does not help with superannuation applications

We do not assist with superannuation applications of any kind. We will not prepare a letter, provide a quotation formatted for an application, review a draft report, or recommend an "early release specialist." If you ask us to, the answer will be no, and we would rather explain why than quietly decline.

The reason is that we have a financial interest in your answer, and the ATO's rules exist precisely to keep people with a financial interest away from the certification. A provider who helps you unlock the money that pays them is not helping you. They are removing the last obstacle between you and a transaction, and calling it service.

So take this as a practical test you can apply to any clinic, facilitator or agent, anywhere:

  • If a provider offers to help you access your superannuation, that is a warning sign about that provider, not a service they are offering you.
  • If a provider recommends a doctor who "understands the process," treat that as the same warning sign with an extra step.
  • If a provider's payment plan, deposit schedule or booking timeline assumes the release will be approved, they are pricing in a decision the ATO has not made.

What it actually costs you to take the money out early

Even where an application is legitimate and approved, the money is not free. Amounts released on compassionate grounds are generally taxed as a superannuation lump sum when they are paid out, with the rate depending on your age and the components of your balance — check that with the ATO or a financial adviser, never with a clinic. And a withdrawal in your thirties or forties removes not just the amount but every year of compounding it would have earned.

Here is the part that does not help us sell anything. If you cannot fund an elective operation without touching preserved retirement money, you almost certainly cannot fund the complication either. Elective surgery has a failure mode that costs more than the surgery: a haematoma returning you to theatre the same night, an infection requiring weeks of intravenous antibiotics, wound breakdown, tissue necrosis along a long incision, a seroma drained repeatedly, a venous thromboembolism, or a revision procedure twelve months later. Any one of those can cost as much again as the original operation, and none of them can be scheduled.

Being unable to absorb that is not a reason to find creative financing. It is a reason to wait. That is not the answer a clinic is supposed to give, and it is still the right one.

What to do instead if you cannot afford surgery right now

Wait and save, on a real timeline with a real number, including a contingency for revision. Get the assessment done anyway — a proper consultation will tell you whether you are even a candidate, and there is no point saving for an operation Dr Rushapol would decline to perform. If your concern has a functional or medical component, see your GP about it on its own merits: some conditions attract a Medicare rebate under strict criteria, and some are managed in the public system. And if the driver is distress rather than anatomy, say so out loud to your GP. That is a legitimate reason to seek help, and surgery is not always the help that works.

When to seek care

If you have already had surgery — funded however it was funded — the thresholds are the same for everyone.

Emergency, immediately, by ambulance if you cannot walk — in a Bangkok hotel, in transit, or back home: chest pain, breathlessness, coughing blood, or a hot, swollen, painful calf. That is possible deep vein thrombosis or pulmonary embolism. Also: bleeding soaking through dressings, a breast or abdomen swelling rapidly and becoming tight and painful, fever above 38.5°C with shaking chills, spreading redness with dusky, blistered or numb skin, or sudden confusion or collapse.

Same-day review, not tomorrow: a wound edge turning grey or black, discharge that has become cloudy, thick or foul-smelling, pain escalating rather than settling after day three, one-sided calf discomfort, or a temperature climbing over 24 hours.

In Australia, go to a public hospital emergency department for anything in the first group. Emergency care is provided on clinical need, and no one will ask how the procedure was paid for. Take your operation report, medication list and surgeon's contact details, and send the notes to your surgeon afterwards.

The one-line version

Compassionate release exists for treatment that is life-threatening, that relieves acute or chronic pain, or that treats acute or chronic mental illness, and that is not readily available in the public system. Most cosmetic surgery is none of those things. The ATO decides, your treating practitioners provide evidence, and anybody with a commercial interest in the outcome — including us — belongs nowhere near the paperwork.


Dr. Rushapol Sdawat (known to international patients as Dr. Dominic) is a Thai Board-certified plastic and reconstructive surgeon practising at Intrarat Hospital, Bangkok, Medical Licence No. 17689. He holds Thai Board certification in General Surgery (Phramongkutklao Hospital) and in Plastic and Reconstructive Surgery (Ramathibodi Hospital, Mahidol University), has been a member of ISAPS since 2008 and is an international member of the American Society of Plastic Surgeons. Dr. Rushapol holds Thai specialist certification; he is not registered with Ahpra and does not hold Australian or New Zealand specialist registration. His registration can be verified on the Medical Council of Thailand register at checkmd.tmc.or.th.

This article is provided for general information and education. It is not medical advice and cannot substitute for individual assessment by a qualified practitioner who knows your history. Surgery carries risk, including risk of serious complications and of outcomes that do not meet expectations. Results vary between patients.

Read More