Pulse ·
AHPRA puts high-volume off-label prescribers on notice
AHPRA issued guidance on 16 September 2026 warning that practitioners prescribing unapproved peptides, GLP-1 weight-loss drugs, or medicinal cannabis in high volumes or after brief consultations may now face investigation without a prior patient complaint. The guidance targets practitioners operating in commercial models where consumer demand drives prescribing decisions.
GPs should ensure every off-label prescribing decision has a documented clinical rationale, adequate health records, and reflects current clinical evidence rather than patient demand or commercial pressure.
The regulator has been watching.
AHPRA released guidance on 16 September 2026 making explicit what many practitioners have quietly known for some time: the bar for prescribing unapproved peptides, GLP-1 weight-loss medicines, and medicinal cannabis has tightened — and the threshold for regulatory scrutiny no longer requires a patient complaint.
This is a shift in posture. From reactive complaint-handler to proactive monitor of prescribing patterns.
For most GPs doing careful, documented, clinically grounded prescribing, this guidance confirms what good practice already looks like. For a smaller cohort operating at the edge — high-volume telehealth models, compounding networks, commercial GLP-1 services — it is a direct warning with enforcement teeth.
What the guidance actually says
AHPRA’s statement targets practitioners prescribing scheduled medicines in what the regulator describes as commercially influenced models — practices built around consumer demand rather than clinical indication.
Three categories are named: unapproved peptides, GLP-1 weight-loss drugs, and medicinal cannabis. These are not fringe substances. All three have legitimate clinical applications and are prescribed legally by GPs in appropriate contexts. What AHPRA is addressing is prescribing that departs from those contexts: brief telehealth consultations, inadequate clinical records, high-volume dispensing patterns, and deviation from professional standards under commercial pressure.
Medical Board Chair Dr Susan O’Dwyer framed it plainly: “A patient may want peptides, but that doesn’t mean they need peptides.” AHPRA CEO Justin Untersteiner was more direct: practitioners should not be responding to patients who arrive after taking advice from “online influencers with zero clinical knowledge.”
The significant change is operational. AHPRA can now investigate practitioners showing red flags without a prior patient complaint. Those red flags include:
- High prescribing or compounding rates of scheduled medicines
- Brief consultations preceding scheduled medicine prescribing
- Inadequate clinical documentation
- Failure to manage conflicts of interest
- Deviation from professional standards under commercial influence
Available regulatory responses include direct action with the practitioner, referral to tribunals, and notification to other agencies governing associated business structures. The range of responses is wide. That breadth is deliberate.
Both sides of this
The practitioners who will read the guidance most uneasily are those operating in the high-throughput space — often telehealth platforms where patients arrive having already decided what they want. For them, this is a direct warning with a clear enforcement signal.
But it lands in a broader context worth holding.
Consumer demand for these medicines has grown for reasons beyond marketing. Obesity treatment pathways in Australia remain limited; access to medicinal cannabis for chronic pain and sleep has outrun the formal prescribing system’s capacity to manage it thoughtfully. Some of the prescribing AHPRA is now scrutinising exists because patients were not being adequately served by the standard-of-care options available to them.
That does not justify inadequate clinical process. It does mean the patients presenting to commercial prescribing models are often arriving with real, unmet clinical need — and wherever those patients end up, they deserve documented, considered care.
The second tension: AHPRA’s proactive monitoring posture is a meaningful extension of regulatory reach. It will deter unsafe prescribing. It will also create uncertainty for practitioners doing careful, well-reasoned off-label prescribing in areas where evidence is emerging faster than guidelines. The line between “evidence-informed off-label prescribing” and “reckless prescribing” is not always self-evident. Documentation and clinical rationale are now not merely good practice — they are the legal defence.
What this means in general practice this week
Documentation is now load-bearing. Every off-label prescribing decision — not just the three categories AHPRA named — should have a clinical rationale recorded. Why this medicine, why for this patient, what evidence base, what monitoring plan. If a decision could not be defended before a tribunal without the health record, the record needs to be better.
Telehealth carries specific risk. The guidance names telehealth prescribing as a context where clinical rigour may be insufficient. If you prescribe GLP-1 medicines or medicinal cannabis via telehealth, the clinical process — history, examination equivalent, documented reasoning — should match what an in-person consultation would require, not be abbreviated because the medium is different.
Know the legal pathway. AHPRA specifically mentioned understanding obligations under the Therapeutic Goods Act. For TGA-approved medicines used off-label, the framework differs from unapproved substances (including many peptides). GPs should be clear about which category their prescribing falls into and what each pathway requires.
Volume is now a risk marker. High-volume prescribing is not inherently wrong — a GP working in a complex chronic disease population may legitimately prescribe more than average. But volume is one of the triggers AHPRA has named. If your prescribing patterns sit in the upper range for these medicines, documentation needs to be correspondingly robust.
The guidance does not create new ethics. It applies existing ethics with a new enforcement posture. Careful, evidence-based, documented prescribing remains what it always was — the right approach. What has changed is that AHPRA is watching without waiting to be told to.
Verdict: yes — this guidance is worth reading. The regulatory risk is real and the enforcement posture is new.
Sources cited
Frequently asked questions
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Can AHPRA investigate a GP for off-label prescribing without a patient complaint?
Yes. AHPRA's September 2026 guidance states the regulator may take direct action against practitioners showing red flags — including high-volume prescribing of scheduled medicines, inadequate documentation, and deviation from professional standards — without requiring a prior complaint. Referral to a tribunal and notification to other agencies, including those governing associated business structures, are also available to the regulator.
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Which medicines are currently under AHPRA's prescribing scrutiny?
AHPRA has specifically named three categories: unapproved peptides (including those provided through compounding or commercial models selling directly to consumers), GLP-1 weight-loss drugs (such as semaglutide or tirzepatide prescribed outside current clinical guidelines), and medicinal cannabis. Telehealth prescribing after brief consultations is a named red flag across all three categories.