Possibly, but if your injectables are given by doctors or dentists, it is less straightforward than in a beauty salon. HPCSA Booklet 19 says registered practitioners "shall not charge fees for health services not yet rendered", apart from a short list of exceptions, and a routine booking deposit for a treatment is not on that list. A leading medico-legal insurer has said the guidance is unclear for self-funded care such as cosmetic work. So check with your indemnity provider before you rely on deposits, and lean on informed financial consent, reminders and a lawful cancellation policy.
Deposits are standard across the beauty industry, and many aesthetic clinics borrow the habit. The difference is who holds the needle.
This is a plain-language summary of published guidance, not legal advice. Confirm your own policy with the HPCSA, your indemnity provider or an attorney.
Why the HPCSA's rules apply to your clinic
In South Africa, injectables such as botulinum toxin and fillers may only be administered by registered medical practitioners. The Aesthetic and Anti-Aging Medicine Society of South Africa puts it plainly: "only Medical Doctors or Dentists with further training and acting within their Scope of Practice are allowed to offer these injectables."
Doctors and dentists are registered with the Health Professions Council of South Africa, so their billing is governed by HPCSA ethical guidance, not just by consumer law. If your clinic also offers non-medical treatments delivered by beauty therapists, those sit outside the HPCSA. Your policy may need two parts.
What Booklet 19 says about paying in advance
The HPCSA published Booklet 19, Guidelines on matters relating to ethical billing practices, in June 2024. Section 12 reads:
Health practitioner shall not charge fees for health services not yet rendered, except for costs of prostheses, co-payment at medical aid rates required from patient or it is a foreign patient requiring health services in South Africa, or it is for custom made medical devices which cannot be used or supplied to another patient...
A deposit taken when a client books a toxin or filler appointment is a fee for a service not yet rendered. Unless the client is a foreign patient, it does not obviously fit any of the listed exceptions.
Where the grey area is
Booklet 19 was written with medical scheme billing in mind. EthiQal, a medico-legal indemnity insurer, said in its 2025 Booklet 19 resource sheet that there is "no clear guidance" on advance payment by South African patients who are not on a medical scheme, and that this "requires clarification by the HPCSA", specifically naming people who self-fund care such as cosmetic surgery.
That is the honest position: the text restricts advance fees, the people who insure doctors think it is unclear for self-funded aesthetic work, and the HPCSA has not yet said more. A complaint would be judged by the professional board, which Booklet 19 says is guided by the ethical rules and these guidelines.
What you can do with confidence
| Approach | Status under the guidance | Notes |
|---|---|---|
| Tell clients your fee before treatment | Required (Health Professions Act s53, Booklet 19) | Put prices in writing at consultation |
| Written informed financial consent | Required in writing (Booklet 19 s5 and s11) | A signed estimate covers it |
| Charge for the consultation when it happens | Allowed | It is a service rendered |
| Advance payment from a foreign patient | Listed exception (s12) | Common for medical tourists |
| Reasonable cancellation charge for a late cancellation | Allowed by the Consumer Protection Act s17, with conditions | Must be disclosed at booking |
| Routine deposit at booking for injectables | Unclear | Ask your indemnity provider first |
The cancellation route deserves a closer look. The Consumer Protection Act allows a reasonable cancellation charge on an advance booking, with a hard exception for death or hospitalisation, and the HPCSA expects patients to be told about it when they book. Our guide to charging for no-shows in South Africa sets out those conditions.
Making the consultation do the work
Without a deposit, the consultation becomes your protection:
- Quote in writing. Booklet 19 expects patients to know the fee "prior to the commencement of any fee generating activities" and to give written informed financial consent. Agree the treatment plan and price at consultation and have the client sign it.
- Book the treatment there and then. A client who leaves with a date and a written price is far more likely to return than one who will "call to book".
- Explain the cancellation policy at the same moment, in writing, so it is fair and defensible.
- Remind them. Clients forget aesthetic appointments as easily as any other. Remi sends reminders at 48 hours, 24 hours and 2 hours and lets clients move a booking by replying, so a cancelled slot can be offered to someone else instead of sitting empty.
If you do decide to take deposits
Some clinics will take advice and decide deposits are defensible for their circumstances, for example for a product ordered specifically for one client. If you do:
- get the advice in writing from your indemnity provider or attorney
- tell the client the amount, what it covers and when it is refundable, before they pay
- record their agreement
- treat the deposit as the client's money until the treatment is delivered
Deposits and payment links are optional settings in Remi, so the decision stays with you and your adviser.
Where the phone fits
The deposit question usually starts on a call: "Do I need to pay to book?". Answering it consistently, at 8pm as well as 10am, matters more than the policy itself. An AI receptionist for aesthetic clinics can give every caller the same answer you have agreed, book the consultation and leave anything about reactions or medical suitability to your doctor.
The short version
- Injectables are given by HPCSA-registered doctors and dentists, so HPCSA billing guidance applies.
- Booklet 19 says no fees for services not yet rendered, except listed cases such as foreign patients and custom-made devices.
- A routine booking deposit for injectables is not a listed exception. EthiQal says self-funded care is unclear and needs HPCSA clarification.
- Quote in writing, get informed financial consent, book at consultation and remind clients.
- A reasonable, disclosed cancellation charge under the Consumer Protection Act is a separate, clearer route.
- If you still want deposits, get written advice first.