Executive Summary
On 17 June 2026, AHPRA and Australia’s Special Envoy to Combat Antisemitism announced that AHPRA has formally adopted the International Holocaust Remembrance Alliance (IHRA) working definition of antisemitism as a reference tool in its regulatory work, alongside a review of its Vexatious Notifications Framework and the establishment of a practitioner advisory panel.
The Australian Islamic Medical Association (AIMA) supports the underlying objective of protecting healthcare practitioners, staff and patients from discrimination and harassment of any kind, and recognises that genuine antisemitism in healthcare settings causes real harm and must be addressed. However, AIMA holds significant concerns about the design, scope and likely impact of this initiative, particularly its potential to disproportionately affect Muslim, Arab and Palestinian healthcare practitioners, who have already experienced a comparable wave of notifications since October 2023.
This statement sets out AIMA’s concerns, draws on comparable international experience, and proposes recommendations intended to achieve AHPRA’s stated goal, a healthcare system safe for everyone, without entrenching unequal protection or chilling legitimate professional and humanitarian expression.
About AIMA
The Australian Islamic Medical Association represents Muslim healthcare practitioners and advocates for a health system grounded in equity, compassion and justice. AIMA’s advocacy is informed by the Islamic values of compassion, justice and service, which align closely with AHPRA’s own stated commitment to a healthcare system that is safe and fair for the entire community. AIMA has engaged with AHPRA and the Medical Board of Australia previously, including through a 2024 petition addressing the use of the notifications process to target practitioners over their advocacy on the war in Gaza.
Background and Timeline
- October 2023 onward: a significant number of Australian health practitioners, across medicine, nursing, psychology and allied health, became the subject of AHPRA notifications relating to social media posts and public statements about the war in Gaza. AHPRA confirmed that the majority of these notifications did not meet the threshold for formal investigation.
- February 2024: AHPRA updated its social media guidance to clarify that advocacy for peaceful resolution, protection of health workers and civilians in conflict, and calls for accurate reporting would not, on their own, warrant regulatory action.
- Early 2024: AIMA and the Australian and New Zealand Doctors for Palestine jointly petitioned the Medical Board of Australia, raising concerns that vexatious and Islamophobic complaints were being used to target practitioners advocating on humanitarian grounds.
- 17 June 2026: AHPRA and the Special Envoy to Combat Antisemitism announced that AHPRA has adopted the IHRA definition as a reference tool, is reviewing its Vexatious Notifications Framework in response to concerns about antisemitism-related weaponisation, is establishing an advisory panel including practitioners with lived experience of antisemitism-related notifications, and is supporting dedicated research into antisemitism in healthcare settings.
Key Concerns
1. Definitional scope and the risk of conflating political speech with discrimination
The IHRA working definition is accompanied by eleven illustrative examples, the majority of which concern the State of Israel rather than antisemitism in the traditional sense, including statements about Israel’s right to self-determination and the legitimacy of the state. Internationally, legal scholars, civil liberties organisations and even contributors to the definition’s original drafting have cautioned that these examples are frequently applied to good-faith political or human-rights commentary, conflating criticism of a state’s policies with hatred of a people. For practitioners discussing the humanitarian situation in Gaza in a clinical-ethics or human-rights context, this creates real uncertainty about where legitimate professional and personal expression ends and regulatory risk begins.
2. International precedent
Comparable adoptions of the IHRA definition in healthcare and education settings overseas offer a useful, cautionary guide. NHS England’s adoption of the definition in October 2025 has reportedly resulted in disciplinary scrutiny of practitioners over conduct as limited as displaying a small Palestinian flag, and is now the subject of a judicial review challenge on the basis that it restricts lawful professional and political expression. Universities that have adopted the definition have likewise reported students and staff being investigated over commentary critical of Israeli government policy, with the large majority of such complaints ultimately not substantiated. AIMA raises this experience not to suggest AHPRA’s intentions mirror these outcomes, but because the same definitional ambiguity that produced them is now embedded in Australia’s own healthcare regulator.
3. Asymmetry in regulatory protection
AHPRA’s own notification data since October 2023 indicates that practitioners experiencing Islamophobic targeting, including doxxing, public mischaracterisation and coordinated reporting campaigns, were affected in comparable numbers and by similar methods to those now being addressed under the new antisemitism-focused measures. The Vexatious Notifications Framework review, the advisory panel and the dedicated research program announced on 17 June 2026 are each scoped specifically to antisemitism. No equivalent mechanism currently exists for practitioners who have experienced Islamophobia through the same notifications process. AIMA considers this asymmetry inconsistent with AHPRA’s own stated commitment to addressing antisemitism together with all forms of racism and discrimination in healthcare.
4. Implications for practitioner wellbeing and trust
Regulatory notifications are already recognised as a source of significant psychological strain for practitioners, regardless of outcome. Practitioners who have experienced Islamophobic or anti-Palestinian targeting through this process have described feelings of isolation and a loss of trust in the fairness of the system. An asymmetric regulatory response risks compounding this, both by failing to address the discrimination these practitioners have already experienced, and by introducing a new mechanism that some practitioners may reasonably perceive as carrying greater risk for them than for others.
5. Legal and procedural risk for AHPRA
The IHRA definition was developed, and is described by IHRA itself, as a non-legally binding working tool rather than a legal or adjudicative standard. Embedding it directly into a statutory regulator’s decision-making processes, without independent consultation or a clearly articulated legal basis, creates procedural uncertainty and has already attracted legal challenge in comparable jurisdictions. AIMA notes this as a risk to AHPRA’s own regulatory standing, independent of the equity concerns raised above.
AIMA’s Position
AIMA does not oppose AHPRA taking meaningful action against genuine antisemitism in healthcare, nor against any other form of discrimination. Our concern is with the design of the current response: its narrow definitional basis, its asymmetric scope, and the absence of consultation with the communities most likely to be affected by its unintended consequences. A healthcare regulator’s protections should extend equally to all practitioners and patients, consistent with the principle AHPRA itself has articulated.
Recommendations
- Extend the scope of the current Vexatious Notifications Framework review to explicitly include Islamophobia-related and anti-Palestinian notifications, alongside antisemitism.
- Expand the advisory panel to include practitioners with lived experience of Islamophobia-related notifications, with representation comparable to that committed for antisemitism.
- Commission research into the prevalence and impact of Islamophobia in healthcare settings, comparable in scope to the research now being supported into antisemitism.
- Establish a formal consultation process with AIMA and other relevant community and professional organisations before further implementation guidance on the IHRA reference tool is finalised.
- Publish clear guidance reconciling the IHRA reference tool with AHPRA’s existing social media guidance, to ensure practitioners can continue to advocate for humanitarian protection and peaceful resolution of conflict without fear of disproportionate regulatory consequence.
- Commit to an independent review of the impact of these measures after twelve months, including disaggregated reporting on the nature and outcome of notifications relating to both antisemitism and Islamophobia.
Conclusion
AIMA recognises and shares AHPRA’s stated goal of a healthcare system that is safe for the entire community, patients, practitioners and staff alike. We believe that goal is best achieved through measures that are consistent, transparent and applied equally to all forms of discrimination. AIMA welcomes the opportunity to work constructively with AHPRA to refine the current approach, consistent with our shared commitment to compassion, justice and the equal dignity of every person who gives or receives care.
Contact
Australian Islamic Medical Association
For further enquiries, please reach out to us at admin@aima.org.au.
