A broad coalition of Australian healthcare organisations, professional bodies and individual practitioners has mounted a significant challenge to the Australian Health Practitioner Regulation Agency’s (AHPRA) decision to adopt the International Holocaust Remembrance Alliance (IHRA) working definition of anti-Semitism as a reference tool for its regulatory work.

Among those expressing concern are the Australian Islamic Medical Association (AIMA), the Australia Palestine Advocacy Network (APAN), Australian Friends of Palestine Association (AFOPA), Australian and New Zealand Doctors for Palestine, nurses’ organisations, healthcare academics and more than 1,400 healthcare practitioners and over 60 health organisations that have endorsed an open letter seeking clarification from AHPRA.

The controversy follows a joint announcement by AHPRA and Australia’s Special Envoy to Combat Antisemitism, Jillian Segal, on Wednesday 17 June announcing the regulator had adopted the IHRA working definition, alongside a review of its Vexatious Notifications Framework, establishment of a practitioner advisory panel and research into anti-Semitism in healthcare.

AHPRA Chief Executive Justin Untersteiner said the reforms were intended to strengthen protections against discrimination.

“Anti-Semitism costs lives and has no place in healthcare. AHPRA is committed to working with the Special Envoy and partners to eliminate anti-Semitism from the health system, because everyone should feel safe when accessing care.”

AIMA welcomes protection, but raises concerns

In a detailed position statement released on Friday 19 June, AIMA said it fully supports efforts to eliminate genuine antisemitism from healthcare but warned the current approach risks creating unintended consequences.

“AIMA supports the underlying objective of protecting healthcare practitioners, staff and patients from discrimination and harassment of any kind,” the statement says.

However, the association argues that adopting the IHRA definition without broader safeguards could disproportionately affect Muslim, Arab and Palestinian healthcare professionals who have already experienced waves of complaints linked to their public advocacy since October 2023.

According to AIMA, many healthcare practitioners who spoke publicly about humanitarian issues in Gaza became the subject of AHPRA notifications despite the regulator later confirming that most complaints did not reach the threshold for investigation.

The organisation argues that uncertainty surrounding some of the IHRA definition’s accompanying examples could lead practitioners to fear that legitimate discussion of humanitarian issues, medical ethics and international humanitarian law may expose them to professional complaints.

Concerns over freedom of professional expression

AIMA notes that several of the IHRA definition’s illustrative examples relate to the State of Israel rather than anti-Semitism directed at Jewish people, and says international legal scholars and civil liberties groups have cautioned against conflating criticism of a government’s policies with racial or religious hatred.

The organisation also points to overseas experience, particularly within Britain’s National Health Service, where implementation of the IHRA definition has become the subject of legal challenge amid claims that lawful political expression by healthcare workers has been restricted.

Rather than opposing measures against anti-Semitism, AIMA calls for equal protections for all forms of racism.

Its recommendations include extending AHPRA’s review of vexatious notifications to include Islamophobia and anti-Palestinian racism, expanding advisory panels to include affected Muslim practitioners, commissioning comparable research into Islamophobia in healthcare, undertaking formal consultation before implementation and conducting an independent review after twelve months.

APAN calls for suspension

The Australia Palestine Advocacy Network has also called for implementation of the policy to be suspended pending wider consultation.


APAN argues that significant regulatory changes affecting more than 900,000 registered health practitioners should only occur after transparent engagement with affected professional bodies and communities.

Executive member Dr Mohamad Assoum said:

“Anti-Semitism and all forms of discrimination have no place in healthcare, which is why I’m concerned that AHPRA has embedded the IHRA definition into its regulatory work without the transparency, consultation or evidence base a change of this significance demands, in a way that risks treating legitimate criticism of the Israeli government as racism and discouraging health workers from speaking out on humanitarian crises.”

Jewish historian and APAN executive member Jordana Silverstein similarly argued that combating anti-Semitism should not come at the expense of broader anti-racist work.

“As a Jewish person I know that dealing with antisemitism in this way isn’t an anti-racist approach,” she said, calling instead for anti-racism strategies developed in consultation with affected communities.

Victorian nurse Matt, representing Nurses and Midwives for Palestine, said healthcare workers have “a moral, professional and democratic right to criticise any state or government that commits human rights abuses.”

Open letter seeks answers

On Monday 22 June, healthcare workers and students from across Australia submitted an open letter to AHPRA Chief Executive Justin Untersteiner requesting clarification about the regulator’s decision-making process.

The letter emphasises that antisemitism has no place in healthcare but asks why an additional definition was required when Australia’s existing anti-discrimination laws and AHPRA’s Code of Conduct already prohibit discrimination based on race, ethnicity and religion.

Signatories seek clarification regarding:

  • what legal authority underpins the decision;
  • what consultation occurred with healthcare organisations and affected communities;
  • how the IHRA definition will be used during complaint assessments;
  • safeguards protecting lawful political advocacy;
  • equal recognition of Islamophobia and anti-Palestinian racism; and
  • balanced representation on AHPRA’s new advisory panel.

The letter also requests a formal public consultation before the definition is embedded into regulatory guidance or practitioner training.

Wider debate continues

The debate reflects broader international discussion surrounding the IHRA working definition.

Supporters argue it provides an internationally recognised framework for identifying contemporary manifestations of anti-Semitism and protecting Jewish communities from discrimination.

Critics, including some Jewish scholars, human rights advocates and medical organisations—argue that several accompanying examples risk blurring the distinction between antisemitism and criticism of Israeli government policy, potentially creating uncertainty for those speaking on issues relating to Gaza and the occupied Palestinian territories.

For many Australian healthcare workers, the issue has become particularly significant following almost three years of conflict in Gaza, and lately in Lebanon during which international organisations have documented repeated attacks on hospitals, healthcare infrastructure and medical personnel, prompting widespread humanitarian concern and advocacy by medical professionals worldwide.

As discussions continue, healthcare organisations are urging AHPRA to engage in broader consultation to ensure that efforts to combat antisemitism proceed alongside equally robust protections against Islamophobia, anti-Palestinian racism and all other forms of discrimination, while preserving healthcare workers’ ability to advocate on humanitarian and medical ethics issues without fear of disproportionate regulatory consequences.