Multiple relationships under the new Code of conduct: it's not just about conflict of interest any more

The Psychology Board of Australia’s Code of conduct came into effect on 1 December 2025. Most of the discussion has been about the big picture. I want to focus on one area I don’t think is getting enough attention.

From “should” to “must”

First, the philosophy. The Code has moved from an aspirational ethics code to a regulatory one, and the language shows it. Where the old APS Code of Ethics said you should, the new Code says you must.

Informed consent is a good example. In the old APS Code it sat fairly simply in 8.2. In the new Code it runs from point (a) all the way to point (l), spelling out in detail what is expected of you.

A lot of the changes are just that: aspirational language becoming regulatory language. But on multiple relationships, I think there is a genuine, fundamental difference.

How it used to work

There are many kinds of multiple relationship. A conflict of interest arises when the role you hold under one hat is incompatible with the responsibilities of another. Treating a husband and wife who are in the middle of divorcing each other is the classic example: you can’t act in both of their best interests.

In the past, psychologists decided for themselves which situations were a conflict of interest and which were simply a multiple relationship. You could look at the relationship, ask whether there was an inherent conflict, a latent one or none, and carry on if there was none.

What the new Code says

Section 4.9 opens by noting that psychologists often find themselves in, or at risk of, multiple relationships that could compromise their objectivity or the safety and effectiveness of their services, or expose clients and others to exploitation.

To see what counts as a multiple relationship, you need the appendix. Broadly, it is where a psychologist provides a service to someone:

• with whom they have, or have had, a non-service association: a friend or business partner;
• to whom they provide different services, such as being both treating psychologist and forensic assessor. You can’t treat someone and then write an independent report for their parole board hearing;
• where they have or had a non-service association with associated parties, such as a friend who is your client’s partner, or your business partner who is your client’s employer;
• who has treated the psychologist. So no providing therapy to your own GP or physiotherapist.

Who counts as an “associated party”?

This is the point I didn’t make clearly enough when I first recorded this, and it makes the Code a lot less scary.

Associated parties aren’t everyone in your client’s life. The Code defines them as people or bodies you interact with while providing a service who aren’t the client or a third party: a client’s carers, partner, relatives, friends or employer, other practitioners, and so on.

The key words are “interact with while providing a service”. Your client’s sister is not an associated party just because she exists, or because you happen to know her socially. She becomes one if you deal with her in the course of the service: she comes to a session, you speak with her about your client’s care, or you share information with her. If your friend’s cousin becomes your client and you never interact with your friend about the therapy, that isn’t the kind of multiple relationship this part of the Code is aimed at.

So the test isn’t “do I know anyone connected to this client?” It’s “will someone I already have a relationship with be part of the service I’m providing?”

Then comes the key line. Psychologists must discontinue or avoid multiple relationships unless they reasonably believe they are ethically, legally or organisationally obliged to continue. They should consider consulting an experienced practitioner, and if they do continue, the Code sets out specific steps for managing the risk.

My read is that the default has flipped. All multiple relationships are to be avoided unless you are compelled into them in a way you can’t resist. That is a very different approach from the old Code, which let you judge whether a conflict existed.

Who this affects

If you routinely provide assessments for people you treat, you need to reconsider your practice.

Someone asked me recently: “Don’t we always assess the people we treat?” Yes, but there’s a difference. A diagnostic assessment for someone you plan to treat is part of treatment. An independent assessment for the NDIS, WorkCover or a court, for someone you are also treating, is two roles.

If that combination is part of your business model, think carefully about how you will stay compliant, and talk it through in supervision before the next request lands.

If you want to work through the Code case by case, Rebecca and I built Principles to Practice for exactly this.