The basal leaves of Berkheya cirsiifolia grow in a spiny rosette, the smaller stem leaves are alternate. The oblong leaves are elaborately lobed along their wavy lateral margins. There are thick, white leaf midribs and long spines spaced along the deeply toothed margins. The clasp of the stem by the large leaves is winged and spiny. The blades are glossy and rough from glandular hairs above and white-felted below. The leaf dimensions of the big leaves are about 30 cm long and 8 cm wide.
The specific name, cirsiifolia, recognises the leaf similarity with Cirsium, a genus of thistles (Pooley, 1998; Trauseld, 1969; iNaturalist).