The AHPRA advertising guidelines put five rules on anyone advertising a registered practitioner's services: no false or misleading claims, no gifts or discounts without stated terms and conditions, no testimonials, no unreasonable expectation of benefit, and nothing that encourages unnecessary treatment. Those five come from section 133 of the Health Practitioner Regulation National Law, and the maximum penalty is $60,000 per offence for an individual and $120,000 for a business. Since 2 September 2025, injectables and other higher risk non-surgical procedures also carry extra advertising guidelines: strict conditions on before-and-after images, influencers held to the testimonial ban, and no advertising aimed at under-18s. On top of that, the TGA bans advertising prescription-only medicines, including most cosmetic injectables, to the public. Your clinic, team, education and general loyalty or membership offers can still be promoted. This guide covers each rule and the practical steps that keep marketing compliant.
Updated 2 October 2026
AHPRA publishes guidelines for advertising a regulated health service and a summary of the requirements, but they are principles rather than a list of banned words. Understanding those principles is far more useful than memorising phrases, because your marketing will keep changing even if the rules do not.
Who the AHPRA advertising guidelines apply to
The AHPRA advertising guidelines apply to any registered health practitioner advertising their services in Australia. For cosmetic clinics, that means cosmetic doctors, nurse injectors, dermal therapists who hold a registered health profession, and any clinic they work within. The guidelines apply regardless of channel: website, social media, email, print, SMS, in-clinic signage.
Non-registered practitioners, such as beauticians offering non-invasive cosmetic treatments, are not directly subject to AHPRA's advertising rules, but may still fall under TGA restrictions on advertising regulated goods, and under Australian Consumer Law on misleading conduct. For the purposes of this guide, we are focused on registered practitioners running cosmetic clinics.
The rules also apply to the business entity advertising on behalf of a registered practitioner, not only to the practitioner themselves: section 133 says "a person" must not advertise a regulated health service in the prohibited ways, and the cosmetic procedure advertising guidelines name businesses, corporate entities and non-practitioners as covered. If your clinic's Instagram account promotes a registered nurse injector's services, the guidelines apply to that account even though it is run by a marketing coordinator.
The testimonial ban: what it means in practice
The clearest rule in the AHPRA advertising guidelines is the prohibition on testimonials, which comes from section 133(1)(c) of the National Law. AHPRA defines a testimonial as a positive statement about the clinical aspects of a regulated health service: the symptom, the diagnosis or treatment, or the outcome. Testimonials about clinical aspects cannot appear in advertising for a registered health practitioner's services, in any form. Comments only about customer service or communication style are not testimonials under the same guidelines.
In practice this means:
- No written quotes from patients about their results on your website or social media
- No video testimonials in any promotional content
- No screenshots of positive messages from patients shared in a promotional context
- No asking patients to post about their results and tagging your clinic in a way that becomes advertising
Google Reviews and third-party platforms are more nuanced. AHPRA's guidelines accept that reviews on a third-party site the clinic does not control are outside a practitioner's direct control, and its testimonial tool walks through each scenario. For higher risk cosmetic procedures, practitioners must not interact with positive reviews on those sites either. However, a clinic should not curate, feature, or embed third-party reviews in their own advertising materials. For the full breakdown of what counts as a testimonial and what does not, see testimonials and reviews: what cosmetic clinics can show in Australia.
Reposting a patient's Instagram story about their results, even if the patient posted it voluntarily, can constitute using a testimonial in advertising. Once the clinic shares or amplifies a patient's statement about their outcomes, the clinic has adopted it as advertising. Stick to sharing your work, your brand, and your clinic culture, not patient commentary on results.
Before-and-after photos: where the line sits
Before-and-after photos are one of the most contested areas, because two regulators touch them. AHPRA's guidelines for advertising higher risk non-surgical cosmetic procedures do not ban them outright. They require the images to be genuine photos of the practitioner's own patients, matched in lighting, angle, framing, posture, clothing and makeup, not filtered or retouched, labelled with how long after the procedure the "after" was taken, and never of anyone under 18.
The TGA position is stricter for injectables. Its cosmetic injections FAQ says that where it is apparent the "after" photo results from a prescription-only injectable, the photo is likely to be an unlawful advertisement for that medicine.
The practical position for an injectables clinic: before-and-after images in public-facing advertising, including social media posts, website landing pages and email campaigns, are very likely to breach the TGA rules, and anything that slips past them must still meet every AHPRA condition above. For other procedures, the AHPRA conditions are the test.
In a clinical consultation context, showing a patient results from similar cases as part of informed consent and treatment planning is appropriate. The distinction is between a clinical tool and a marketing asset.
| Context | Compliant? | Why |
|---|---|---|
| Showing results in a clinical consultation (informed consent) | Yes | Clinical tool, not public advertising |
| Posting before-and-after of an injectable result on Instagram | No | TGA treats it as advertising a prescription-only medicine |
| Before-and-after on a password-protected patient portal | Likely yes | Not public-facing advertising |
| Before-and-after in a medical journal or conference presentation | Yes | Educational/scientific, not advertising |
| Sharing a patient's before-and-after that they posted themselves | No | Becomes a testimonial once clinic amplifies it |
These distinctions have specific edge cases, particularly around consent forms and clinic portals. Can you show before-and-after photos in Australia? covers those in more detail.
Education versus advertising: a useful distinction
One of the most practical frameworks in the AHPRA guidelines is the distinction between educational content and advertising. Educational content that explains a condition, procedure or treatment in a balanced, factual way is generally not considered advertising. Advertising is content designed to promote the practitioner's services and encourage people to book.
This means a blog post explaining what a treatment involves, who it suits, how the process works, and what realistic outcomes look like can be published without it constituting an advertisement, provided it does not include claims that encourage the reader to book that specific treatment with your clinic. The content of this very post is an example: it provides information about advertising rules, not a prompt to book a particular clinical service.
You can publish educational content about treatments and conditions freely. What you cannot do is pair that content with promotional claims about your specific results, prices or patient outcomes.
The line becomes advertising when you add: a call to book, a price, a claim about your specific clinic's results, or a comparison that implies your clinic outperforms others clinically. General educational writing stays on the right side of the rules. Promotional writing needs to be reviewed against the guidelines before publishing.
Social media and the AHPRA guidelines
Social media is where most cosmetic clinics run into AHPRA issues, because the format rewards visual results and personal stories, exactly what the guidelines restrict. The rules apply equally to Instagram, Facebook, TikTok, and any other channel.
What you can post: your clinic environment and culture, your team, factual information about treatments and conditions, your values and approach, and educational content that informs without promoting. Your loyalty and membership program can be promoted on social media provided it does not name specific prescription treatments in the offer.
What you cannot post: patient testimonials or results commentary, before-and-after imagery that breaks the conditions above, claims about specific clinical outcomes, and content that names or promotes a prescription-only treatment to a general audience, which the TGA says includes nicknames such as "anti-wrinkle". Influencer partnerships that involve a registered practitioner's services also fall under the guidelines. The 2025 cosmetic guidelines make the clinic responsible for what its influencers and ambassadors publish, including the testimonial ban. AHPRA's social media guidance covers the wider rules.
What happens if a clinic breaches the guidelines
Many AHPRA advertising matters start as a complaint. A patient, a competitor clinic, or a member of the public reports advertising they believe breaches the guidelines, and AHPRA or the relevant National Board assesses it. That is also why non-compliant advertising can sit live for months before it is raised.
Once a complaint is accepted, the usual first step is a request to remove or amend the advertising. Repeated or serious breaches, such as ongoing use of testimonials after a warning, can be escalated under the Health Practitioner Regulation National Law, which covers the practitioner's registration, not just the advertisement itself. Advertising offences carry a maximum of $60,000 per offence for an individual and $120,000 for a body corporate. The clinic as a business entity can also be pursued, separately from the individual practitioner whose service was advertised.
The practical takeaway is not "the odds are low so it does not matter". It is that fixing non-compliant advertising promptly, before it becomes a pattern a regulator can point to, is the difference between a quiet correction and a formal escalation.
| Content type | Compliant? | Why |
|---|---|---|
| Factual blog post explaining a treatment or condition | Yes | Education, not a promotion of your clinic's services |
| Loyalty or membership program advertised without naming a treatment, terms stated | Yes | No prescription medicine named; section 133 requires the terms of any inducement |
| Percentage-off promotion naming a specific injectable | No | Advertises a prescription-only treatment and its price to the public |
| Clinic environment, team or culture content, no patient results | Yes | Does not advertise a health service outcome |
| Gift voucher redeemable across the clinic's services generally | Likely yes | Not tied to a specific regulated treatment or price |
Discounting rules for prescription treatments specifically are stricter again. See can clinics discount injectables in Australia? before running any price-based promotion.
Go deeper: compliance guides for clinic marketing
- TGA and AHPRA rules for loyalty and rewards: how to structure points, tiers and memberships without naming a prescription treatment
- Can clinics discount injectables? What price-based promotions are and are not allowed
- Testimonial and review rules for websites, Google reviews and social media
- Before-and-after photo rules, including the 2025 conditions and the TGA position on injectables
- How to market a cosmetic clinic compliantly, channel by channel
- The best marketing tools for cosmetic clinics and where each one carries compliance risk
Frequently asked questions
What are the AHPRA advertising guidelines for cosmetic clinics?
AHPRA advertising guidelines, built on section 133 of the National Law, prohibit advertising that is misleading, uses testimonials, offers gifts or discounts without stating the terms and conditions, creates an unreasonable expectation of benefit, or encourages unnecessary use of health services. Since 2 September 2025, extra guidelines apply to injectables and other higher risk non-surgical cosmetic procedures. Separately, TGA rules ban advertising prescription-only medicines, including most cosmetic injectables, to the public.
Can cosmetic clinics use before-and-after photos in marketing?
AHPRA does not ban them outright, but its 2025 cosmetic advertising guidelines require genuine, unedited images of the practitioner's own patients, matched in lighting and framing, with the timing stated and nobody under 18. For injectables, the TGA says a before-and-after that shows the effect of a prescription-only injectable is likely an unlawful advertisement, so public before-and-after posts for injectables are best avoided. Showing results in a consultation is a different matter.
Can a clinic use patient testimonials on their website?
No, not about clinical aspects. Section 133 of the National Law prohibits testimonials in advertising a regulated health service, and AHPRA defines a testimonial as a positive statement about a symptom, treatment or outcome. Comments only about customer service are not testimonials. Reviews on third-party sites the clinic does not control are treated differently, but the clinic should not republish them, and for higher risk cosmetic procedures should not interact with positive reviews.
What is the difference between education and advertising under AHPRA rules?
Educational content that explains a condition, procedure or treatment in a balanced, factual way is not considered advertising. Advertising is content designed to promote the practitioner's services and attract clients. The distinction matters: a blog post explaining what a treatment involves is generally education; a post urging readers to book that treatment with your clinic is advertising and must comply with the guidelines.
What happens if a clinic breaches the AHPRA advertising guidelines?
A breach often starts with a complaint, from a patient, a competitor or a member of the public, lodged with AHPRA or the relevant National Board. The regulator can require the advertising to be taken down, issue a warning, and refer serious or repeated breaches for investigation, which can affect the practitioner's registration. Advertising offences under the National Law carry a maximum penalty of $60,000 per offence for an individual and $120,000 for a body corporate.
Can a cosmetic clinic advertise a loyalty program or gift vouchers?
Yes, provided the advertising does not name or price a specific prescription-only treatment and states the terms and conditions of the offer, which section 133 of the National Law requires for any gift, discount or inducement. A loyalty or membership program promoted on points, tiers or general perks advertises the clinic's retention offering, not a prescription medicine.
