Find out if your clinic's advertising is putting you at risk
Most cosmetic clinics in Australia are advertising in breach of the National Law right now. Their agencies don't know. Skin Marketing will audit your advertising against the complete AHPRA and TGA framework and show you exactly where you're exposed, in writing, at no cost.
Up to $10,000 per offence for a body corporate. Each piece of non-compliant advertising is a separate count. Three frameworks apply simultaneously.
The rules most agencies have never read
There are three pieces of Australian law that govern what a cosmetic clinic can and cannot publish in its advertising. They apply simultaneously to every piece of content: your website, your Google Ads, your Instagram, your Google Business Profile.
Most agencies working in this space have never read any of these documents. Content that looks professional and well-produced is still non-compliant if it uses a banned term, includes a patient outcome story, or shows a before-and-after image without the correct disclosures.
Framework 1: AHPRA Guidelines for advertising a regulated health service
The foundational law. Under section 133 of the Health Practitioner Regulation National Law, advertising of a regulated health service must not be false, misleading or deceptive; offer a gift or inducement without full terms; use testimonials; create an unreasonable expectation of beneficial treatment; or encourage unnecessary use of regulated health services.
Note: Up to $5,000 per offence for individuals. Up to $10,000 per offence for body corporates. Each piece of non-compliant advertising is a separate offence. These are criminal offences.
Framework 2: AHPRA Guidelines for advertising higher-risk non-surgical cosmetic procedures
Additional hard obligations specific to cosmetic clinics. The rules cover testimonials, before and after images, practitioner titles, banned phrases, body image language, risk information, targeting of vulnerable people, and social media content.
Note: AHPRA proactively audits cosmetic procedure advertising and does not only respond to complaints.
Framework 3: TGA Advertising Code
The Therapeutic Goods Administration prohibits specific terms in cosmetic clinic marketing because they lead a reasonable consumer to understand the intent is to promote prescription-only medicines. These terms are banned across all channels: websites, ads, social media, meta titles, alt text, and Google Business Profile descriptions.
Note: Applies simultaneously with AHPRA requirements across every published channel.
What turns up in almost every audit
These are the most common breaches Skin Marketing identifies when auditing cosmetic clinic advertising.
Banned TGA terms in live advertising
Words including "injectables", "dermal filler", "anti-wrinkle injections", and "fat-dissolving" are prohibited under the TGA Advertising Code. They appear on the majority of clinic websites and in most active Google Ads campaigns.
The title "cosmetic surgeon" used without surgical specialist registration
Under section 115A of the National Law (amended 2023), only medical practitioners with specialist registration in surgery, obstetrics and gynaecology, or ophthalmology can use the title "surgeon". A general practitioner performing cosmetic procedures cannot be advertised as a "cosmetic surgeon", regardless of experience.
Testimonials in active advertising
Testimonials are prohibited under the National Law. The ban is broad: it includes patient stories, before and after captions quoting outcomes, re-shared Instagram posts, Google review badges that include clinical comments, and any positive statement about the clinical aspects of a procedure. Liking or responding to a patient's post on a third-party platform can also constitute using a testimonial.
Non-compliant before and after images
The rules on before and after images are specific. Both images must be shown. The before image must appear first. No filters, no editing, no professional lighting changes between images. A timing statement is required on the after image. An individual outcomes disclaimer must appear on every image. Separate written advertising consent must have been obtained from the patient, separate from consent to the procedure itself.
Banned phrases throughout website and ad copy
A defined list of terms is prohibited in cosmetic procedure advertising: "perfect", "painless", "gentle", "quick", "easy", "ideal", "best version of yourself", "happier you", "flawless", "youthful", "doll", "barbie", and others. These appear routinely in clinic copy.
No risk information
Advertising that mentions a procedure must not minimise or omit the risks associated with it. Most clinic websites describe procedures without any reference to risk.
Urgency language
Phrases including "book before prices increase", "limited appointments available", "don't delay", and "for a limited time only" are prohibited when linked to health services.
What the audit covers
Skin Marketing reviews your publicly visible advertising (website, Google Business Profile, Instagram, Facebook, and any active Google Ads) against all three regulatory frameworks.
The report is plain English. No legal jargon. A practice manager can read it in ten minutes and understand exactly what is wrong and why.
There is no obligation to engage Skin Marketing after receiving the report. If you choose to fix the breaches yourself or through another agency, the report gives you everything you need to do that.
As the person who creates and authorises the advertising, Skin Marketing is legally exposed alongside the clinic if content is not compliant. Every audit is carried out with that in mind.
This audit is for your clinic if:
A good fit
- You operate a cosmetic procedure clinic, skin cancer clinic, or dermatology practice in Australia
- You have an active website and at least one social media presence
- Your current agency has not explicitly audited your advertising against AHPRA and TGA requirements
- You are the practice manager, clinic owner, or medical director responsible for marketing decisions
What you do not need
- You do not need to have a compliance concern already. Most clinics that request an audit are not aware they have one
- You do not need an existing relationship with Skin Marketing
- You do not need to be considering changing agencies
Request your free audit
Skin Marketing will review your advertising and send you a written report within five business days.
Get in touch with your clinic name and website URL
Brendan reviews your publicly visible advertising against all three frameworks
You receive a written report identifying every breach, rule citation, and compliant alternative
Requesting an audit does not create any obligation to engage Skin Marketing. The report is confidential.
Get in touch
Reach out directly and Brendan will get back to you to arrange your audit.
Not ready to request an audit?
Browse the Skin Marketing resources section for plain-English guides to the AHPRA and TGA advertising rules, written for practice managers, not lawyers.
View resources