The advertising rules for cosmetic clinics

A general practice answers mainly to AHPRA. A pharmacy answers mainly to the TGA. A cosmetic clinic answers to both at once, plus a third set of guidelines written specifically for its procedures. If you own a cosmetic or medical aesthetic clinic, or you inject in one, every piece of your advertising has to pass all three frameworks at the same time, and the strictest rule always wins. This page maps how they stack. It is general information, not legal advice about your clinic.

The TGA prohibition comes first

Start with the hardest constraint. In the TGA’s words: “Most cosmetic injectables contain substances that are in Schedule 4 to the Poisons Standard and, in accordance with the Therapeutic Goods Act 1989 (the Act), cannot be advertised to the public.” The prohibition sits in the Act itself, subsections 42DL(10) and 42DLB(7), and advertising means anything “intended, directly or indirectly, to promote the use or supply of therapeutic goods”.

Indirectly is the word that catches clinics. The guidance for cosmetic services is blunt: “do not refer to prescription medicines or substances – even indirectly. This includes: brand names, acronyms or abbreviations, colloquial names or nicknames, hashtags”. Brand names are out. Class terms are out, the TGA’s own examples include “wrinkle reduction injections” and “dermal fillers”, and everyday variants like anti-wrinkle injections sit inside the same class reference rule, which covers substitute terms. Nicknames are out, the current guidance lists “Tox” and “Haytox” by name. Hashtags built from any of these are out too.

New guidance published on 18 June 2026 pushed the line further in three ways. Implied visual references are now an explicit example: “Graphics of syringes, applicator pens, vials, capsules or pills associated with prescription medicines”, including in logos. The consultation page workaround is closed: a service that “offers consultations for specific medicines, whether directly or indirectly, where the advertising implies that a prescription could or will result from the consultation” is likely unlawful. And even generic phrasing can breach: a clinic post saying it “’specialise[s] in natural-looking cosmetic injectables that enhance your beauty’” “may amount to unlawful advertising of botulinum toxin”.

Price lists are their own breach, separate from naming. Under the code, price information for these goods may only be published by a retail pharmacy, its agent, or an approved medical practitioner, and the TGA’s FAQ applies that directly to this sector: publication of price lists by cosmetic injection services “is likely to contravene the Act”. The full framework is in the TGA advertising code article and the vocabulary detail is in the banned terms article.

The five section 133 prohibitions

The AHPRA layer applies to every regulated health service. Section 133 of the National Law says advertising must not do five things: be false, misleading or deceptive or likely to be, offer a gift, discount or inducement without stating the full terms and conditions, use testimonials, create an unreasonable expectation of beneficial treatment, or directly or indirectly encourage indiscriminate or unnecessary use of health services.

Behind the first prohibition sits a strict evidence standard. Every claim must be supportable by acceptable evidence, which AHPRA defines as peer reviewed research, not anecdotes or before and after observations. Words like safe, effective and pain free mislead without risk acknowledgement. Breaching section 133 is a criminal offence, and each non compliant piece of advertising is a separate offence. The clause level detail is in the AHPRA guidelines article.

The September 2025 layer on top

On 2 September 2025 AHPRA issued guidelines for advertising higher risk non-surgical cosmetic procedures, made under section 39 of the National Law. They cover cosmetic injectables, thread lifts, injection lipolysis, PRP and similar procedures, and they bind everyone who advertises them: practitioners, clinics, and the agencies writing for them.

The additions are specific. No trivialising terms anywhere, including taglines and hashtags, with ‘doll-maker’, ‘magic hands’, ‘sculptor’ and ‘master’ named. If a named individual is advertised as performing procedures, their AHPRA registration number must appear in the ad. No language implying normal ageing or normal features need fixing, and no claims like ‘boost confidence’ without acceptable clinical evidence. No advertising targeted at under 18s, and social media advertising must be marked as adult content. Influencer and ambassador content is high risk and remains your responsibility, covered in the influencer rules article.

Testimonials, including the widget on your homepage

A testimonial is any positive statement about the clinical side of your service: the symptom, the treatment, the outcome, or the practitioner’s skill. They are banned outright. The September 2025 guidelines close the side doors: no linking to reviews on third party sites, no re-sharing positive patient posts, no liking or responding to reviews, and stories posts count even though they expire. AHPRA goes as far as recommending practitioners disable reviews, comments and tagging on their social pages.

The breach hiding in plain sight is the embedded Google review widget. Reviews sitting on Google’s own platform are not your advertising. The moment a widget renders them on your website, they become testimonials you have published. Full detail in the testimonial rule article.

Before and after images

Before and after images are permitted, and they carry the tightest image rules in the framework. Both images must be shown, with the before image first or most prominent. They must match in lighting, angle, background, framing, posture, clothing and makeup, with no editing, filters or retouching. The after image must state how long post procedure it was taken, and outcome images need a prominent disclaimer that results are individual. No emojis on or under the images, no lifestyle shots, no captions like ‘perfect’ or ‘instant’, and separate patient consent specifically for advertising use. One more layer: the TGA states that advertising the prescription medicines themselves through before and after photos has never been compliant. The full checklist is in the before and after article.

Gift cards, discounts and inducements

Offers are not banned. Offers without their full terms and conditions are. A gift card, a discount, a package or a free consultation all sit under the same rule: the complete conditions must appear in the advertisement itself or be clearly linked from it. The classic breaches are a ‘free’ offer where the cost is recovered elsewhere, an instalment amount with no total cost, and eligibility restrictions buried out of sight.

Two extra layers apply in this segment. Anything promoting a prescription only treatment cannot carry a price at all, per the TGA rule above, and a free treatment involving a Schedule 4 medicine is a sample under the code, which bans samples of these goods outright. And under the fifth section 133 prohibition, offers cannot push people toward treatment regardless of clinical need, which is where prize draws and pressure discounts fail.

Your social media history counts

The TGA is explicit that all social media posts, “historical and new, are required to comply”. The 2022 posts still on your feed are judged against today’s rules, not the rules that applied when you posted them. Businesses are also responsible for “user-generated content, such as third-party comments posted on those social media platforms that are controlled by the business”. A follower naming a brand under your post becomes your compliance problem while it stays visible. Disclaimers do not rescue any of it: the TGA states that a disclaimer “does not discharge the obligation to comply with legislation”.

What compliant advertising can look like

After all of that, most owners assume nothing is left. That is not the regulators’ position. The TGA’s guidance says promoting “the type of health practitioner consultations offered by a health service, or the medical conditions a service can treat, without directly or indirectly referring to therapeutic goods, is unlikely to constitute advertising of therapeutic goods”. Its own worked example: “Call our clinic for a consultation to discuss treatment options for migraine”.

In practice that means consultation and practitioner led advertising. Lead with the consultation, the practitioner’s genuine qualifications and experience, and the concerns you treat. Name services by the concern, not the product or the product class. The framing has to be genuine: a consultation page that still signals a specific medicine through imagery, hashtags or old naming fails the June 2026 test above. But a clinic that advertises its people, its consultation process and the concerns it treats, and leaves the clinical conversation for the room, is advertising the way both regulators intend.

Find out where your clinic stands

Three rulebooks, one advertising surface, and most of the breaches sit in plain view: the review widget, the price menu, the syringe in the logo, the 2022 posts still on the feed. The free compliance audit reviews your website, Google Business Profile, social accounts and ads against all three frameworks, current as at the June 2026 guidance, with every finding in writing and cited to the provision it sits under. No call required. The document speaks for itself.