Key takeaways
- Influencer promotion of clinics can breach two frameworks at once: the AHPRA testimonial ban and the TGA rules on endorsements and prescription medicine references
- The TGA code bars testimonials from anyone receiving payment or free product, and its note expressly includes influencers
- A clinic is responsible for content it engages an influencer to create, including stories and hashtags
- Gifted treatments count as valuable consideration, and disclosure does not cure a breach
Offering a social media influencer free or discounted treatment in exchange for a post about your clinic is a common arrangement. It is also prohibited under two separate pieces of Australian regulation, simultaneously.
Breach 1: AHPRA advertising rules
Under the AHPRA Guidelines for advertising higher-risk non-surgical cosmetic procedures (September 2025), practitioners and advertisers are responsible for all influencer content related to procedures performed at their clinic. A social media post from an influencer describing their experience of a procedure, showing a result, or recommending the clinic is a testimonial. Testimonials are prohibited under section 133(c) of the National Law. The fact that the influencer posted it does not remove the clinic's responsibility. The clinic authorised the arrangement.
Breach 2: clinical practice guidelines
The AHPRA Guidelines for registered health practitioners who perform non-surgical cosmetic procedures (September 2025) state: registered health practitioners must not provide or offer to provide free or discounted procedures to prospective or existing patients, including social media influencers, for promotion of cosmetic procedures or services. This is an absolute prohibition.
The TGA layer
The TGA Advertising Code prohibits testimonials from anyone who has received valuable consideration (including free treatment, discounted treatment, gifts, or accommodation) in exchange for their post. Valuable consideration covers: cash, free treatment, discounted treatment, gifts, flights, accommodation, and any promise of future benefit.
What a clinic can do
A clinic can engage an influencer to endorse its brand (as an endorsement, not a testimonial) if the influencer discloses the paid partnership, is not a current or former health practitioner, and the content complies with all other advertising rules. Any influencer content that describes the influencer's personal experience with a procedure is a testimonial and is prohibited.
What to do now
If your clinic has any active influencer arrangements where treatment was provided in exchange for posts, those posts need to be assessed against the testimonial ban. If they refer to the influencer's personal experience of a procedure, they are non-compliant and need to be removed from all channels the clinic controls.
Skin Marketing audits clinic advertising against the complete AHPRA and TGA framework and produces a written report showing every breach found and the compliant fix. Request a free audit.
Related reading
The AHPRA advertising guidelines, explained in plain English
The five things clinic advertising must never do under section 133 of the National Law, what counts as advertising, who is liable, and how to check your own site.
The TGA advertising code, explained for clinics
What the Therapeutic Goods Advertising Code actually requires, what changed in the TGA's June 2026 guidance, and the penalties, with every rule cited to its clause.
Testimonials in cosmetic clinic advertising: what the ban actually covers
Testimonials in cosmetic clinic advertising: what the ban actually covers
Brendan Barnhill
Founder & Head of Digital, Skin Marketing
I built Skin Marketing because that gap is fixable. As the person who creates and authorises the advertising, I am legally exposed alongside the clinic if content is not compliant. That tends to focus the mind. The rules exist. Most agencies simply have not read them.
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