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.
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