AHPRA advertising compliance: a plain-English guide for practice managers

If you manage a cosmetic procedure clinic, skin cancer clinic, or dermatology practice and you are responsible for marketing decisions, three pieces of Australian law govern what your clinic can and cannot publish in its advertising.

Most marketing agencies working in this space have not read them. This guide summarises what you need to know.

The three frameworks

AHPRA Guidelines for advertising a regulated health service (December 2020)

The foundational law. Under section 133 of the Health Practitioner Regulation National Law, all advertising of a regulated health service must not:

• Be false, misleading or deceptive
• Offer a gift, discount or inducement without stating full terms and conditions
• Use testimonials or purported testimonials
• Create an unreasonable expectation of beneficial treatment
• Encourage indiscriminate or unnecessary use of regulated health services

AHPRA Guidelines for advertising higher-risk non-surgical cosmetic procedures (September 2025)

Additional obligations specific to clinics offering cosmetic procedures. Key rules:

• Testimonials are banned in full, including re-shares, story reposts, likes, and responses to third-party reviews
• Before and after images have specific requirements covering editing, ordering, timing, disclaimers, and patient consent
• Banned phrases include: "perfect", "painless", "gentle", "quick", "safe", "easy", "ideal", "best version of yourself", "happier you", "flawless"
• Lifestyle imagery is banned: no beach, pool, bedroom, or hotel backgrounds
• Entertainment content is banned: no procedure videos with singing, dancing, or trending audio
• Advertising must be marked as adult content on social media
• Practitioners must include their AHPRA registration number when named in advertising

TGA Advertising Code (May 2024)

The TGA prohibits specific terms in cosmetic clinic advertising. Banned terms include: injectables, dermal filler, anti-wrinkle injections, fat-dissolving injections, and their abbreviations. Permitted alternatives: cosmetic clinic, skin clinic, medical aesthetics, cosmetic medicine.

What you are responsible for

If you authorise advertising content, brief an agency to produce it, or have the ability to modify or remove published content, you are an advertiser under the National Law. The clinic is legally responsible for everything published in its name, including content produced by a marketing agency. Delegating to an agency does not transfer legal responsibility. "The agency wrote it" is not a defence.

The most common breaches

• Banned TGA terms in website copy, Google Ads, and meta descriptions
• Testimonials in active advertising, including re-shared patient posts and liked reviews
• Calling the practitioner a "cosmetic surgeon" without surgical specialist registration (illegal since 2023)
• Before and after images without timing statements, outcomes disclaimers, or compliant conditions
• Banned phrases in service descriptions and ad copy
• No risk information included alongside procedure descriptions

What to check right now

• Does any advertising use the words "injectables", "dermal filler", "anti-wrinkle", or "fat-dissolving"?
• Is any practitioner described as a "cosmetic surgeon"?
• Does any controlled channel include patient testimonials, reviews, or re-shared patient posts?
• Do before and after images show only the after, use filters, or lack a timing statement and outcomes disclaimer?
• Does any copy include the words "perfect", "painless", "gentle", "safe", or "quick"?
• Is there urgency language such as "book now", "limited time", or "don't delay"?
• Are risk information and terms and conditions clearly accessible?

If the answer to any of these is yes, each instance is a potential offence.

Getting help

AHPRA cannot advise you on whether your advertising is compliant. Their role is enforcement, not guidance. If you need a compliance review, seek it from your professional association, indemnity insurer, independent legal adviser, or a marketing agency that has built its production process around these rules.