Three laws. Most agencies know none of them.
Australian cosmetic and skin clinic advertising is governed by three separate regulatory frameworks. Publishing content that breaches any of them is a criminal offence. Skin Marketing is built around knowing these rules at a granular level and applying them to every piece of work before it leaves the desk.
Book a strategy callWhy I Built Skin Marketing
Some agencies publishing content for clinics have never read the AHPRA advertising guidelines. Every non-compliant post they publish is a separate criminal offence, and the clinic wears it.
Practice managers know the feeling. You brief an agency, they deliver content that looks professional, and six months later you have a detailed report and the same appointment gaps. You also have no idea whether any of it was compliant.
I built Skin Marketing because that gap is fixable.
Every piece of content I produce is checked against three regulatory frameworks before it reaches you: the AHPRA guidelines for advertising a regulated health service, the September 2025 rules for higher-risk cosmetic procedures, and the TGA advertising code. That check covers:
- Banned terms in copy, metadata, and ad text
- Before and after image requirements
- Testimonial compliance across all channels
- Practitioner registration number requirements
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.
This matters because the liability sits with the clinic. Up to $10,000 per offence for a body corporate. Each piece of non-compliant content is a separate count.
Beyond compliance, I measure work by one thing: patient bookings. Not impressions. Not reach. The campaigns I run and the content I produce are built to put patients in your appointment calendar.
When you work with Skin Marketing, you deal with me directly. Every strategy, every campaign, every piece of copy. No account managers, no handoffs, no explaining your clinic's context to a different person every month.
Founder & Head of Digital
Brendan Barnhill
The problem with most agencies
Most digital marketing agencies working with cosmetic and skin clinics have no idea that three separate pieces of Australian law govern what can and cannot appear in their client's advertising. They write copy that sounds compelling, publish it, and unknowingly expose their clients to prosecution.
They don't know the rules
Agencies outside healthcare rarely read AHPRA guidelines or TGA advertising codes. They default to standard copywriting practices that happen to be illegal in this context.
Each breach is a separate offence
A campaign with ten non-compliant posts is ten separate criminal offences. Penalties apply per piece of content, not per campaign or per month.
"My agency did it" is not a defence
Under Australian health advertising law, the practitioner who authorises the advertising is the advertiser. Delegating to an agency does not transfer legal responsibility.
Brendan is legally exposed too
As the person who creates and authorises advertising on behalf of clinics, Brendan is a co-advertiser under Australian law. He is not just professionally motivated to get compliance right, he is legally obligated. This is what "skin in the game" actually looks like: if content is non-compliant, he faces the same exposure as the clinic. That creates a very different standard of care than an agency that is simply billing for deliverables.
The three regulatory frameworks
Every piece of content Skin Marketing produces is checked against all three before it is delivered.
AHPRA guidelines for advertising a regulated health service
Health Practitioner Regulation National Law, section 133 (December 2020)
This is the foundational law that applies to every clinic in Australia offering a regulated health service. All advertising must not:
- Be false, misleading, or deceptive
- Offer a gift, discount, or inducement without stating full terms and conditions in the advertisement
- Use testimonials or purported testimonials
- Create an unreasonable expectation of beneficial treatment
- Directly or indirectly encourage indiscriminate or unnecessary use of regulated health services
Penalties: up to $5,000 per offence for individuals, up to $10,000 per offence for body corporates. Each non-compliant advertisement is a separate offence.
AHPRA guidelines for higher risk non-surgical cosmetic procedures
September 2025, applies specifically to cosmetic clinics
These guidelines layer additional obligations on top of the foundational law for cosmetic procedure advertising. Key obligations include:
Testimonials banned in full
Includes re-sharing patient posts, liking patient reviews, responding to reviews on social media, and time-limited stories from patients.
Before and after image rules
Both images must appear, before image first, no filters or editing, consistent lighting and framing, timing statement, and individual outcomes disclaimer on every image.
Banned phrases
Perfect, ideal, painless, gentle, safe, quick, easy, happier you, best version of yourself, restore self-esteem, flawless, youthful, doll, barbie, magic hands, sculptor, artist, master, world's best.
AHPRA registration numbers
Required in any advertising that names a practitioner individually.
No lifestyle imagery
No beach, poolside, bedroom, or hotel backgrounds in cosmetic procedure advertising.
No emojis in ad text
Cannot appear in advertising copy or in responses to patient images.
No psychological benefit claims
Cannot claim confidence, self-esteem, or life improvement outcomes without peer-reviewed clinical evidence.
No normalising body image
Cannot imply that normal ageing, normal body shapes, or normal facial features are problems requiring correction.
TGA Advertising Code: cosmetic injectable terms and testimonials
May 2024 (banned terms) and June 2022 (testimonials)
The Therapeutic Goods Administration prohibits the use of specific terms in any marketing for cosmetic clinics because these terms lead a reasonable consumer to understand the intent is to promote prescription-only medicines. These terms cannot appear in websites, ads, social media, blog posts, metadata, alt text, schema markup, or Google Business Profile descriptions.
Banned terms
- ✕Injectables / injectable clinic / injection clinic
- ✕Dermal filler / biostimulatory filler
- ✕Anti-wrinkle injections / anti-wrinkle treatment
- ✕Wrinkle-reducing injections
- ✕Fat-dissolving injections
- ✕Specific brand names in a promotional context
- ✕Abbreviations or hashtags of any of the above
Permitted terms
- Cosmetic clinic
- Skin clinic
- Medical aesthetics
- Medical aesthetic clinic
- Cosmetic medicine
The TGA also prohibits health practitioners from providing testimonials about therapeutic goods, and prohibits advertisers from using influencers or ambassadors who receive any form of valuable consideration.
The pre-flight compliance check
Every deliverable, before it is sent, is checked against the following. Nothing leaves without passing all of them.
No banned TGA terms
Every page, heading, meta title, alt text, schema property, and Google Business Profile field is checked for restricted terms. This applies to blog posts, landing pages, ad copy, and extensions.
No banned AHPRA phrases
Copy is checked for banned language: no outcome guarantees, no psychological benefit claims, no urgency language linked to health claims, and no normalising of healthy anatomy as a problem to fix.
Testimonials removed or made compliant
No patient testimonials appear in any Skin Marketing deliverable without full compliance review. Re-sharing patient posts, liking reviews, and responding to patient social media content are all flagged.
Before and after images reviewed
If before and after imagery is used, both images must appear together, no filtering, consistent framing, timing disclosed, and an individual outcomes disclaimer applied to every image.
AHPRA registration numbers confirmed
Any advertising that names a practitioner individually must include their AHPRA registration number. This is checked before sign-off.
Disclaimer language verified
Required disclaimers are present and correctly worded. This includes individual results statements, GST-exclusive pricing notation, and terms and conditions for any discounts or promotions.
Important note
Skin Marketing applies these checks as part of every engagement and is not a compliance service or legal adviser. Final regulatory responsibility rests with the clinic and its practitioners. Clinics with specific compliance questions should seek independent legal advice.
What compliant marketing actually looks like
The TGA restrictions do not make clinic marketing impossible. They change the vocabulary. Skin Marketing builds SEO and content strategy around concern-led and outcome-led topics, the questions patients actually search for, rather than treatment names that are now prohibited.
Concern-led content topics
Instead of service pages built around banned treatment terms, content is structured around the problems patients are searching for:
- Forehead lines
- How to get a slimmer face
- Jowls treatment options
- Neck rejuvenation
- Facial sweating
- Broken blood vessels on the nose
- Volume loss in the face
- Bow-shaped lips
High-volume compliant keyword targets
These terms carry significant search volume and are fully compliant under TGA guidelines:
What this means for your clinic
The clinics that adapt their content strategy now, building authority around compliant keyword targets while competitors are still figuring out what they can and cannot say, will hold a significant organic advantage within 12 to 18 months.
Who Skin Marketing works with
Cosmetic procedure clinics
Clinics offering botulinum toxin, thread lifts, PRP, sclerotherapy, injection lipolysis, and related non-surgical procedures. Compliance requirements here are the most complex and carry the highest individual risk.
Skin cancer clinics
Dedicated skin cancer detection and treatment facilities offering full body checks, excisions, and surveillance programmes. Often bulk billing and competing for high-intent local search.
Dermatology practices
Medical dermatology practices with a mix of clinical and cosmetic services. Often require careful separation of regulated and non-regulated service marketing.
GPs with a skin cancer service
General practices that have invested in skin cancer training and equipment and want to build a patient base for that specific service.
Skin Marketing does not work with general dental practices, general practices outside of skin cancer services, or non-clinical beauty businesses. The focus is narrow by design, because compliance requirements, patient intent, and keyword strategy differ significantly across these categories.
Ready to work with someone who knows the rules?
Book a 30-minute call to discuss your clinic's current marketing, what needs to change for compliance, and what a realistic growth strategy looks like from here.
Book a strategy callNo obligations. No pitch deck. Just a direct conversation about your clinic's marketing and what compliance-first growth looks like.