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Ahpra advertising guidelines for cosmetic clinics, explained

26 Sep 2026 6 min read By SimplyGJ

Short answer

Australian cosmetic clinics advertise under three layers of rules. Section 133 of the National Law bans testimonials, misleading claims and unstated inducements. Ahpra’s guidelines add specific rules for cosmetic surgery (from 1 July 2023) and for higher risk non-surgical procedures like injectables (from 2 September 2025). And the TGA bans advertising prescription medicines such as botulinum toxin to the public. Fines reach $60,000 per offence for an individual and $120,000 for a company.

If you run a cosmetic clinic in Australia, your advertising is regulated more tightly than almost any other small business. Testimonials are banned. Before-and-after photos have strict conditions. Prescription injectables can’t be named in public advertising at all.

This guide is for clinic owners, practice managers and the marketers who work for them. It sets out what each set of rules covers, the mistakes that come up most, and how to market a clinic that still grows.

The three layers of rules

Cosmetic clinic advertising in Australia sits under three overlapping sets of rules, and a single Instagram post can breach all three.

The first is section 133 of the Health Practitioner Regulation National Law. It applies to anyone advertising a regulated health service, including clinics owned by non-practitioners.

The second is Ahpra’s guidelines. The general Guidelines for advertising a regulated health service (December 2020) apply to all practitioners. On top of those sit the cosmetic surgery advertising guidelines, in force from 1 July 2023, and the guidelines for advertising higher risk non-surgical cosmetic procedures, in force from 2 September 2025.

The third is the TGA. Botulinum toxin is a prescription-only (Schedule 4) medicine, and the TGA does not allow prescription medicines to be advertised to the public.

What section 133 bans

Section 133 prohibits advertising a regulated health service in a way that:

  • is false, misleading or deceptive
  • offers a gift, discount or other inducement without stating its terms and conditions
  • uses testimonials or purported testimonials
  • creates an unreasonable expectation of beneficial treatment
  • directly or indirectly encourages the indiscriminate or unnecessary use of health services

The penalties went up in 2022. According to Ahpra’s enforcement strategy, the maximum is now $60,000 per offence for an individual and $120,000 for a body corporate. Western Australia is the exception, where the older, lower penalties still apply.

Each post can be a separate offence. That’s the part that makes clinic owners sit up.

Testimonials: the rule that catches most clinics

Testimonials are banned in health advertising. Under Ahpra’s general guidelines, a testimonial is a positive statement about the clinical side of a service: the symptoms, the treatment or the outcome. A comment that only praises your reception staff or the free parking isn’t a testimonial.

The line that matters is control. You aren’t responsible for reviews patients leave on sites you don’t control, like Google. You are responsible for testimonials on anything you run, including your website and your own social media. If you can’t moderate comments there, Ahpra expects you to turn them off.

For higher risk cosmetic procedures, the rule is stricter again. The guidelines prohibit testimonials outright, and that includes influencers or ambassadors reviewing your treatments. If you pay or gift someone to post, their content is your advertising.

Rules for injectables from September 2025

The guidelines for higher risk non-surgical cosmetic procedures cover cosmetic injectables such as botulinum toxin and dermal fillers, plus treatments like thread lifts and injection lipolysis. The main rules, as summarised by Barry Nilsson Lawyers and Ahpra’s own page, are these.

Before-and-after images have to be genuine, of real patients, unedited, and taken with the same lighting, angle and background. The “before” image must be at least as prominent as the “after”, and there must be a prominent warning that the results apply only to that patient. No filters, no airbrushing.

No advertising aimed at, or designed to appeal to, people under 18. No images of anyone under 18.

No glamorising. Lifestyle shots by the pool, emojis showing emotional reactions after a procedure, and words like “gentle”, “safe” or “easy” without risk information all push against the rules.

No offering procedures as competition prizes. Ahpra says it trivialises a serious decision.

What the TGA adds for Botox and other prescription injectables

The TGA rule is simpler and stricter. You can’t advertise a prescription-only medicine to the public. That means you can’t name botulinum toxin or its brands in public-facing advertising, and the TGA has also warned against euphemisms that point to the product.

What you can do is advertise the consultation and the service. “Consultations for lines and wrinkles with our registered nurses” describes a medical service without promoting a medicine.

Old posts count. If your feed from three years ago names the product, it’s still advertising today.

A comparison: what’s allowed and what isn’t

Topic Generally allowed Not allowed
Reviews Genuine Google reviews you don’t control Testimonials on your site or socials, influencer reviews
Before-and-after photos Genuine, unedited, matched, with a warning Filtered, airbrushed or mismatched images
Offers Offers with clearly stated terms Procedures as prizes, offers with unstated terms
Injectables Advertising consultations for a concern Naming botulinum toxin or its brands
Audience Adults Content aimed at or showing under-18s

How to grow a cosmetic clinic inside the rules

The rules take away the easiest tools: glowing reviews on your homepage, flashy before-and-afters, and “20% off” campaigns. What’s left is the marketing that compounds.

Build pages around concerns. People search for “lip filler Brisbane” or “treatment for frown lines”, and a page that explains the options, the risks, the recovery and who performs the treatment can rank without breaching anything. Make sure every page names the practitioner and their registration.

Let reviews happen where you don’t control them. Ask every patient for a Google review. Don’t offer anything in return, and don’t quote the reviews in your ads. Google’s own review policy also bans incentives and selectively asking only happy customers.

Get into AI answers. When someone asks ChatGPT or Perplexity which clinic is good in their suburb, the tools lean on reviews, listings and clear treatment pages. That’s the work we describe on our GEO page.

Audit before you spend. Most clinics we look at have compliance problems in their bios, pinned posts and old promotions. Fixing those first protects everything you build next.

We run SEO and GEO for clinics in Australia through our med spa and aesthetics programme. For clinics in the UK, the equivalent rules sit with the ASA, covered in our guide on advertising Botox in the UK.

Quick answers

What should I fix first?
Social bios, pinned posts and any testimonials on your own site. They’re the most visible and the easiest to find.

Can a compliant clinic still grow from search?
Yes. Concern-led pages, a strong Google Business Profile and genuine reviews work well, and none of them rely on what the rules ban.

How do I know if AI tools recommend my clinic?
Ask for our free AI visibility check. We’ll show you which clinics ChatGPT and Perplexity name in your area.

See all our international services, or read our med spa marketing ideas for more on growing a clinic from search.

This article is general information, not legal advice. Check the current guidelines on ahpra.gov.au and tga.gov.au before you publish.

Questions people ask

What does Ahpra count as a testimonial?

A positive statement about the clinical side of a service, such as the treatment or its outcome. Comments about customer service alone aren't testimonials.

Am I responsible for Google reviews of my clinic?

Not for reviews on sites you don't control. You are responsible for testimonials on your own website and social media, and you shouldn't reuse Google reviews in your advertising.

Can I post before-and-after photos of injectables?

Only if they're genuine, unedited and matched in lighting and angle, with the before image at least as prominent and a warning that results vary. Ahpra's guidelines set these conditions.

Can I name Botox on my clinic's Instagram?

No. Botulinum toxin is a prescription-only medicine, and the TGA bans advertising prescription medicines to the public.

What are the penalties for breaching section 133?

Up to $60,000 per offence for an individual and $120,000 for a body corporate, except in Western Australia, where lower penalties apply.

Do the rules apply to influencers I work with?

Yes. If you engage an influencer or ambassador, you're responsible for what they post about your treatments.

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