Healthcare compliance guide
AHPRA-Compliant Marketing for Australian Health Practices
AHPRA's advertising rules apply to every registered practitioner in Australia and to anyone who advertises on their behalf, which includes practice managers, web developers and marketing agencies. Section 133 of the National Law prohibits five things — advertising that is false or misleading, gifts and discounts offered without their terms, testimonials about clinical care, claims that create an unreasonable expectation of benefit, and copy that encourages indiscriminate use — and you can screen your own copy against them with our free AHPRA advertising compliance checker. The practices that stay out of trouble treat compliance as a step in the publishing workflow rather than something they review after a complaint arrives.
Plain-English guidance, not legal advice.
Written by Sara Smith, Head of SEO, and reviewed by Lucas Durante, Founder, Odin Digital. Rule set independently reviewed by a third party, September 2026.
The five prohibitions in plain English
Section 133 of the Health Practitioner Regulation National Law is short, and almost every compliance problem traces back to one of its five limbs. Read them as five questions to ask of any page, ad or post before it goes live.
1.False, misleading or deceptive advertising
The widest of the five, and where most breaches land. It covers claims you cannot substantiate, qualifications framed to imply more than they are, photographs that are not your own work, and pricing that omits a material condition. Copy can be literally true and still mislead if the impression it leaves is wrong.
2.Offering a gift, discount or inducement without the terms
You may run an offer, but not without stating the terms that apply: expiry, exclusions and what the price covers. A free consultation, a bundled scan or a percentage off all need their conditions where the offer appears, not on a separate page.
3.Using testimonials about clinical care
A testimonial is a positive statement about the clinical aspects of a regulated health service. Practitioners, and anyone advertising for them, cannot use one, including patient comments first published somewhere else.
4.Creating an unreasonable expectation of benefit
Copy that promises a result, implies a treatment is risk free, or presents an outcome as typical when it is not. Guaranteed, permanent, painless and life-changing are the usual culprits, along with recovery times quoted without the range.
5.Encouraging indiscriminate or unnecessary use
Advertising that pushes people towards a procedure they have not been assessed for. Countdown timers, limited-place offers on surgical or injectable treatments, and book-now urgency ahead of assessment are the common versions.
What you can say
Compliance conversations focus on what is banned, which leaves practices nervous about publishing anything. The permitted ground is wide, and it lines up with what patients search before they book.
Registration and credentials
Registration status, registration number, division of registration and recorded qualifications can all be stated plainly, and approved specialist titles can be used by practitioners who hold them.
Years in practice and case volume
Time in practice and procedure volumes are factual and verifiable, so they can be published, provided the number is accurate, current and supported by records.
Procedures and services performed
What you do, who it suits, what is involved, the risks and what recovery looks like is exactly what patients search for. Describe the procedure rather than promising the outcome.
Educational and explanatory content
Condition explainers, preparation guides, aftercare instructions and answers to pre-booking questions are clean ground, and where most healthcare search demand sits.
Comments on non-clinical service
Feedback about parking, wait times, reception or billing is not about clinical care, so it sits outside the testimonial rule. Keep it clearly separated from treatment and results.
Testimonials and Google reviews: where the line sits
This is the single most misunderstood rule in Australian healthcare marketing, and the distinction is simpler than it looks. Reviews about clinical care may exist on third-party platforms such as Google or Facebook, and practitioners are not expected to police what patients independently write.
What you cannot do is turn those reviews into your advertising. That means no embedding a review widget on your site, no pull-quotes on a landing page, no screenshots in a social post, no star ratings in ad copy or structured data tied to clinical care, and no asking, prompting or incentivising patients to leave one — a review request in your recall SMS is solicitation, even when neutrally worded.
Two things remain available. Comments about non-clinical service — parking, wait times, reception, billing, the comfort of the rooms — are not testimonials for the purposes of the National Law, so they can be published if kept away from anything about treatment. And your Google Business Profile rating is displayed by Google, not by you, so a healthy profile still helps you in the map pack. Our guide to clinic reviews and AHPRA works through the practical cases.
The 2023 cosmetic rules
In 2023 AHPRA published dedicated advertising guidelines for cosmetic surgery and non-surgical cosmetic procedures. They sit on top of the general guidelines and are considerably more prescriptive.
- Schedule 4 substances cannot be named by brand. Write anti-wrinkle injections or dermal filler rather than the product name, and do not use nicknames, abbreviations or emojis that stand in for the brand.
- Trivialising language is out. Copy that presents a cosmetic procedure as a lunchtime treat, a quick fix or a routine purchase understates a medical procedure with real risk.
- No influencer or third-party endorsement of a cosmetic procedure, paid or gifted, and no sponsored content built around a patient's experience.
- No promotion through finance or payment plans as a reason to proceed, and no positioning a procedure as affordable to prompt a booking.
- A cooling-off period statement is required for cosmetic surgery advertising, so patients know a consultation is not a booking.
- Before-and-after images are only permitted under strict conditions covering consistency, consent, sequence and the accompanying information.
The Schedule 4 rule catches the most clinics, because it applies to every surface: copy, headings, alt text, file names, hashtags, captions and service names in a booking system.
Before-and-after checklist
Before-and-after imagery is permitted, but only when every condition below is met. If you cannot tick all six for a given set of images, the safe answer is not to publish them.
- Consistent lighting, angle, distance, background and pose across both images.
- No filters, retouching, smoothing or cropping that changes what the image shows.
- Both images are the same patient and the same practitioner's work.
- Written, informed, current consent on file, with an obvious way for the patient to withdraw it.
- The time between the images stated, along with the number of sessions and any adjunct treatment involved.
- A clear statement that results vary between individuals, placed with the images rather than in a page footer.
Google Ads for healthcare: platform policy vs AHPRA
These are two separate tests and both apply. Google's healthcare and medicines policies decide whether your ad is allowed to run at all: certification requirements for some services, restrictions on prescription medicine terms and limits on health-related targeting. AHPRA decides whether the same copy is lawful in Australia, regardless of what Google approves.
An ad can pass Google review and still breach the National Law — review extensions, seller ratings and callouts promising results are the standard examples — and it can be AHPRA-compliant and still be disapproved. Screen every asset twice, and run the AHPRA pass first with the free compliance checker so you are not rewriting approved ads later.
Social media and influencers
Every public post from a practice account is advertising, and so is a comment reply, a story, a reel caption and a pinned highlight. The rules do not soften because the platform is casual. The recurring problems are patient stories posted as content, patient comments left under treatment posts, brand names in captions and hashtags, and countdowns on promotions.
Influencer arrangements deserve their own line. For cosmetic procedures, influencer endorsement is prohibited outright, paid, gifted or discounted. Outside cosmetics, an influencer describing their treatment is still a testimonial. Practitioner-led educational content is the version of social that works: compliant, credible and the format patients respond to.
Websites: the 12-point compliance pass we run before anything goes live
Every healthcare site we build or take over goes through this pass before launch, and again whenever a page or campaign is published.
- 01Every page scanned for testimonials, embedded review widgets and star ratings tied to clinical care.
- 02Protected and specialist titles checked against each practitioner's actual registration.
- 03All named practitioners cross-checked on the public register, with registration numbers displayed.
- 04Outcome language reviewed for guarantees, absolutes and implied risk-free framing.
- 05Offers, packages and bundles checked for full terms and conditions at the point of the offer.
- 06Schedule 4 and Schedule 8 product names removed from public-facing copy, including image alt text and file names.
- 07Before-and-after galleries audited against the conditions above, or removed.
- 08Pricing reviewed so that what is included, excluded and conditional is stated.
- 09Urgency devices, countdowns and scarcity claims removed from treatment pages.
- 10Comparative and superlative claims removed unless they are substantiated and referenced.
- 11Forms, chat and booking flows checked so no automated message promises an outcome or solicits a review.
- 12Structured data, meta titles and descriptions screened, since they are advertising too.
Specialty quick guides
The rules are the same across professions; the pressure points differ by what each practice sells.
Dentists
Dental sites carry more review widgets and smile galleries than any other vertical, which is where the problems start. Procedure pages explaining implants, aligners and endodontics do the ranking work without patient quotes.
Cosmetic surgeons
The 2023 cosmetic guidelines apply on top of the general rules, so galleries, cooling-off statements and consent records must be in order before publishing. Surgeon-authored procedure and risk content carries the page instead.
Cosmetic clinics and med spas
Non-surgical clinics post the most social content, which is where brand names and trivialising language creep in. Pages written around the concern rather than the product stay compliant and still match how people search.
Dermatologists
Medical and cosmetic dermatology sit on one site under two sets of expectations. Separating the medical pages from the aesthetic ones keeps the cosmetic rules where they belong.
Chiropractors
Claims about what adjustment treats are the recurring issue, particularly anything reaching beyond musculoskeletal care. Our guide to the chiropractor advertising rules walks through the language that draws attention and what to write instead.
Physiotherapists
Physio marketing leans heavily on recovery stories, which are testimonials once they touch clinical care. Condition and rehabilitation content, written by the treating clinicians, covers the same search demand without the risk.
Psychiatrists
Mental health advertising needs care with expectation setting and with anything that could identify a patient. Referral pathways, fees and intake information are the pages that convert.
Audiologists
Hearing clinics face device promotion rules as well as the National Law. Our guide to reviews and AHPRA for audiology clinics covers where the line sits between a Google review and advertising it.
Fertility clinics
Success-rate presentation is the whole game. Rates need their denominator, age band and source stated, and patient stories cannot imply a typical outcome.
Vein clinics
Vein work sits between medical and cosmetic, so pages often mix Medicare-relevant treatment with aesthetic framing. Separating the two makes both compliant and easier to rank.
Plastic surgeons
Specialist title use is tightly defined, and how a surgeon is described in page titles, headings and schema all counts as advertising. Accurate credentials are both a requirement and a trust asset.
GP and medical practices
General practices publish the least risky content and still trip on review widgets and bulk-billing offers without terms. Service, appointment and condition pages are what patients search and what practices under-invest in.
The same workflow covers cardiologists, orthopaedic surgeons and pharmaceutical companies, where the TGA advertising code carries as much weight as the National Law. The medical marketing hub sets out how the work is structured across all of them.
Our compliance workflow
Compliance fails when it is a one-off review. We run four fixed steps, and nothing is published outside them.
01Screen
Every draft page, ad, email and social asset is screened against section 133 and, where relevant, the cosmetic guidelines and the TGA code before it reaches the client.
02Practitioner sign-off
A registered practitioner from the practice reads and approves the clinical substance of anything published under the practice name. The approval is recorded with a date and the version approved.
03Publish
Assets go live with consent records, substantiation for any factual claim and the approval reference stored together, so a query can be answered without reconstructing anything.
04Quarterly re-check
Live pages, active ads and evergreen social content are re-screened each quarter, and whenever AHPRA updates its guidance, because the rules move and old pages do not.
Frequently asked questions
Does AHPRA apply to my agency?
Yes. Section 133 of the National Law applies to any person who advertises a regulated health service, not only to registered practitioners. An agency, a web developer or a marketing manager who publishes non-compliant copy can be prosecuted in their own right, and the practitioner remains accountable as well.
Can I show Google reviews on my website?
Reviews can exist on third-party platforms such as Google or Facebook, and you are not required to remove them. What you cannot do is reproduce, embed, quote or screenshot reviews about clinical care on your own site or ads, and you cannot solicit them. Comments about non-clinical service, such as parking or reception, sit outside the testimonial rule.
Can I call myself a specialist?
Only if you hold specialist registration in that field, and only using the approved title. Protected titles are defined in the National Law and using one without the registration behind it is an offence, including in page titles, headings and structured data.
Can I advertise Botox?
Not by brand. Botulinum toxin products are Schedule 4 prescription medicines and their brand names cannot appear in advertising to the public, including hashtags, abbreviations and image file names. Anti-wrinkle injections is the standard compliant description.
Can I offer a discount?
You can, provided the full terms and conditions appear with the offer. For cosmetic procedures you also need to avoid framing the discount, or a payment plan, as a reason to proceed with treatment.
Are before-and-after photos allowed?
Yes, under conditions: consistent imaging, no editing, informed and current consent, and clear information about time frame, sessions and variability of results. Cosmetic procedures carry extra requirements. If any condition cannot be met, do not publish the images.
What are the penalties?
Advertising offences under the National Law carry court-imposed fines of up to $30,000 for an individual and $60,000 for a body corporate per offence. Advertising conduct can also be dealt with as a notification against a practitioner's registration, which is often the more consequential outcome.
Is this legal advice?
No. This is plain-English guidance based on the published AHPRA guidelines and the National Law, written to help you brief and review marketing. It is not legal advice and it does not replace advice about your particular practice, procedures or advertising.
Sources
- AHPRA — Guidelines for advertising a regulated health service
- AHPRA — Advertising resources hub
- AHPRA — Cosmetic surgery advertising guidelines (2023)
- TGA — Therapeutic Goods Advertising Code
This page is plain-English guidance, not legal advice. Check the current AHPRA guidelines and seek your own advice before relying on it for your practice.