Dermatology advertising in Australia is governed by the National Law's general advertising obligations, the 2023 cosmetic surgery and cosmetic procedure advertising guidelines, and TGA restrictions on advertising prescription-only medicines to the public. Together these rules shape what can appear in before-and-after images, social media content and any offer copy a practice publishes.
The baseline: National Law advertising obligations
Every regulated health service advertised in Australia, including dermatology, must not be false, misleading or deceptive, must not create unreasonable expectations of benefit, must not offer a gift or inducement without stating the terms, and must not encourage indiscriminate or unnecessary use of a health service. These obligations apply everywhere the practice advertises — the website, paid search, social media, printed material and the Google Business Profile — not only in formal advertisements.
The s.133 testimonial prohibition
Section 133 of the National Law prohibits the use of testimonials in advertising a regulated health service. For dermatology, this covers patient quotes describing treatment outcomes, video testimonials, and reposted reviews that describe a clinical or cosmetic result. It applies regardless of whether the practice wrote the testimonial itself or is simply republishing something a patient said elsewhere — the act of using it in advertising is what triggers the prohibition. Content that describes the practice's service, communication or facilities in general terms, without describing a clinical outcome, sits outside this restriction.
How the 2023 cosmetic guidelines change before-and-after imagery
The 2023 cosmetic surgery and cosmetic procedure advertising guidelines set a specific standard for before-and-after photography used in advertising cosmetic procedures. Both images must be taken under the same conditions — the same lighting, angle, pose, background and, where relevant, the same time of day. Editing or retouching that enhances the "after" image beyond the actual result is not permitted. Documented patient consent is required before the images are used, and the guidelines expect the comparison to be a fair, representative example rather than a best-case outcome. For a dermatology practice offering cosmetic treatments, this means before-and-after content needs a documented process behind it, not an ad hoc collection of clinic photos.
Social media and influencer content
The same guidelines restrict the use of social media influencers, idealised body or skin imagery, and testimonial-like content in cosmetic procedure advertising. A dermatology practice running Instagram or TikTok content promoting cosmetic services should treat that content as advertising subject to the same rules as the website — meaning no outcome guarantees, no borrowed influencer credibility standing in for clinical evidence, and no imagery that implies an idealised result rather than a realistic one. Educational content about skin conditions and general treatment information sits more comfortably within the rules than result-focused promotional content.
TGA limits on advertising prescription-only treatments
The Therapeutic Goods Administration restricts advertising of prescription-only medicines directly to the public. Many treatments used in dermatology, including some cosmetic injectables, involve prescription-only substances. A practice can describe that it offers a category of treatment and explain the consultation process, but should not name specific prescription products in public-facing advertising or make claims about a specific product's effects. This rule sits alongside, not instead of, the National Law obligations above — a practice needs to satisfy both simultaneously.
Practical implications for a dermatology practice
- Before-and-after content needs a documented photography protocol and signed consent, kept on file, before any image is published.
- Reviews should be moderated so that outcome-specific comments are not amplified or reposted, even though a practice generally cannot control what patients post publicly.
- Offer copy for cosmetic treatments needs full terms stated plainly, with no urgency language that misrepresents genuine availability.
- Product naming should stay generic — describing a treatment category rather than naming a specific prescription medicine.
- Staff training matters, because advertising rules apply to anything published under the practice's name, including social posts made by staff on the practice's behalf.
What this looks like in day-to-day marketing
In practice, compliant dermatology advertising tends to read as informative rather than persuasive: what a treatment involves, who performs it, what a consultation covers, and how to book. Results-focused claims, comparative superiority statements and emotionally charged urgency are the recurring patterns that create risk, and they are also, generally, not necessary for a well-run practice to generate enquiries.
How these rules interact with each other
It helps to think of these obligations as layered rather than separate. The National Law's general prohibition on misleading advertising and unreasonable expectations of benefit applies to everything a practice publishes. The 2023 cosmetic guidelines add a more specific, procedure-focused layer on top of that for cosmetic content, particularly imagery. The TGA's restriction on prescription medicine advertising is narrower still, applying specifically to naming or promoting a prescription-only product. A single piece of content — a social media post about an injectable treatment, for example — can need to satisfy all three at once, which is why a documented review process before publishing matters more in dermatology than in many other specialties.
Who is responsible for compliance
Responsibility sits with the practice and the individual practitioners named in the advertising, not with a marketing agency or a social media manager acting on the practice's behalf. This means a practice should retain final sign-off on any advertising content, even where day-to-day production is outsourced, and should keep records of consent forms, photography protocols and approved offer wording in case a complaint or audit requires them. Treating compliance review as a standing step in the content process, rather than an occasional check, is the most reliable way to avoid the recurring issues regulators tend to flag.
Keeping up with regulatory change
Advertising guidance in this area has been updated more than once in recent years, and further changes are reasonably likely given ongoing scrutiny of cosmetic advertising nationally. A practice that treats its compliance documentation as a fixed, one-time exercise risks falling out of step with current expectations. Reviewing the AHPRA and Medical Board of Australia guidance annually, and whenever a new campaign type or platform is introduced, keeps the practice's advertising aligned with the current standard rather than the standard that applied when a page or campaign was first built.
Building this into an ongoing marketing programme
These rules should shape every channel a dermatology practice uses, from paid search through to the practice's Google Business Profile, and they apply equally across the broader medical SEO work we do for other specialties. Before publishing new creative, run it through the free AHPRA advertising compliance checker, and see our AHPRA-compliant marketing page for the fuller set of principles behind this guide.
For how these rules apply specifically to paid campaigns, see Google Ads for dermatologists, and for how they apply to the practice's free local listing, see the Google Business Profile checklist for dermatology clinics.
