Short answer: if your clinic offers injectables or other prescription-based aesthetic treatments, you are advertising a regulated health service and the National Law applies to everything you publish — website, ads, social posts, email and signage. The rules that catch med spas most often are the prohibition on testimonials, the conditions on before-and-after imagery, offers published without terms, the ban on naming prescription medicines to the public, and copy that trades on appearance anxiety.
Who the rules apply to
The obligations attach to advertising a regulated health service, and to the registered practitioners involved. That includes nurse-led clinics operating under medical supervision, and it includes the business itself, not only the individual injector. A common misunderstanding is that a clinic branded as a spa or studio sits outside the framework; branding does not change what is being advertised.
Responsibility also does not transfer to an agency, a freelancer or a social media manager. Whoever writes the post, the practitioner and the business carry the exposure — which is why compliance review has to sit inside the publishing process rather than at the end of it. The framework we use is on AHPRA-compliant marketing.
The prohibitions that matter most
- Testimonials. Testimonials about the regulated service cannot be used in advertising. That covers website review sections, quoted feedback in ads, screenshots of messages, and reposting a patient's story to your own feed.
- False or misleading content. Including implied claims created by imagery, editing or selective presentation.
- Unreasonable expectation of beneficial treatment. Promising a look, a longevity, or a guaranteed result.
- Offers without terms. Any price, discount, package or gift must carry its terms, expiry and conditions in the same place.
- Encouraging unnecessary use of a health service. This is where seasonal urgency campaigns and bulk-treatment discounts run into trouble.
- Naming prescription medicines to the public. Use anti-wrinkle injections and dermal fillers rather than product brand names.
Social media is advertising
Aesthetic clinics live on Instagram and TikTok, and the framework applies there in full. A reel showing a treatment being performed, a story with a price on it, a post quoting a happy client, a comment naming a product — all of it is advertising a regulated health service.
Two features of social create most of the risk. Filters and editing are built into the platforms and are incompatible with honest treatment imagery. And comments are part of your advertising once you engage with them, so replying to "what product do you use?" with a brand name publishes the thing you avoided in the caption.
Give the person running your accounts a written list of what cannot be posted, and keep prescription product names off it entirely. Influencer arrangements need the same treatment: a paid creator describing their result is a testimonial, and it is your advertising.
Before-and-after imagery
Before-and-after photographs are not banned, but they are only acceptable under conditions, and this is where most med spa breaches occur. The photographs must be genuinely comparable: same lighting, same angle, same distance, same framing, same expression, no make-up differences that flatter the result, and no filters, retouching or editing of any kind.
They also need appropriate consent, and consent needs to be documented and specific about where the images will be used and for how long. Patient characteristics should be comparable to the audience the image is shown to, and qualifying information — that results vary, that individual factors apply, that a consultation and assessment are required — should sit with the image rather than in a footer nobody reads.
The practical checklist for running this properly, including a photography protocol and a consent record, is in the before-and-after photos AHPRA checklist.
Offers, packages and pricing
Price advertising is permitted and often useful, but it has to be complete. A published price needs to state what is included, what is excluded, whether a consultation fee applies, any conditions, and the expiry of any time-limited element. "From" pricing without the qualifying detail is a frequent problem, because it leaves the reader with an expectation the clinic cannot meet.
Volume and loyalty mechanics deserve care. Structures that reward a patient for having more treatment than they need push against the prohibition on encouraging unnecessary use of health services. Prize draws and giveaways involving regulated treatment are worse, because the recipient has not been assessed as suitable.
Consultation-first framing solves most of this. Advertise the assessment, explain that suitability is determined there, and keep pricing information factual rather than promotional.
Language, tone and appearance anxiety
Guidance in this area consistently cautions against advertising that trades on body image insecurity, and it applies to tone as much as to explicit claims. Copy that names a perceived flaw and offers to fix it, imagery that presents one appearance as the standard, and messaging aimed at younger audiences all attract scrutiny.
Compliant, effective alternatives exist. Explain what a treatment involves and who it suits. Describe the consultation and the assessment. Foreground the qualifications and registration of the people performing the treatment. Talk about safety, aftercare and what happens if something does not go to plan. Clinics that lead with clinical seriousness tend to attract better patients anyway.
Building a review process that actually runs
Rules only work if there is a routine. Nominate one person who approves anything public. Keep a short written standard covering the prohibitions above. Run copy — website, ads, captions, email — through the free AHPRA advertising compliance checker before publishing. Keep consent records for every image. Re-audit the website twice a year, because old pages accumulate claims nobody remembers writing.
Then treat it as commercial rather than administrative. A compliant clinic advertises more consistently, because it is not repeatedly taking material down. The wider programme sits on our med spa marketing and medical SEO pages, the paid side is covered in Google Ads for med spas, and the budget implications are set out in what med spa marketing costs in Australia.
Common breaches we find in clinic audits
The same handful of problems appear again and again when we audit an aesthetic clinic's published material, and none of them are exotic.
- A prescription product name sitting in an old service page, a Google Business Profile service description or an image caption nobody has read for two years.
- A reviews section on the website pulling testimonials in automatically through a widget installed by a previous developer.
- A "from" price with no terms, expiry or explanation of what is included.
- Before-and-after images with different lighting, make-up in the after photograph only, or a filter applied by the platform.
- A birthday or seasonal promotion offering a discount for booking multiple treatments in advance.
- Social captions naming a perceived flaw and offering to correct it.
All six are fixable in an afternoon once someone has looked. The reason they persist is that nobody owns the published estate — the website was built once, the profile was set up by a former manager, and the social account is run by whoever has time. Assigning that ownership is the single highest-value compliance step most clinics can take.
