What changed on 2 September 2025
Free tool for this topic
Try it: AHPRA & TGA Ad Compliance CheckerAHPRA's cosmetic procedure advertising guidelines took effect 2 September 2025, and they strengthened an already-strict testimonial ban under National Law s133 to explicitly cover influencer content and re-shared patient stories — not just a clinic's own paid testimonials. The update also banned apps, websites, tools or programs that predict a person's appearance post-procedure (or without the procedure), prohibited advertising cosmetic procedures to under-18s outright, and introduced a mandatory 7-day cooling-off period between a first consultation and any procedure for under-18 patients where a procedure is clinically appropriate at all.
Separately, since 1 July 2023 the title "surgeon" — including "cosmetic surgeon" — is legally protected. Only practitioners with specialist medical registration in surgery, obstetrics and gynaecology, or ophthalmology may use it; a general-registration doctor with a cosmetic procedures endorsement cannot, regardless of experience.
What's actually banned
- Testimonials — patient, influencer, or reshared. The National Law's testimonial ban now explicitly covers influencer partnerships and re-shared patient content, including time-limited formats like Stories.
- Before/after imagery. Prohibited for higher-risk cosmetic procedures because it creates an unrealistic expectation of benefit — no consent-based exception.
- Appearance-prediction tools. Any automated app, website or program predicting post-procedure appearance is banned in advertising — a narrower carve-out exists for general skin-analysis tools not tied to a specific outcome.
- Advertising to under-18s. Banned outright, with the 7-day cooling-off period applying to any under-18 patient where a procedure is clinically appropriate.
- Named prescription medicines. Under the Therapeutic Goods Act 1989 (a separate TGA rule, not AHPRA), botulinum toxin (Botox), dermal fillers and other prescription-only or professional-use-only products cannot be named in public advertising — refer to the treatment category generically instead.
- Discounts and inducements without clear terms. A regulated health service advertised with a gift, discount or inducement must state full terms plainly; urgency language pressuring a clinical decision is separately discouraged.
What still converts within these rules
The clinics performing best under AHPRA's restrictions build around three assets the rules don't touch: practitioner credibility (qualifications, experience, specific expertise — genuinely persuasive and entirely compliant), process transparency (what a consultation actually involves, how a treatment plan gets built), and facility quality. None require a testimonial or before/after photo, and all three are exactly what a patient comparing clinics for a personal decision is actually looking for. See our full Australian aesthetic clinic marketing programme for how this plays out in a real campaign structure.
Self-check your own ad copy against every rule above — testimonials, before/after, appearance-prediction, under-18 targeting, inducements, and named prescription medicines — with our free AHPRA & TGA Ad Compliance Checker. It flags the specific phrase that triggers each rule and suggests a compliant rewrite, in your browser, with nothing sent anywhere.
Penalty exposure
Dental practices sit under the same AHPRA framework via the Dental Board of Australia, with breach penalties reaching A$30,000 per breach for an individual practitioner and A$60,000 for a corporation — the same enforcement mechanism applies to medical cosmetic practice. The cost of a compliance review before a campaign launches is trivial next to that exposure.
What we do differently
We build Australian cosmetic and dental campaigns compliant-first: creative reviewed against AHPRA's September 2025 guidelines and TGA rules before a single dollar is spent, AUD budgeting against real benchmarks, and enquiry-to-consultation tracking so spend optimises toward patients who actually show up — not raw click volume. See our Australia practice overview for the full programme.