Before & After Photos: What Injectors CAN and CAN’T Publish (AHPRA + TGA + ACL explained)

Content Index

• Why Before & After Photos Are a Compliance Hot-Spot
• The Three Regulatory Frameworks that Apply
• The Golden Rule for Injectables (TGA)
• Why “Overall Impression” Matters More Than Disclaimers
• What the TGA Allows (and Doesn’t)
• AHPRA Rules for Regulated Health Services
• ACL: The Common-Sense Layer Clinics Forget
• What You Can Legally Post (Before & After Images)
• Image Standards That Keep B&A Compliant
• Mandatory Context & Disclaimers (What They Do and Don’t Fix)
• What You Cannot Post (Common Breaches)
• Compliant Caption Examples (Copy-Ready)
• Extra Requirements When an AHPRA-Registered Practitioner Is Involved
• Quick-Start Compliance Checklist
• Protecting Your Clinic, Registration and Brand

Important: This guide explains advertising compliance, not clinical appropriateness. When in doubt, assume the stricter rule applies and seek advice before publishing.

Why Before and After Photos Are a Compliance Hot-Spot

In Australia, advertising rules for cosmetic services intersect across TGA (therapeutic goods), AHPRA/National Law (regulated health services), and the ACL (consumer law). Missteps, especially with before/after images, can quickly turn an innocuous post into unlawful advertising of prescription-only medicines or misleading conduct.

This guide breaks down exactly what you can and can't publish if you provide injectables, skin treatments, medical devices, or any regulated health service.

The Three Regulatory Frameworks that Apply

Before and after content is risky because it can trigger more than one regulator at once. A single post can:

• be unlawful advertising of prescription-only medicines under TGA rules,
• breach AHPRA advertising requirements for regulated health services, and
• mislead consumers under the ACL.

That overlap is why clinics often breach more than one regulator in a single caption, carousel, or Reel.

The Golden Rule for Injectables (TGA)

THE GOLDEN RULE (TGA)

If a result involves or appears to involve a prescription-only injectable (Schedule 4), do not post the before/after.

TGA prohibits advertising prescription-only medicines to the public (including language that would reasonably lead a consumer to understand the result was achieved using prescription-only cosmetic injectables (for example, references to ‘anti-wrinkle injections’, ‘dermal fillers’, doses, prices, or injectable-specific outcomes).

Recent TGA guidance and FAQs warn that before-and-after images that make it apparent the ‘after’ is due to a prescription-only cosmetic injectable are likely to be unlawful advertising.

Public price advertising for Schedule 4 cosmetic injectables (outside limited pharmacy-only exemptions) is not permitted.

Plain English: If a reasonable consumer would think the “after” photo happened because of an injectable → don’t post it.

Why “Overall Impression” Matters More Than Disclaimers

Disclaimers can help with context, but regulators focus on the overall impression of what a consumer would reasonably take from the post.

If your images, wording, emojis, hashtags, or framing still point to injectables or unrealistic outcomes, a disclaimer won’t “fix” it.

What the TGA Allows (and Doesn’t)

You must not:

• Advertise (directly or indirectly) Schedule 4 medicines, including via euphemisms, acronyms, nicknames or hashtags (e.g. “anti-wrinkle”, “lip filler”, “skin booster”).
• Use B&A sets in a way that makes it apparent the outcome is from a prescription-only cosmetic injectable.
• Publish price information for Schedule 4 injectables (outside the strict pharmacy exceptions).

You may:

• Advertise non-S4 cosmetic services (e.g., facials, cosmetic peels, cosmetic-level microneedling/LED) provided there’s no implication of prescription-only goods and claims are consistent, accurate, and non-therapeutic.
• Advertise certain devices (e.g., lasers) if they’re properly regulated (ARTG) and you avoid unapproved indications or exaggerated claims.

AHPRA Rules for Regulated Health Services

If a nurse, doctor, or other AHPRA-registered practitioner delivers or supervises the service, AHPRA’s advertising requirements apply. Key obligations:

• No testimonials (or purported testimonials) about clinical outcomes, anywhere you control (website, social, comments).
• No misleading or deceptive claims; no unreasonable expectations of benefit; include clear terms for any inducements.
• Images/B&A must not mislead (e.g., no filters, avoid glamorisation, and present typical, not exceptional, results).

Penalties can be significant. Depending on the breach, maximum fines can reach $60,000 for individuals and $120,000 for corporations, with additional consequences including registration conditions, reprimands, or prosecution.

ACL (Australian Consumer Law): The “common sense” layer

The ACL prohibits false or misleading representations, regardless of intent.

• Claims must be true, accurate, and evidence-based; images must not create a false impression.
• Watch words like “instant”, “miracle”, “permanent”, or posts that imply exceptional results are typical.

ACL is the “common sense” layer: If it looks too good to be true → it’s illegal.

What You Can Legally Post (Before & After Images)

(This is the part clinics always get wrong.)

Allowed Before & After Photos
(for cosmetic-only treatments where no prescription medicines are involved, and where advertising complies with AHPRA, ACL and TGA requirements)

• Standard facials
• Cosmetic-level peels
• Cosmetic microneedling (no medical-grade or therapeutic claims)
• LED therapy
• Skincare programs/routines
• Cosmetic-level laser facials

→ Ensure images and captions remain cosmetic, non-therapeutic, and do not imply Schedule 4 medicines, medical devices, or unapproved indications.

Image Standards That Keep B&A Compliant

Image standards (best practice):

• Same lighting, angle, background and expression
• No filters, retouching or enhancements
• Typical results only (not outliers)
• Avoid superiority or comparative language

Mandatory Context & Disclaimers (What They Do and Don’t Fix)

Mandatory context:

• Include a variation disclaimer (e.g. “Individual results vary. General information only.”)

Example (compliant tone):

“Results after 3 cosmetic microneedling sessions. Individual results vary. This post provides general information only.”

(No device names. No therapeutic claims. No guarantees.)

Important: Disclaimers help with context, but they never cure a non-compliant image or an injectable “overall impression”.

What You Cannot Post (Common Breaches)

• B&A that depict or imply results from: anti-wrinkle injections, biostimulators, fat-dissolve, skin boosters, PRP (where regulated as biologicals/Schedule 4), or any B&A that indirectly promotes a prescription-only product.
• B&A that glamorise outcomes, target minors, or create unreasonable expectations.
• Testimonials about clinical outcomes or reposts of patient “success stories” on channels you control.
• Public price advertising for Schedule 4 cosmetic injectables (outside limited pharmacy-only exemptions) is not permitted.

Compliant Caption Examples (Copy-Ready)

Cosmetic Peel (B&A)

“Before and after a series of cosmetic peels. No injectables were used. Individual results vary. General information only.”

LED Program (B&A)

“After 6 weeks of LED + skincare routine. Typical results vary by skin type. No filters used.”

Microneedling (B&A)

“3 sessions of cosmetic microneedling. Results are not guaranteed and vary per individual.”

Avoid: product/device names, therapeutic claims, guaranteed outcomes, injectable cues.

The above examples are generally compliant because:

• They do not reference injectables or Schedule 4 medicines.
• They avoid product names and therapeutic claims.
• They include disclaimers like “Individual results vary” and “General information only.”

Extra Requirements When an AHPRA-Registered Practitioner Is Involved

• Ensure images are not misleading (same lighting, angle, no filters).
• Include disclaimers like “General information only. Does not replace professional advice.”
• No testimonials or language implying guaranteed outcomes.
• Avoid inducements or unclear promotional terms.
• Include the practitioner’s name and AHPRA registration number for transparency.

Caption examples (when AHPRA-registered practitioner is involved):

Cosmetic Peel (B&A)

“Before and after a series of cosmetic peels. No injectables were used. Individual results vary. General information only. Does not replace professional advice. Service provided by Jane Smith, RN, AHPRA Registration No. NMW000123456.”

LED Program (B&A)

“After 6 weeks of LED + skincare routine. Typical results vary by skin type. No filters used. General information only. Does not replace professional advice. Service provided by Jane Smith, RN, AHPRA Registration No. NMW000123456.”

Microneedling (B&A)

“3 sessions of cosmetic microneedling. Results are not guaranteed and vary per individual. General information only. Does not replace professional advice. Service provided by Jane Smith, RN, AHPRA Registration No. NMW000123456.”

Quick-Start Compliance Checklist

□ No direct/indirect references to Schedule 4 injectables (incl. euphemisms or hashtags).

□ No B&A where the “after” is obviously due to injectables.

□ No price lists for injectables (unless strictly within pharmacy exceptions).

□ No testimonials/outcome stories on channels you control.

□ Images: same conditions, no filters, typical outcomes, clear disclaimers.

□ Claims are accurate, non-misleading, non-therapeutic (ACL).

□ If an AHPRA-registered practitioner is involved, apply AHPRA guidelines.

□ Remove or fix historic posts that would now breach updated TGA guidance.

Protect Your Clinic, Registration, and Brand

If you’re unsure, assume the stricter rule applies and err on the side of caution. Penalties and enforcement are real, and rising.

Want everything in one place?

Our AHPRA & TGA Marketing Compliance Pack includes: posting policy, website/ad/influencer guides, mandatory wording, B&A rules, practitioner number requirements, hashtag rules, comment moderation, checklists, and compliant vs non-compliant examples, so your team can publish confidently. (Alternatively, ask us for details.)

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Sources & Further Reading

• TGA  Advertising a health service (updated 23 Sep 2024): Prohibitions on public advertising of Schedule 4 medicines; avoiding indirect references and substitute terms. [tga]
• TGA - FAQs: Advertising cosmetic injections (updated 10 Jul 2025): B&A photos linked to injectables likely contravene the Act; price‑list rules; social media and historic content. [tga.gov.au]
• TGA -  What can/can’t be advertised to the public (updated 19 Aug 2025): Prescription‑only medicines are prohibited from public advertising. [tga.gov.au] 
• AHPRA/Medical Board - Advertising a regulated health service: Core prohibitions; penalty increases (July 2024). [medicalboard.gov.au]
• AHPRA -  Summary of the advertising requirements: Images/B&A must not mislead; general advertising obligations. [ahpra.gov.au]
• AHPRA - Testimonials tool: No testimonials or purported testimonials about clinical aspects on channels you control. [ahpra.gov.au]
• ACCC - False or misleading claims: Accuracy, substantiation, and truthful imaging/claims under the ACL. [accc.gov.au]
• APAN/TGA “10 Tips” (PDF): Practical pointers; caution on B&A implying Schedule 4 goods. [cms.apanetwork.com] 

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Disclaimer

We do our best to keep this content accurate and up to date, but laws change, interpretations evolve, and the internet isn’t perfect. Occasionally, information may be outdated or contain errors.

This content is for general information only and isn’t legal advice. If you choose to rely on it, you do so at your own discretion. For advice specific to your business, you’ll need support tailored to your situation.