Before & After Photos: What Injectors Can and Can’t Publish

Why B&A 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 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 indirect references like “anti‑wrinkle injections” or “dermal fillers”).

TGA’s 2025 FAQs explicitly warn that B&A photos that make it apparent the “after” is due to a prescription‑only cosmetic injectable are likely an unlawful advertisement.

Even price lists for Schedule 4 injectables in non‑pharmacy settings are considered advertising and are not permitted.

Plain English: If a reasonable consumer would think the “after” photo happened because of an injectable → don’t post 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 have increased: As of July 2024, max penalties under National Law advertising offences are $60,000 (individual) and $120,000 (corporations) per offence.

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)

(This is the part clinics always get wrong.)

✔ Allowed B&A Photos

(when no injectables are involved and AHPRA/ACL rules are met):

Standard facials
Cosmetic‑level peels
Cosmetic microneedling (not claiming medical‑grade outcomes)
LED therapy
Skincare programs/routines
Cosmetic‑level laser facials (avoid medical indications and device‑grade claims)
→ Ensure the caption and image stay cosmetic, non‑therapeutic, and avoid implying Schedule 4 goods or medical devices with unapproved indications.

Image standards (best practice):

Same lighting, angle, background, expression; absolutely no filters/retouching.
State disclaimer (e.g., “Individual results vary. General information only.”).
Present typical outcomes (not outliers).
Avoid comparative/superiority phrasing.
(These points reflect AHPRA’s emphasis that B&A must not mislead.)

Example (compliant tone):

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

(No device/product names; no therapeutic claims; no guarantees.)

WHAT YOU CANNOT POST

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.

Price lists for injectables in non‑pharmacy settings.

EXAMPLES

Practical Caption Templates (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.” [tga]

(Avoid product/device names; keep claims cosmetic; include disclaimers.)

The above examples (Cosmetic Peel, LED Program, Microneedling) 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.”

✔ This satisfies TGA and ACL requirements for non-injectable cosmetic services.

If an AHPRA-registered practitioner provided or supervised the service, extra rules apply:

Must ensure images are not misleading (same lighting, angle, no filters).
Must 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.

Here’s how the captions should look if an 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 (Save/Share)

□ 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.

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Our AHPRA & TGA Marketing Compliance Pack for Cosmetic Injectors 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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***Disclaimer. Please read!!***

This article is for general information purposes only and should be used solely as general guidance. It does not and is not intended to represent legal advice or other professional advice.