Is Your Clinic Accidentally Breaching AHPRA? 10 Red Flags Every Injector Misses

Content Index

• Why AHPRA Advertising Compliance Matters for Injectors
• How AHPRA, TGA and ACL Intersect
• The 10 Most Common AHPRA Advertising Red Flags Clinics Miss
• Red Flag 1: Using Testimonials in Advertising
• Red Flag 2: Before & After Images That Create Unrealistic Expectations
• Red Flag 3: Superlatives and Superiority Claims
• Red Flag 4: Creating Unreasonable Expectations of Benefit The danger of overselling benefits.
• Red Flag 5: Inducements and Urgency Tactics
• Red Flag 6: Incorrect or Vague Titles and Credentials
• Red Flag 7: Failing to Moderate Comments, Tags and Reposts
• Red Flag 8: Expectations Implying guaranteed or typical results
• Red Flag 9: Giving Personalised Clinical Advice in Social Content
• Red Flag 10: Glamorised or Aspirational Content Targeting Vulnerability
• Quick AHPRA Compliance Checklist
• Frequently Asked Questions
• How to Market Confidently Without Risking Your Registration
• Sources & Further Reading

Advertising rules for cosmetic clinics are strict, and many injectors breach them without realising.

What feels like “normal marketing” (before-and-after photos, captions, comments, or promotions) can quickly become unlawful advertising once AHPRA rules apply. Social media is where clinics get caught out most often.

Why AHPRA Advertising Compliance Matters for Injectors

If you advertise injectables or any regulated health service, your content must meet AHPRA’s advertising requirements under section 133 of the National Law, and separate rules may also apply under the TGA (therapeutic goods) and Australian Consumer Law (ACL). Breaches can lead to prosecution and significant penalties, plus conditions on registration.

Scope of this guide: This blog covers general AHPRA advertising requirements (for all regulated health services) and highlights TGA and ACL touchpoints clinics commonly overlook, particularly on social media.

Most AHPRA advertising breaches don’t happen because clinics are careless, they happen because the rules are misunderstood or applied inconsistently.

How AHPRA, TGA and ACL Intersect

Cosmetic clinic marketing often sits at the crossroads of three sets of rules:

• AHPRA / National Law: governs advertising of regulated health services (including bans on testimonials and misleading advertising).
• TGA: regulates advertising of therapeutic goods (including strict rules about prescription-only medicines and some devices).
• ACL: prohibits misleading or deceptive conduct and “too good to be true” representations.

That’s why one post can trigger multiple regulators at once, even if it looks harmless at first glance.

The 10 Most Common AHPRA Advertising Red Flags Clinics Miss

The red flags below are the issues AHPRA most commonly sees in cosmetic clinic advertising, particularly on social media. Individually, they may seem minor. Together, they can amount to advertising that is misleading or creates an unreasonable expectation of beneficial treatment under the National Law.

Red flag 1 – Using testimonials in advertising

What’s the issue? The National Law prohibits testimonials (or purported testimonials) in advertising regulated health services. That includes patient comments about clinical care, outcomes, or practitioner skill on platforms you control (website, socials), and even re-posting patient content with outcomes. This applies even if the testimonial is unsolicited or left by a patient without prompting.

Do this instead: Allow general feedback about non-clinical aspects (e.g., booking experience) only if it doesn’t venture into clinical outcomes, and don’t republish clinical reviews. On owned channels, moderate or remove comments that read like outcomes or praise of clinical care.

Red Flag 2 - Before/after images that create unrealistic expectations

What’s the issue? AHPRA treats images/photos as advertising; they must not be misleading or create an unreasonable expectation of benefit. The Medical Board’s cosmetic surgery guidance shows how poor-quality or glamorised before/after sets breach the rules (lighting, posture, editing, emojis, lifestyle shots, outcome hype).

Do this instead:

• Use consistent lighting, angle, framing; avoid filters/retouching; never use stock images that imply patient outcomes.
• Provide balanced information.

Red Flag 3 - Superlatives like “safe”, “best”, “superior”, or “expert”

What’s the issue? Claims that overstate benefits or imply superiority can mislead or create an unreasonable expectation of beneficial treatment, both prohibited.

Do this instead: Use plain, evidence-based descriptions of the service and practitioner credentials; avoid comparative claims.

Red Flag 4 - Creating Unreasonable Expectations of Benefit

What’s the issue? 

Do this instead: Focus on realistic, balanced messaging. Avoid language or imagery that oversells outcomes or downplays recovery. Make it clear that suitability and outcomes vary and are assessed during consultation. 

Red Flag 5 - Inducements and urgency (“limited time”, “don’t miss out”)

What’s the issue? You may only offer inducements if terms and conditions are clearly stated and the advertising does not encourage unnecessary or indiscriminate use of a regulated health service.

Do this instead: If you run promotions, state T&Cs in the ad itself (not buried); avoid pressure tactics that could push vulnerable consumers.

Red Flag 6 - Vague or incorrect use of titles/credentials

What’s the issue? Misleading titles, implied specialist status, or ambiguous credentials in advertising breach the guidelines. (E.g., protected titles like “surgeon” have strict use rules; don’t overstate specialisation.)

Do this instead: Clearly state the practitioner’s name and registration type/role (e.g., RN/NP/GP) and use protected titles correctly. Avoid implying specialist status you don’t hold.

Red Flag 7 - Not moderating comments and tags on owned platforms

What’s the issue? If you control content (can publish/remove), you’re responsible for ensuring it doesn’t include testimonials or misleading claims, this includes comments, tags, and reposts.

Do this instead: Implement a comment moderation policy; disable reviews or restrict tagging where appropriate to reduce testimonial risks.

Red Flag 8 - Creating Unrealistic Expectations 

What’s the issue? 

Do this instead: State clearly that outcomes vary between individuals and depend on clinical assessment. Keep language general and avoid framing results as guaranteed or typical. Emphasise consultation as the point where suitability and expectations are discussed.

Red Flag 9 - Giving personalised clinical advice in social content

What’s the issue? Social posts must not diagnose or recommend specific treatment courses to the public; claims must be supported by acceptable evidence and kept general.

Do this instead: Educate in general terms and invite readers to book a consultation for personalised advice; avoid “You need 2–3 areas” type statements.

Red Flag 10 - Glamorised or aspirational content that targets vulnerabilities

What’s the issue? Advertising must not exploit vulnerabilities or trivialise procedures; glamorised outcomes, lifestyle imagery, or implied social/psychological promises are risky.

Do this instead: Use neutral imagery and educational copy; avoid suggesting treatments will improve life satisfaction, relationships, or self-esteem.

Quick AHPRA Compliance Checklist (save this)

• No testimonials (including patient stories, outcome comments, reposts with outcomes).
• No claims that mislead or create unreasonable expectations.
• Inducements only with T&Cs visible in the ad; avoid pressure tactics.
• Images realistic and consistent; avoid filters, glamorisation.
• Titles/credentials accurate; don’t imply specialist status you don’t hold.
• Moderate comments/tags to remove testimonials on owned channels.
  

FAQs

Can we use before/after photos?

Yes - but only if they don’t mislead or create unreasonable expectations; follow strict good-practice (consistent angles, no editing/filters, balanced risk info). For cosmetic surgery, additional specifics apply.

Are limited-time offers allowed?

Only if T&Cs are stated in the ad, and avoid urgency that could encourage indiscriminate use.

Do I have to publish registration numbers in every ad?

Not in every instance, but advertising must clearly and accurately identify the practitioner’s registration status, role and titles. Including name and registration details is best practice and often necessary to avoid misleading impressions.

Can patients leave reviews on Google?

Yes, but you can’t use or republish clinical outcome reviews in advertising, and you must not encourage outcome-based reviews. On owned channels, remove outcome comments.

What about influencers?

If content promotes therapeutic goods, TGA’s influencer/endorsement rules apply (disclosure, no Rx-only promotion, testimonial restrictions). For service advertising, apply AHPRA rules (no testimonials, no glamorisation, balanced risks).

How to Market Confidently Without Risking Your Registration

Want to market confidently without risking fines or registration?

We’ve built a practical AHPRA & TGA Marketing Compliance Pack for Cosmetic Injectors

• ✔ Step-by-step Master Guide
• ✔ Social Media Posting Policy
• ✔ Checklists
• ✔ Clinic-ready wording templates

It’s plain-English and designed for injectables and aesthetic clinics, so your team can publish with confidence.

Sources & Further Reading

• AHPRA Advertising Guidelines
• Social Media Guidance – AHPRA
• Health Practitioner Regulation National Law – Section 133
• Australian Consumer Law - Misleading Claims

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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.