With new advertising guidelines now in effect, cosmetic clinics must urgently review their content. Alison Lee, director of Clearads and member of the therapeutic goods advertising consultative committee, shares practical advice on how to avoid unintentional breaches.
The cosmetic injectables sector is booming in Australia, valued at $4.1 billion and projected to grow by 19.3 percent annually until 2030. But with this rapid growth has come an equally significant rise in regulatory oversight. For registered healthcare practitioners working in aesthetic medicine, the landscape is shifting fast. It’s crucial to understand the changes ahead, particularly with new advertising guidelines from the Australian Health Practitioner Regulation Agency (Ahpra), which came into effect on 2 September 2025.
At ClearAds, we work closely with health professionals, clinics, marketers and regulators to help ensure advertising across all platforms complies with the law.
And right now, we’re seeing widespread, unintentional non- compliance, particularly in the digital and social media space.
In the regulatory spotlight
In the past financial year alone, the Therapeutic Goods Administration (TGA) requested the removal of nearly 13,500 advertisements from online platforms. This figure highlights the scale of non-compliance in the market and reflects a growing urgency to clean up advertising in the cosmetic space.
The key issue? Many advertisers, whether clinic owners, nurses, GPs or third-party agencies, don’t realise that common promotional tactics used online are actually prohibited under Australian law. From using product nicknames like ‘baby botox’ to listing treatment prices, seemingly harmless phrases and practices can trigger enforcement action.
What changed on 2 September?
While the National Law and TGA Code have long prohibited the direct or indirect advertising of prescription-only medicines, the new Ahpra guidelines provide further guidance on how higher-risk*, non-surgical cosmetic procedures can be advertised. (*Higher-risk procedures include injectables, injection lipolysis, thread lifts, sclerotherapy, platelet rich plasma, biotherapy or injections of any products derived from the patient’s blood, and hair transplants.)
These guidelines don’t just apply to doctors or nurses; they apply to anyone advertising regulated health services, including clinic managers, digital marketers, social media managers and influencers.
Under both TGA rules and the new Ahpra guidelines, advertising should avoid:
- Product names: eg, ‘anti-wrinkle injections’, ‘dermal fillers’
- Brand names: eg, Botox, Juvederm, Restylane
- Nicknames: eg, ‘tox’, ‘lip flips’, ‘baby botox’, ‘brotox’
- Hashtags using any of the above terms
- Treatment prices or inducements
- Testimonials or reviews from patients.
It’s important to note that even indirect references to these products or treatments, especially when linked to images, emojis or influencer content, are considered advertising.
Why this matters for HCPs
As a registered healthcare practitioner, you hold dual responsibilities: to operate within the bounds of clinical best practice and to comply with Australia’s advertising laws. Breaching these laws (knowingly or not) can result in:
- Regulatory investigation by Ahpra or the TGA
- Professional misconduct allegations
- Financial penalties
- Public naming by regulators
- Reputational damage to your practice.
While it may be tempting to delegate marketing responsibilities to third-party agencies or social media managers, you are ultimately accountable for the content published in your name or on behalf of your clinic.
Top 5 most common breaches
ClearAds regularly review clinic websites, Instagram accounts and paid ad campaigns. Here are five of the most common (and avoidable) breaches:
- Use of restricted product names – Even if a brand name is ‘blurred’ or replaced with a similar-sounding nickname, it could still breach TGA rules.
- Price promotions or discounts – Advertising treatment prices, even without a dollar sign, can be considered an advertisement for prescription medicines under the Code.
- Before and after photos – These are often misleading when used incorrectly.
- Testimonials and influencer reviews – Personal endorsements, paid or unpaid, are banned in health service advertising.
- Hashtag misuse – Tags like #botox, #dermalfillers or #babytox are still advertising – even when buried in a caption.
Influencers & agencies
Earlier this year, The Daily Telegraph published an article highlighting the widening regulatory gap between media outlets and social influencers when it comes to cosmetic promotions. While major publishers like News Corp have been fined, many influencers are still ‘flying under the radar’. But that’s changing and enforcement is catching up.
Influencers who receive compensation or gifts to promote a clinic, product or service are considered advertisers and so are the clinics or agencies that engage them. Registered practitioners who repost or collaborate with influencers may also be seen as endorsing non-compliant content.
Now is the time to review all partnerships and ensure that all external collaborators understand the rules.
Even if a brand name is ‘blurred’ or replaced with a similar-sounding nickname, it could still breach TGA rules.
Looking ahead: compliance as a competitive advantage
The aesthetics industry is evolving rapidly, and so too is consumer awareness. Patients are becoming more discerning and regulators are responding to their concerns.
Operating a compliant clinic doesn’t mean sacrificing visibility or marketing effectiveness. In fact, compliance is becoming a trust signal, distinguishing safe, professional practices from those cutting corners.
A transparent, ethical advertising strategy not only meets regulatory expectations, but it also builds credibility, safeguards your registration and reinforces your reputation as a healthcare provider first and foremost.
ClearAds is an Australian advertising review and classification service that helps ensure advertising complies with broadcasting codes and regulations before they go to air, online or print. For more information, visit ClearAds.com.au.
What you can do right now
1. Conduct an audit
Review your website, social media, print materials and any digital ads. Identify and remove non-compliant content, especially product names, treatment prices and testimonials.
2. Train your team
Ensure that receptionists, marketing coordinators and social media managers are aware of the new Ahpra guidelines and understand their role in ensuring compliance.
3. Update influencer briefs
If you work with influencers,
update your contracts and content briefs to reflect the new rules. Avoid testimonials, ‘results’ language or any suggestion of endorsement.
4. Consider expert review services
Companies such as ClearAds offer tailored advertising reviews to help ensure content is compliant before it goes live. They can also provide certificates of review, which can demonstrate a good-faith effort to comply if questioned by a regulator.
