With the updated Ahpra and Medical Board of Australia advertising guidelines now firmly in place, aesthetic medical clinics must take a proactive approach to digital compliance.
Your website, whether it’s a one-pager or a content-rich destination describing offerings in detail, now falls under close scrutiny. From the words you use and the images you feature to pricing and promotion, every element must reflect a strict adherence to the national regulations and TGA advertising code.
This guide walks you through how to audit your website for compliance – essential for clinics offering services such as anti-wrinkle injections, dermal fillers, PRP, threads and other non-surgical procedures now classified as high-risk by Ahpra. These checks are essential to ensure ethical and lawful communication with the site visitor.
1. Review your marketing language
The cornerstone of compliant advertising is fact-based, non- promotional, non-sensational copywriting. This means avoiding hype, emotional triggers and any suggestion that a treatment will achieve ‘perfect’ or ‘flawless’ results.
Key checks:
- Eliminate exaggerated claims such as ‘perfect skin’, ‘no pain’, ‘instant results’ or ‘miracle procedure’.
- Avoid language that pathologises normal features (eg, ‘fix your flaws’).
- Ensure that descriptions are balanced: include potential side effects, downtime and the need for consultation where required.
- Indicate who performs each treatment, including practitioner name and registration level.
- Include disclaimers where appropriate, such as ‘results vary between individuals’.
- Avoid promotional language targeting under-18s or implying casual treatment (eg, ‘lunchtime makeover’).
- Ensure tone is clinical, not commercial.
Remember, even familiar marketing phrases may now fall afoul of regulations if they imply guaranteed or exaggerated results.
2. Audit your use of images
Imagery plays a powerful role in shaping patient expectations. As such, Ahpra and the Medical Board of Australia have outlined firm requirements around how clinics visually represent cosmetic outcomes.
Key checks:
- Remove airbrushed or edited photos from treatment pages.
- Use only actual patient images where results are depicted, and only with documented consent.
- Avoid using only the ‘after’ image to promote results.
- Label any stock images clearly as illustrative or, better still, avoid their use.
- Avoid misleading before and after images; use consistent lighting, angles and expressions.
- Don’t use images of minors in any cosmetic context.
- Delete sexualised, glamourised or sensational content (eg, bikini-clad models, unrealistic depictions).
Before and after images used in aesthetic medicine advertising require a prominent disclaimer emphasising that individual results vary. The disclaimer should state that the depicted outcomes are specific to the individual patient and may not reflect the experience of others.
3. Remove testimonials and social proof
Under the regulations, all patient testimonials about clinical services are banned, even if anonymised or neutral in tone.
Key checks:
- Delete patient quotes, case studies or ‘real patient stories’.
- Remove embedded Google or Facebook reviews, even if published by patients themselves.
- Avoid reposting influencer or patient content, especially if it contains praise or treatment outcomes.
- Do not publish or incentivise ‘selfie’ content shared by patients.
Even well-meaning encouragements like ‘Tell us how we did’ or visible star ratings may be non-compliant if they relate to clinical services.
REMEMBER, EVEN FAMILIAR MARKETING PHRASES MAY NOW FALL AFOUL OF REGULATIONS IF THEY IMPLY GUARANTEED OR EXAGGERATED RESULTS.
4. Pricing, offers & promotions
For high-risk nonsurgical cosmetic procedures, under the new Ahpra advertising guidelines it is illegal to use financial incentives that may encourage patients to undergo treatments. Advertising must not exploit price sensitivity, downplay risks, or pressure potential patients into acting quickly. This includes discounts, giveaways, competitions or promotional language that frames procedures as limited-time offers.
- No inducements or promotional deals (eg, ‘$50 off your first treatment’, ‘bring a friend and save’).
- Payment plans may be mentioned but must be described factually and neutrally – not marketed as special or exclusive offers.
- Free consultations can be advertised only if clearly positioned as general information sessions, and not used as a sales tactic or implied endorsement of a treatment.
All references to pricing must maintain a clinical tone and avoid any implication that cosmetic treatments are casual purchases or impulse decisions.
5. Clarity practitioner qualifications
Transparency around who performs what treatment – and under what qualifications – is critical. This applies to doctors, nurses, dermal clinicians and other registered health professionals.
Key checks:
- List full names, medical degrees, and Ahpra registration numbers.
- Accurately title roles: ‘Registered Nurse’ or ‘Medical Practitioner (General Registration)’.
- Avoid unregulated titles such as ‘cosmetic nurse’ or ‘aesthetic expert’ unless legally supported.
- Ensure only properly credentialled surgeons are described using terms like ‘plastic surgeon’ or ‘ENT surgeon’.
Be clear and specific: If a doctor is a Fellow of the Australasian College of Cosmetic Surgery and Medicine, say so, but ensure it’s framed in line with Ahpra’s guidelines and not as a substitute for FRACS or specialist registration.
6. Special considerations for cosmetic surgery
If your practice offers surgical aesthetic procedures, an even stricter set of standards applies. The updated guidelines aim to reinforce the seriousness and risk of surgery.
Key checks:
- State clearly that surgery is performed in accredited hospitals or surgical centres.
- Include more comprehensive information on risks, recovery and downtime (FAQ sections are ideal for this).
- Do not offer ‘free consults’ or cash-back deals that could be seen as inducements.
- Avoid advertising finance plans as promotional; mention them only as standard payment options.
- Never feature models or branding that appear youth-focused or trivialise surgery.
You should also note any cooling-off period requirements for under-18s if applicable to your services, and ensure this is reflected on relevant pages.
7. Comply with TGA rules on therapeutic goods
If your website mentions products used in high-risk non-surgical cosmetic procedures, such as botulinum toxin injections or dermal fillers, you must comply with the Therapeutic Goods Advertising Code (2022). These products are classified as prescription-only medicines (Schedule 4) and cannot be advertised to the public, either directly or indirectly.
Key checks:
- Do not mention brand names of Schedule 4 products in any promotional context, including treatment menus, headings, hashtags or image captions.
- Avoid using treatment category descriptors like ‘anti-wrinkle injections’, ‘dermal fillers’ or ‘lip flip’ if they are being used to indirectly refer to specific Schedule 4 products. Even indirect references may be considered a breach.
- Avoid price lists or inducements related to these treatments.
- Do not compare products or suggest superiority of one brand over another, even subtly.
- Do not include before and after photos that imply outcomes from a Schedule 4 medicine.
- Do not link to manufacturer product pages, unless clearly intended for health professionals only and not framed as advertising.
- Include a statement that a consultation is required to determine appropriate treatment.
Compliance builds trust
Auditing your website for Ahpra and TGA compliance is not just about avoiding regulatory action – it’s a powerful exercise in professional integrity. Patients are more informed than ever, and clear, honest, medically sound communication builds lasting trust.
It’s worth investing time (and potentially a legal or regulatory expert) to conduct a full audit of your online presence, including social media and email marketing. Ultimately, a compliant website sends a clear message: your clinic values safety, transparency and ethical practice.
Tips:
Schedule a quarterly website review to catch non-compliant copy that may creep in over time, especially after updates or changes in staff.
Keep a close eye out for changes in regulations to ensure that your website stays compliant.
