Advertising a skin clinic without breaching the rules

If you run a skin or cosmetic clinic, the marketing advice you read online probably does not match the rules you are expected to follow. Competitors post what they like, agencies promise results in confident language, and the regulators publish guidance that seems to forbid most of it. It is hard to know which world you are living in.

The honest answer is that the rules are stricter than common practice, and the gap between the two is where clinics get into trouble. The rules are also consistent once you see the logic, and a clinic can market itself well inside them. This guide covers the logic first, then the specifics, then what a compliant and effective presence looks like.

The idea underneath everything: you advertise the consultation

Two regulators care about cosmetic clinics. AHPRA and the National Boards regulate how you advertise a health service, through section 133 of the National Law. The TGA regulates how medicines may be advertised, under the Therapeutic Goods Act 1989 and the Therapeutic Goods Advertising Code. A clinic offering treatments that involve prescription medicines sits under both.

The TGA rule that matters most is simple. Prescription medicines may not be advertised to the public, apart from limited exceptions (subsections 42DL(10) and 42DLB(7) of the Act). What you can advertise is the service: a consultation where a qualified practitioner assesses a person's concerns and discusses options. That is not a workaround. The product is decided in the consulting room, after assessment, by a prescriber. Once you hold that line, you stop asking whether a particular word is allowed and start asking whether the page sells a consultation or a product.

Indirect references: why the generic phrases are caught too

Many clinics moved to generic descriptions years ago, assuming that avoiding a brand name made a page safe. TGA guidance, last updated in June 2026, says otherwise: do not refer to prescription medicines or substances even indirectly. That covers brand names, acronyms, colloquial names and nicknames, and hashtags that could be read as a reference to a specific product. It also covers substitute terms and whole classes of product described by their effect.

Read that list as a lesson, not a word list to dodge. Each phrase is caught because it describes a prescription product by its purpose and a reader fills in the product immediately. Any new phrase built the same way carries the same problem, so there is no synonym to hunt for. Some related traps are easy to miss:

• Business names, logos and icons. These must not refer to a prescription medicine directly or indirectly either. Check the syringe icon in your header as well as your headlines.
• Disclaimers. Adding 'speak to a health practitioner' to consumer content does not exempt it. Only advertising directed exclusively at health professionals is outside the rule.
• Pricing. A price per unit or per syringe for a prescription medicine is unlawful advertising. A consultation fee is fine to state.
• Tissue and blood-derived products. These generally cannot be advertised to the public at all, so describe the service, not the product.
• Google Ads. Google's Australian policy says ads targeting Australia cannot use prescription drug terms in the ad or on its destination, so the landing page counts.

Say this, not this

The left column is the pattern to follow. The middle column describes the pattern to avoid in categories, so that this page does not become an example of the problem.

AHPRA's higher-risk non-surgical cosmetic procedure guidelines

Alongside the general guidelines, the National Boards publish a separate set for higher-risk non-surgical cosmetic procedures. The AHPRA page shows a review date of 14 October 2025. The guidelines are made jointly by 15 National Boards under section 39 of the National Law and apply to anyone advertising these procedures: registered practitioners, unregistered individuals and businesses.

AHPRA describes these as procedures carried out mainly for a more desirable appearance that usually need a registered practitioner, because of restricted-profession rules, an authorisation such as prescribing, or the knowledge needed. Named examples include dental veneers, injection lipolysis, thread lifts, sclerotherapy, platelet-rich plasma and biotherapy procedures, hair transplants and the injectable treatments we have been careful not to name here. They widen what counts as a testimonial, explicitly including links to images showing outcomes and publication in any format, and they sit on top of TGA requirements and the Australian Consumer Law.

Before-and-after images

Being real is necessary but nowhere near enough. AHPRA's cosmetic guidelines require all of the following:

• Both images are of genuine patients who had that exact procedure from that practitioner.
• The first or most prominent image is the before image or a combined pair. The after image must not be most prominent.
• The images are as similar as possible in lighting, angle, background, framing, posture, clothing and makeup, with no filters, retouching or grey-scaling.
• The advertisement says how long after the procedure the after image was taken, and carries a prominent disclaimer that results are specific to that patient.
• No one under 18 appears, and the presentation is not sexualised, idealised or entertainment: no music, comic captions, reaction shots, or words such as 'perfect' or 'instant'.
• Separate, specific consent covers use in advertising. The patient knows where and for how long, can view it first, and can withdraw at any time, after which the image comes down promptly.

There is a second layer. The TGA says content that shows treatment progression or outcomes can be treated as advertising of the therapeutic good involved. So where the procedure uses a prescription medicine, a tidy before-and-after post can still breach TGA rules whatever the caption says.

Titles: surgeon, specialist and what you can call yourself

Misusing a protected title, specialist title or endorsement title is an offence under sections 113 to 119 of the National Law, and where a section 133 breach also involves a protected title an individual can face up to three years' imprisonment as well as fines.

Since a 2023 amendment, section 115A limits the title 'surgeon', including 'cosmetic surgeon', to medical practitioners with specialist registration in surgery, obstetrics and gynaecology, or ophthalmology. Anyone else must remove it from all advertising. AHPRA's guidance noted that adoption in some states depended on state legislation, so confirm how it applies where you practise.

The word 'specialist' works the same way. Only medicine, dentistry and podiatry have specialist registration, so nurses, physiotherapists and others cannot be described as specialists. AHPRA treats 'specialises in', 'specialty' and 'specialised' identically. Its accepted alternatives are 'substantial experience in' and 'working primarily in', which suit a cosmetic clinic well. 'Dr' is not protected, but a practitioner who is not a medical practitioner and uses it should state the profession, as in 'Dr Jones (dentist)'.

Influencers, ambassadors and social media

Social media is where cosmetic clinics are most exposed. The principle in both AHPRA and TGA guidance is control: if you engage an influencer or hand your account to an agency, you remain responsible for what is published, and TGA guidance says responsibility may extend to both clinic and creator. A free treatment in exchange for a glowing post is a testimonial arrangement before it is anything else. Content implying use of a product, showing progression, or carrying a tag, link or discount code to book a service involving therapeutic goods can be treated as advertising of that good.

• Stories count. A story showing a patient's delighted reaction is a testimonial even if it disappears after a day.
• Re-sharing, liking or replying to a patient's positive post about a clinical aspect is use of a testimonial.
• AHPRA suggests considering turning off reviews, comments and tagging on your own pages, so third parties cannot create testimonials you might be seen to interact with.
• Practitioners are not responsible for what patients post elsewhere, but must take care not to interact with it.

Offers, terms and urgency

Section 133 allows a gift, discount or inducement only if the advertisement states the terms and conditions, and the terms must be clear, accurate, honest and easy to find. The test is not generosity. An offer out of proportion to the cost and risk of a treatment can separately raise the unnecessary-use limb. Prices must show the total, not an introductory part of it.

Phrases such as 'don't delay' and 'limited time only' create urgency, and AHPRA says they may be unlawful when linked to claims that health will suffer without acting. A seasonal offer on a skin consultation, with its terms beside it, is fine. Avoid anything suggesting a person needs treatment without a clinical basis, such as regular top-ups.

Reviews

Patients may post reviews anywhere, and AHPRA does not restrict that. Your obligation starts when you use a clinical review by republishing, linking to or interacting with it on a channel you control. In cosmetic practice nearly every glowing review mentions a treatment or outcome, which makes it clinical. Comments about friendly staff or easy booking are not testimonials. Our guide to what you can and can't do with patient reviews has the detail.

What compliant marketing that still works looks like

A clinic that follows all of this is not left with a blank page. It keeps the parts of marketing that help someone decide whether to trust a stranger with their face.

Consultation pages that do the real work

Explain what happens: who you will see, how long it takes, what is assessed, what the fee is and what risks the practitioner will discuss. Describe concerns in the person's own terms, such as skin texture, uneven tone or signs of ageing, without pointing at a product, and end with a booking path. This is the first page we would build for a clinic; see our website service.

Credentials, stated accurately

Name, profession, registration, qualifications and areas of focus, written with 'substantial experience in' language, are your strongest legitimate trust signals. Good photography of your team and rooms helps, because people want to see where they will be.

Education and local search

Articles on choosing a clinic, what to ask at a first appointment and what realistic expectations look like are useful and compliant when they stay general and honest about risk. Most enquiries still begin with a local search, so a complete Google Business Profile matters; our local SEO checklist covers it, and how patients actually choose a practice explains why trust beats cleverness. Before any paid search, read what you can and can't run in Google Ads for healthcare. Our skin and cosmetic clinics page looks at the economics of this kind of practice.

• Cosmetic clinic advertising checklist
• Every consumer page sells a consultation or service, never a productNo brands, abbreviations, nicknames or effect-based class descriptions
• Business name, logo, icons, hashtags and page titles checked for indirect references
• No price lists for any prescription medicineConsultation fees are fine
• Outcome images removed, or meeting every AHPRA conditionAnd not showing a prescription-medicine procedure in consumer channels
• No clinical testimonials, including stories, re-shares, likes and linked reviews
• Titles checked: no 'surgeon' or 'specialist' without the registration
• Influencer and agency content approved by you before it goes live
• Offers state full terms beside them, with total prices and no urgency language
• Google Ads copy and landing pages free of prescription terms, brand or generic
• A named person reviews new content, and a date is set to re-check this list