Ahpra advertising rules for clinic websites: reviews, before-and-after photos, claims and offers (2026)

For allied health and cosmetic clinics: what Ahpra's advertising guidelines and the National Law say about testimonials, before-and-after photos, claims, offers and titles, quoted from Ahpra's own pages on 6 November 2026. Then how our Specialist build is set up for regulated clinics.

By Vish Rathnayaka 6 November 2026 16 min read

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A health clinic can advertise on its website, but the Health Practitioner Regulation National Law (the National Law) sets five limits. Section 133, as Ahpra quotes it, says advertising must not be “false, misleading or deceptive”, must not offer “a gift, discount or other inducement” without stating the terms and conditions, must not use “testimonials or purported testimonials”, must not create “an unreasonable expectation of beneficial treatment”, and must not encourage “the indiscriminate or unnecessary use of regulated health services”. In practice, a review that praises your customer service isn’t a testimonial under Ahpra’s rules, but one about a treatment result is. Any offer needs its terms and conditions, and any claim needs evidence. Cosmetic clinics that offer procedures such as injectables follow a second, more specific set of guidelines, including detailed rules for before-and-after photos.

Ahpra is the Australian Health Practitioner Regulation Agency, the regulator for registered health practitioners. The rules below are quoted from Ahpra and Medical Board of Australia pages we read on 6 November 2026. It’s information, not legal advice, so check Ahpra’s own pages (linked at the end) before you publish.

Who the rules cover

Ahpra’s “Guidelines for advertising a regulated health service” took effect on 14 December 2020. They apply to “Anyone (registered health practitioners, individuals who are not registered as health practitioners and body corporates)” advertising a regulated health service. A body corporate is a company. So the rules reach the clinic business, not just the practitioners in it.

Ahpra works with 15 National Boards and regulates 16 health professions: Aboriginal and Torres Strait Islander Health Practitioner, Chinese Medicine Practitioner, Chiropractor, Dental Practitioner, Medical Practitioner, Medical Radiation Practitioner, Midwife, Nurse, Occupational Therapist, Optometrist, Osteopath, Paramedic, Pharmacist, Physiotherapist, Podiatrist and Psychologist.

Cosmetic clinics have extra guidelines. Ahpra’s “Guidelines for advertising higher risk non-surgical cosmetic procedures” are dated 2 September 2025. Ahpra’s examples include “dental veneers, the administration of cosmetic injectables such as botulinum toxin and dermal fillers”, thread lifts, procedures involving platelet rich plasma, and hair transplants. These guidelines sit on top of the general ones, and Ahpra says “advertisers should comply with the most specific guidance.” They cover practitioners, unregistered individuals and “business, partnerships and corporate entities.”

Cosmetic surgery has its own guidelines for medical practitioners. The Medical Board of Australia says that from 1 July 2023 they “apply to all forms of advertising of cosmetic surgery”, including “printed and electronic communications”. It also says practitioners “need to review all their existing advertising, including their website and their social media accounts”.

Testimonials and reviews

The National Law “specifically prohibits advertising a regulated health service in a way that uses testimonials or purported testimonials”. Ahpra defines testimonials as “recommendations or positive statements about the clinical aspects of a regulated health service used in advertising.”

A clinical aspect is one of three things, according to Ahpra’s testimonials page:

  • the symptom or reason the person sought treatment
  • the diagnosis or treatment the practitioner provided
  • the outcome, including the practitioner’s skills or experience.

“Comments about clinical aspects of a regulated health service are considered a testimonial and cannot be used in advertising.” But “Not all reviews or positive comments made about a regulated health service are considered testimonials.” Comments “about customer service or communication style that do not include a reference to clinical aspects” are not considered testimonials.

Ahpra’s own example shows the line. This review is prohibited: “I confirm that it really does work and my back pain disappeared after three sessions”. This one can be used, because it says nothing clinical: “The practice is really lovely and I have been going there for years.”

What that means for your website:

  • You’re responsible for reviews shown on your site. Ahpra says whoever “has control over the website” is responsible for reviews published or republished on a clinic website. That includes reviews pulled in from somewhere else.
  • Don’t trim mixed reviews. Selective editing of reviews, such as removing negative comments from a mixed review, can be misleading, Ahpra says.
  • If you can’t edit or remove reviews, compliance “may be achieved by disabling the reviews/testimonials functions.”
  • Your clinic’s social pages count too. “Advertisers are responsible for removing testimonials from the advertising they control”, “including social media platforms advertising their regulated health service (e.g. clinic Facebook page).”
  • Third-party sites are different. On directories and forums that don’t advertise your service, “Advertisers are not responsible for removing” testimonials. But Ahpra says they “should take care if they choose to engage with reviews on third-party websites”.

Cosmetic clinics have tighter wording. The cosmetic guidelines ban testimonials “such as patient stories and experiences, success stories or fake testimonials” on “a website or social media”, including “stories”. A practitioner has also used a testimonial if they link to one, re-share a patient’s post, or interact with a review, “such as liking or otherwise responding to a patient’s social media post.” Ahpra suggests “disabling reviews, comments or ‘tagging’ functions” on social media pages. The ban “does not affect” patients “posting reviews on review platforms”. For cosmetic surgery, the Medical Board says: “Testimonials are not permitted in any advertising.”

Before-and-after photos and other images

For every clinic, Ahpra says images must not “create an unreasonable expectation of benefit”, and “the outcomes experienced by one person do not necessarily reflect the outcomes that other people may experience.” An image may breach the law if “it is not clear how the advertised treatment is responsible for, or has directly caused, the benefit shown in the image”, or if “images are not genuine and/or have been edited or enhanced.”

For cosmetic clinics, the 2025 guidelines set out what a before-and-after photo needs:

  • Genuine photos. They “must be of actual patients who have had the procedure being advertised performed by that health practitioner.” Using models or celebrities is misleading where it isn’t established that they had the procedure.
  • The right photo first. “The most prominent or first image seen is either a combined or composite of both the ‘before’ and ‘after’ images or the ‘before’ image”.
  • Matching shots. As similar as possible in “content, lighting (including the use of flash lighting), camera angle, background, framing and exposure, posture, clothing, and makeup”.
  • No editing. No “filters, retouching, grey-scaling and similar techniques”, and no “airbrushed, soft-filter or modified images”.
  • A time label. “The ‘after’ image should specify how long after the higher risk cosmetic procedure the image was taken.”
  • A warning. Outcome images “must include a prominent warning that the outcomes shown are only relevant for this patient and do not necessarily reflect the results other patients may experience.”
  • Age limit. “Images of people under 18 years of age must not be used in advertising of higher risk cosmetic procedures.”
  • Separate consent. Patients must give “fully informed consent”, separate from consent to the procedure, and be given the chance to see their images before they consent. The consent must be documented. Patients can withdraw it “at any time”, and the practitioner must “promptly remove patient images” where possible when they do.

The cosmetic guidelines also say advertising “must not use automated apps, websites, tools or programs that predict an individual’s appearance post-procedure”. That includes a tool on your website that predicts how someone will look.

For cosmetic surgery, the Medical Board requires photos “of actual patients who have had cosmetic surgery performed by the medical practitioner advertising”, and says not to “present the ‘after’ image as the most prominent image”.

Claims, words and risks

Ahpra says “Any claims made in advertising must be supported by acceptable evidence”. If a page lists conditions you treat, “the advertising should also make it clear how the treatment helps each condition listed.” Making comparisons “between health outcomes, professions, practitioners or prices can be misleading”.

Watch for small words. Ahpra’s guidelines name “‘safe’, ‘effective’, ‘risk-free’, ‘pain-free’” as words that can play down treatment risk. Urgency lines such as “‘don’t delay’, ‘act now before it’s too late’, ‘don’t miss out’” are a concern when tied to health claims that aren’t backed up.

Cosmetic clinics have two more rules. “Minimising terms such as ‘gentle’, ‘simple’, ‘safe’, ‘quick’, or ‘easy’ should not be used without clear information about risks.” And “full information about risks and potential risks can be easily found within advertising”. Where an ad can’t fit it all, such as a social media post, it should point to it, for example “through a link, or directions to the section of the health practitioner’s website that contains the information.” A procedure page on your website can be that place.

Offers, discounts and prices

An offer of “a gift, discount or other inducement” must “state or refer to the terms and conditions of the offer”. The terms must be “clear and easily understood, accurate and honest”, and “easy to find”. Ahpra adds: “The public generally consider the word ‘free’ to mean ‘absolutely’ free.”

In Ahpra’s example, “I am offering a $20 discount on their first visit!” is not acceptable on its own, and becomes acceptable once the terms and conditions are added (that the offer is for new clients).

On prices, advertising “should be clear, easily understood, accurate, honest” and “include the total price”, “not just initial costs or prices of certain consultations.” Ahpra also warns that a prize worth far more than the treatment’s cost and risk may encourage people to use a service “regardless of clinical need or therapeutic benefit.”

For cosmetic clinics, price lists for procedures “that involve a therapeutic good, or a prescription-only medicine, such as cosmetic injectables, must comply with the TGA requirements”. The TGA is the Therapeutic Goods Administration, which runs the laws on advertising therapeutic goods such as medicines and medical devices. Ahpra says advertisers “must also comply with the Australian Consumer Law”.

Titles, names and registration numbers

“A practitioner may only use a protected title if they are registered in that profession.” And “Only a practitioner who holds specialist registration in a recognised speciality may use a specialist title”.

In Ahpra’s Example 5, “Dr Jeffries, Specialist Dentist” is not acceptable without specialist registration. “Dr Jeffries (Dentist) Specialist Endodontist” is acceptable.

Cosmetic clinics go further. If advertising names a practitioner as performing higher risk cosmetic procedures, it “must include information about the health practitioner’s registration details, including their registration number”. Ahpra’s format is “Dr G (DEN000456789) Registered dentist, general registration”. Saying someone “specialises” in an area without specialist registration “can be misleading and should not be used”, and “acronyms must not be used alone without explanation”.

What happens if you get it wrong

Ahpra says the maximum penalty is “$60,000 per offence” for an individual and “$120,000 per offence” for a body corporate. Using a protected title without registration can bring “$60,000 per offence, imprisonment for up to three years per offence or both”. Ahpra says that “As of July 2024 these increased penalties now apply in all jurisdictions, including Western Australia.”

Breaches “may be prosecuted”. A National Board may also “take action which may include placing conditions on a health practitioner’s registration.”

A page-by-page check for your clinic website

Part of your websiteWhat Ahpra says
Home and service pagesBack every claim with acceptable evidence. Say how the treatment helps each condition listed. Take care with “safe”, “effective”, “risk-free” and “pain-free”
Reviews section or review widgetOnly comments with no clinical aspect, such as customer service. Don’t trim mixed reviews. Turn reviews off if you can’t edit or remove them
Before-and-after gallery (cosmetic)Genuine patients of that practitioner, “before” or combined image first, matching shots, no editing, a time label, a prominent warning, documented consent, no under-18s
Offers and price pagesTerms and conditions clear and easy to find. Show the total price, not just the first visit
Practitioner profilesProtected and specialist titles only with the right registration. Cosmetic: registration number when a practitioner is named
Procedure pages (cosmetic)Full risk information that’s easy to find, so social posts can link to it
Social media you controlAdvertisers are responsible for removing testimonials from the advertising they control, including a clinic Facebook page

How our Specialist build is set up for clinics

Our Specialist build is the package for regulated industries. It’s from $1,500 including GST (goods and services tax), paid once, and it’s delivered within 7 business days of the kickoff call. The card on our pricing page describes it as “For regulated industries and targeting niche buyers.” It includes everything in our Standard build, plus:

  • More advanced custom design.
  • Custom industry design, with allied health and cosmetic clinics among the industries we design for.
  • Industry compliance baked in (AHPRA, ACCC, GST display rules). The ACCC is the Australian Competition and Consumer Commission, the consumer watchdog. More on what this means below.
  • Integrations included: booking tools (online booking), Google Business schema (code that tells Google your business details) and capability PDFs. If you already have a capability statement PDF, we put it on the site free. Writing a new one is quoted separately.
  • Up to 15 pages. We count the pages that are uniquely designed. Privacy and terms pages generally don’t count.
  • Unlimited revisions.
  • Free hosting with no ongoing cost. The site runs on your own Cloudflare account.

What “compliance baked in” means on a clinic site

We build the layout the rules call for. That includes prices shown as total prices including GST, no patient testimonials, and practitioner registration numbers on profiles. Those match the Ahpra rules above on total prices, testimonials and registration numbers. Before launch we check the layout, and we also check your own words and photos against those rules. It’s a careful check, not legal advice. Under Ahpra’s rules, anyone advertising a health service must make sure the advertising complies, and whoever controls the website is responsible for the reviews on it.

Copywriting (writing the page words) is part of every build. If you have your own words, we help you refine them. If you don’t, we write them, and AI-assisted copy is free.

What else you get

  • You own it. Your site, its code and its content are yours. If we register a domain for you, you’re listed as the owner.
  • Built to accessibility standards.
  • Fast on phones. Pages are built to score 95+ on Google’s Lighthouse mobile test (Google’s speed score) and load in under a second on 4G.
  • A careful launch. On a redesign we set up redirects, which send your old page addresses to the new ones. Before launch we set up Google Search Console, Bing Webmaster Tools and Google Analytics for free, so you can see how people find and use the site. We keep an eye on them until handover, generally one to two weeks after the site goes live.

Our optional Specialist care plan is from $79 a month. It adds “Premium-level care, plus monitoring of your regulator’s rules (AHPRA, ACCC, your industry body)”, and it includes 30 minutes of content updates a month. The first month is free, and you can cancel any month with 14 days’ notice. Without a care plan, you look after updates and fixes yourself, and you can email or call us for help at our hourly rate.

The price is always fixed in writing before we start, and quotes are generally valid for 2 weeks. You can split payments through Klarna, and bigger builds can be paid 50/50: half at the start and half at launch.

Bigger sites and other platforms

Need more than 15 pages? Each newly designed page is roughly $100 up to 15 pages, with a lower price per page above 15. Blog posts and news articles aren’t counted. As a guide, that’s about $1,000 for 10 pages, about $1,900 for 20 and about $2,500 for 30. The exact price is fixed in writing on the 30-minute call before you pay, and so is the timeline for builds over 15 pages. Bigger sites get unlimited revisions until you’re 100% happy, and hosting is usually free, confirmed in your quote. See website cost by number of pages for how that compares. Anything bigger or unusual is a custom quote, and we do those too. Scope, timing, payment and what’s included can all be adjusted to suit you: we work it out with you on the call.

We aren’t tied to one platform. We recommend the setup that suits your project, and you choose. If you want WordPress, we’ll build on WordPress, with the price fixed in writing before you pay.

The Aesir Legal website was a Specialist build, for a Perth law firm practising commercial law. You can see it on our work page.

Start a Specialist build, or read more about our websites for allied health practices and cosmetic clinics.

Frequently asked questions

Can a clinic website show Google reviews? Reviews that mention a clinical aspect can’t be used. Ahpra says comments about customer service or communication style aren’t testimonials, but comments about symptoms, treatment or outcomes are, and can’t be used in advertising. Whoever controls the website is responsible for reviews republished on it.

Can a cosmetic clinic show before-and-after photos? Yes, under the 2 September 2025 guidelines, with conditions. The photos must be genuine, of that practitioner’s patients, unedited and closely matched. The “before” or combined image must come first, the “after” image needs a time label, and a prominent warning must say results vary. The patient must give separate, documented consent.

Can a clinic advertise a discount or a free consult? Yes, if the terms and conditions are clear, accurate, honest and easy to find. Ahpra notes that the public take “free” to mean “absolutely” free.

Do the higher Ahpra penalties apply in Western Australia? Ahpra says that as of July 2024 the increased penalties apply in all jurisdictions, including Western Australia. The maximum is $60,000 per offence for an individual and $120,000 per offence for a body corporate.

Sources

All read on 6 November 2026.

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