Educational
Dr. Sandy Adel
April 15, 2026 · 15 min read
You have spent years building your surgical skills, your reputation, and your practice. The last thing you want is for a single social media post or a poorly worded website page to trigger an AHPRA investigation.
The rules governing plastic surgery advertising in Australia are strict, detailed, and actively enforced. They apply to your website, your Instagram, your Google ads, your brochures, and anything a marketing agency publishes on your behalf. Getting them wrong is not just embarrassing. It is a criminal offence.
This guide explains the rules clearly, in plain language, with real examples so you know exactly where the line is. If you want marketing that is built compliance-first from the first draft, visit the ContentClicks Plastic and Cosmetic Surgery page to see how the process works for practices across Australia.
Two regulatory bodies set the rules for how plastic surgeons can market their services in Australia. Understanding how each one fits into the picture is the starting point for building a compliant practice.
The Australian Health Practitioner Regulation Agency (AHPRA) regulates health service advertising under Section 133 of the National Law. Every plastic surgery practice in Australia, regardless of size, must comply. AHPRA also conducts proactive audits of cosmetic surgery advertising and actively monitors social media platforms. Historic content is not exempt from review.
The Therapeutic Goods Administration (TGA) adds a second layer of rules for anything related to prescription-only medicines, including the injectable treatments many plastic and cosmetic surgery practices also offer. Following significant industry non-compliance, the TGA reinforced and expanded its guidance on cosmetic injectable advertising in March 2024.
This is where many practices get caught out. AHPRA’s definition of advertising is deliberately broad, and understanding its scope is essential before reviewing any of your content.
AHPRA defines advertising as any public-facing communication that promotes your services and is designed to attract patients to your practice. It is not limited to paid campaigns or formal advertisements. This definition captures your website, your Instagram grid, your Facebook page, your Google Business profile, your email newsletter, your clinic brochure, and organic social media posts.
It also applies to anyone acting on your behalf. If your marketing agency publishes non-compliant content, you are equally responsible as the service provider.
These five prohibitions come directly from Section 133 of the National Law and form the foundation of AHPRA’s advertising compliance framework. They apply to every piece of content your practice produces, on every platform, in every format.
You must not advertise your services in a way that is false, misleading or deceptive; offers a gift, discount or other inducement without also stating the full terms and conditions; uses testimonials or purported testimonials about the service or the practitioner; creates an unreasonable expectation of beneficial treatment; or directly or indirectly encourages indiscriminate or unnecessary use of health services.
From 1 July 2023, registered medical practitioners who advertise cosmetic surgery must also comply with a separate, more detailed set of requirements under the cosmetic surgery advertising guidelines. These sit on top of the general rules, not in place of them. The AHPRA advertising guidelines explain the full scope of these obligations.
The language you use in advertising is where most breaches occur. The following categories cover the most common areas of non-compliance across plastic surgery advertising in Australia.
Surgical outcomes are inherently variable, and your advertising must reflect that. Phrases to avoid include “guaranteed results,” “permanent solution,” “painless procedure,” “zero downtime,” “totally safe,” “instant recovery,” and “100% natural-looking results.” These create what AHPRA calls an unreasonable expectation of beneficial treatment and are a direct breach of the National Law.
The cosmetic surgery advertising guidelines specifically prohibit language that trivialises or downplays the invasive nature of surgical procedures. Words like “artistry,” “sculpting,” and “silhouette” have been flagged by AHPRA as inappropriate because they make surgery sound effortless and low-risk when it is not.
Describing yourself as “Australia’s leading surgeon,” “the best in Sydney,” or “a specialist in aesthetic breast surgery” when no recognised surgical subspecialty exists in that area is likely to breach the guidelines. The title “specialist” may only be used by practitioners who hold specialist registration in the relevant field.
Terms like “droopy,” “flabby,” “deflated,” “problem areas,” and “tired-looking” have been cited by the Australian Society of Plastic Surgeons as examples of non-compliant language that targets physical insecurities to drive demand for procedures.
This is one of the most misunderstood rules in Australian health advertising, and one of the most commonly breached. The prohibition is absolute.
Section 133(1)(c) of the National Law prohibits the use of testimonials or purported testimonials in advertising a regulated health service. It does not matter whether the patient consented, whether the review is genuine, or how positive and factual the content is.
The prohibition covers written patient reviews on your website, patient quotes in brochures or social media posts, video testimonials from patients, before-and-after photographs accompanied by patient commentary, and patient Instagram or Facebook posts that you share, repost, or amplify. The moment you share or repost a patient’s positive social media content, you have used a testimonial in your advertising. As of 2 September 2025, this prohibition also extends to influencer testimonials for non-surgical cosmetic procedures.
Reviews posted on third-party platforms like Google or Healthengine, where the practice had no involvement, are generally not your responsibility. However, the moment you link to, screenshot, or reference those reviews in your own content, the prohibition applies.
If your practice offers any injectable aesthetic treatments, you face a second layer of regulation under the Therapeutic Goods Act 1989. This layer is separate from AHPRA’s rules and has its own penalties.
Most cosmetic injectable products, including botulinum toxin and dermal filler products, are classified as Schedule 4 prescription-only medicines. Under Section 42DL of the Therapeutic Goods Act, advertising prescription-only medicines to the general public is prohibited.
Following the TGA’s March 2024 update, the following are now prohibited in any advertising directed at the general public: brand names including Botox, Dysport, Xeomin, Juvederm and Restylane; generic chemical names including botulinum toxin and hyaluronic acid; general descriptive terms that lead a reasonable consumer to understand they refer to a prescription product, such as “anti-wrinkle injections,” “dermal fillers,” “lip fillers” and “fat dissolving injections”; before-and-after photographs used to promote injectable treatment outcomes; and price lists for injectable services.
Patients can be given information about injectable treatments during a clinical consultation, as individual practitioner-to-patient communication is exempt from the advertising prohibitions. It simply cannot appear in public-facing advertising.
Every public-facing social media post that promotes your practice or a procedure you offer is advertising under the National Law. The informal tone of the platform makes no difference to your legal obligations.
Every post that discusses an invasive procedure must include a risk disclaimer directing the public to seek further information. Where before-and-after photographs are used, both images must match as closely as possible in lighting, angle, background, framing, clothing, and expression. Offering free or discounted surgery to patients, including social media influencers, in exchange for promotional content is expressly prohibited. From 2 September 2025, advertising higher-risk cosmetic procedures must be classified as adult content on social media platforms to prevent it from reaching individuals under 18.
Breaching Section 133 is a criminal offence, not a civil matter. Under the National Law, standard advertising offences carry penalties of up to $5,000 per offence for individuals and up to $10,000 per offence for body corporates. Offences involving unlawful use of a protected title carry penalties of up to $60,000 and/or three years’ imprisonment for individuals and up to $120,000 for body corporates.
Under TGA legislation, civil penalties for advertising prescription-only medicines to the general public can reach $1,565,000 for individuals and $15,650,000 for body corporates. Infringement notices can reach $13,320 per contravention for individuals.
Beyond financial penalties, non-compliant practitioners face AHPRA investigation, disciplinary proceedings, conditions on their registration, suspension, and in serious cases, deregistration. These consequences apply equally to practice managers and marketing agencies involved in producing the content.
Staying compliant is not a one-time task. It requires systems, regular review, and clear expectations for everyone who produces content on your behalf.
Review your website, social media profiles, paid advertisements, and printed materials at least quarterly. The TGA has confirmed that historic social media content is subject to review, so older posts matter too. Before any content goes live, ensure everyone producing it understands what AHPRA and the TGA require. Display full registration details whenever you are mentioned in any detail, for example: “Dr Jane Smith, MED0001234567. Registered medical practitioner, Specialist Plastic Surgeon (specialist registration in surgery: plastic surgery). FRACS (Plast).”
Stay across key regulatory dates: the Medical Board’s cosmetic surgery reforms (1 July 2023), the TGA’s updated injectable terminology rules (March 2024), penalty increases across all jurisdictions (July 2024), and the new non-surgical cosmetic procedure advertising guidelines (2 September 2025).
If your current marketing was not built with these changes in mind, a full review is overdue. Talk to the ContentClicks team about compliance-first marketing built specifically for plastic and cosmetic surgery practices in Australia.
AHPRA's advertising rules are set out in Section 133 of the Health Practitioner Regulation National Law. The five core prohibitions cover false or misleading claims, inducements without stated terms, testimonials, unreasonable outcome expectations, and encouraging unnecessary use of health services. From 1 July 2023, additional obligations apply to practitioners who advertise cosmetic surgery specifically.
No. Patient testimonials are prohibited under Section 133(1)(c) of the National Law. This covers written reviews, patient quotes, video testimonials, before-and-after photographs with patient commentary, and patient social media posts that the practice shares or amplifies. As of September 2025, influencer testimonials for non-surgical cosmetic procedures are also expressly banned.
No. Botulinum toxin products and dermal fillers are classified as Schedule 4 prescription-only medicines. Advertising them to the general public is prohibited under the Therapeutic Goods Act 1989. Following the TGA's updated guidance effective March 2024, even general terms such as "anti-wrinkle injections" and "dermal fillers" are not permitted in public advertising.
Yes. Social media posts are advertising under the National Law. This applies to all platforms and all formats including organic posts, Stories, Reels, and paid promotions. Risk disclaimers are required wherever invasive procedures are discussed, and before-and-after imagery is subject to strict rules.
Under the National Law, standard advertising offences carry penalties of up to $5,000 per offence for individuals and up to $10,000 for body corporates. TGA civil penalties for advertising prescription-only medicines can reach over $1.5 million for individuals. Non-financial consequences include AHPRA investigation, disciplinary action, conditions on registration, suspension, and deregistration.
Prohibited language includes outcome guarantees such as "guaranteed results," "permanent," "painless," "zero downtime," and "totally safe"; language that minimises surgical invasiveness such as "artistry" and "sculpting"; body-shaming terms such as "droopy," "flabby," "deflated," and "problem areas"; and superiority claims. Injectable product names and general injectable terms such as "anti-wrinkle injections" and "dermal fillers" are separately prohibited under TGA rules.
No. AHPRA and the Medical Board do not provide pre-approval of advertising content. Their role is regulatory enforcement. If you need guidance on whether specific content is compliant, seek independent legal advice or consult your professional indemnity insurer or professional association.
In limited circumstances and subject to strict rules. Since 1 July 2023, a single image cannot be used if it is likely to give the impression it represents a surgical outcome. Where before-and-after photos are used, both images must match as closely as possible in lighting, angle, background, framing, clothing, and expression. Before-and-after photos promoting injectable treatments are separately prohibited under TGA rules.
Both the practice and the agency can be held legally responsible. Section 133 applies to any person advertising a regulated health service, not only the treating practitioner. You cannot transfer your legal exposure to a third party by delegating the work.
This article is intended for informational purposes only and does not constitute legal advice. Advertising laws and regulatory guidelines are subject to change. Australian plastic surgeons and their marketing teams are encouraged to refer directly to AHPRA, the Medical Board of Australia, and the TGA for the most current requirements.
ContentClicks builds compliance-first content marketing for healthcare and medical aesthetics practices. Let’s talk.
Plastic surgeons, cosmetic dentists, and aesthetic clinics trust us to get them found. AI-driven content and marketing, built for the way people search today.
