More insights.
Subscribe to our newsletter.
Deep dives into design thinking, creative process, and the intersection of business and aesthetics.
Most cosmetic clinic marketing in Australia is technically non-compliant. Since 2 September 2025, AHPRA's guidelines prohibit naming Schedule 4 medicines in any public-facing marketing, prohibit the code words that replaced them, ban patient and influencer testimonials in advertising, ban before-and-after photos of prescription-only injectable results, and require every historical post to comply. Penalties reach $60,000 per offence for individuals and $120,000 for companies, with TGA infringement notices up to $106,500 on top.
That paragraph is the shortest accurate summary of the current rules. What follows is what they mean in practice.
What changed in September 2025
The industry already knew it could not name prescription medicines in advertising. The 2025 guidelines closed every door that habit had left open.
The code words went. "Anti-wrinkle injections" and "dermal fillers", the polite workarounds an entire industry was built on, are treated the same as the product names they replaced. Price lists for these services went with them. So did the hashtags. So did testimonials, including the influencer kind, in any advertising context.
Before-and-after photos of prescription-only injectable results are now treated as advertising the medicine itself, which places them under the Therapeutic Goods Act. Images must be real and unedited, carried with a warning that results vary. Terms that trivialise a medical procedure, including "artist", "sculptor" and "magic hands", sit on a banned list of their own. Advertising these procedures to anyone under eighteen is prohibited outright.
Why "historical content" is the trap
The guidelines apply to everything a clinic has ever posted, not everything it posts next. The Story from 2022. The pinned post with a product name in the caption. The highlight reel of results. Each one is live advertising in the regulator's eyes, and each one counts.
This is why most clinics are exposed without knowing it. The marketing was compliant when it was made. The rules moved. The content did not.
What the rules left behind
Strip away product names, prices, testimonials and result photos, and what remains is everything that was always harder to build: the clinician's expertise. The consultation process. The environment. The philosophy of the practice. The reasons a patient chooses one clinic over another before she has compared a single price.
The clinics that win under these rules are not the ones that found cleverer workarounds. They are the ones whose brand never depended on the banned material in the first place.
The regulator did not end cosmetic clinic marketing. It ended a particular kind of it, the loud kind, and left the field to clinics built on identity rather than offers. POLMIRA was built for that field. Every piece of creative the studio produces is built inside these constraints from the brief stage, not edited into compliance after.
Where a clinic starts
Three moves, in order. Audit everything historical, because the back catalogue is the live risk. Remove every product name, code word, price and testimonial from every surface, including Stories and highlights. Then rebuild the marketing around what can lawfully carry weight: expertise, process, environment and brand.
This article describes the published rules in general terms. It is not legal advice. The current guidelines sit on AHPRA's cosmetic procedures hub, and they are worth reading in full.
The studio works with three to five clinics per season, one per suburb. Apply for an introduction.
FAQ
Can cosmetic clinics advertise injectables by name in Australia? No. Schedule 4 prescription medicines cannot be named in any public-facing marketing, and since September 2025 the common code words for them are prohibited as well.
Are before-and-after photos banned for cosmetic clinics? For prescription-only injectable results, yes. AHPRA treats them as advertising the medicine itself, which contravenes the Therapeutic Goods Act. Photos for non-prescription treatments must be real, unedited, and carry a warning that results vary.
Can a cosmetic clinic use patient testimonials? Not in advertising. The ban covers patient testimonials and extends to social media influencers. It applies to new and existing content.
What are the penalties for non-compliant cosmetic advertising? Up to $60,000 per offence for individuals and $120,000 per offence for companies, plus TGA infringement notices that reach $106,500 per offence.
Most cosmetic clinic marketing in Australia is technically non-compliant. Since 2 September 2025, AHPRA's guidelines prohibit naming Schedule 4 medicines in any public-facing marketing, prohibit the code words that replaced them, ban patient and influencer testimonials in advertising, ban before-and-after photos of prescription-only injectable results, and require every historical post to comply. Penalties reach $60,000 per offence for individuals and $120,000 for companies, with TGA infringement notices up to $106,500 on top.
That paragraph is the shortest accurate summary of the current rules. What follows is what they mean in practice.
What changed in September 2025
The industry already knew it could not name prescription medicines in advertising. The 2025 guidelines closed every door that habit had left open.
The code words went. "Anti-wrinkle injections" and "dermal fillers", the polite workarounds an entire industry was built on, are treated the same as the product names they replaced. Price lists for these services went with them. So did the hashtags. So did testimonials, including the influencer kind, in any advertising context.
Before-and-after photos of prescription-only injectable results are now treated as advertising the medicine itself, which places them under the Therapeutic Goods Act. Images must be real and unedited, carried with a warning that results vary. Terms that trivialise a medical procedure, including "artist", "sculptor" and "magic hands", sit on a banned list of their own. Advertising these procedures to anyone under eighteen is prohibited outright.
Why "historical content" is the trap
The guidelines apply to everything a clinic has ever posted, not everything it posts next. The Story from 2022. The pinned post with a product name in the caption. The highlight reel of results. Each one is live advertising in the regulator's eyes, and each one counts.
This is why most clinics are exposed without knowing it. The marketing was compliant when it was made. The rules moved. The content did not.
What the rules left behind
Strip away product names, prices, testimonials and result photos, and what remains is everything that was always harder to build: the clinician's expertise. The consultation process. The environment. The philosophy of the practice. The reasons a patient chooses one clinic over another before she has compared a single price.
The clinics that win under these rules are not the ones that found cleverer workarounds. They are the ones whose brand never depended on the banned material in the first place.
The regulator did not end cosmetic clinic marketing. It ended a particular kind of it, the loud kind, and left the field to clinics built on identity rather than offers. POLMIRA was built for that field. Every piece of creative the studio produces is built inside these constraints from the brief stage, not edited into compliance after.
Where a clinic starts
Three moves, in order. Audit everything historical, because the back catalogue is the live risk. Remove every product name, code word, price and testimonial from every surface, including Stories and highlights. Then rebuild the marketing around what can lawfully carry weight: expertise, process, environment and brand.
This article describes the published rules in general terms. It is not legal advice. The current guidelines sit on AHPRA's cosmetic procedures hub, and they are worth reading in full.
The studio works with three to five clinics per season, one per suburb. Apply for an introduction.
FAQ
Can cosmetic clinics advertise injectables by name in Australia? No. Schedule 4 prescription medicines cannot be named in any public-facing marketing, and since September 2025 the common code words for them are prohibited as well.
Are before-and-after photos banned for cosmetic clinics? For prescription-only injectable results, yes. AHPRA treats them as advertising the medicine itself, which contravenes the Therapeutic Goods Act. Photos for non-prescription treatments must be real, unedited, and carry a warning that results vary.
Can a cosmetic clinic use patient testimonials? Not in advertising. The ban covers patient testimonials and extends to social media influencers. It applies to new and existing content.
What are the penalties for non-compliant cosmetic advertising? Up to $60,000 per offence for individuals and $120,000 per offence for companies, plus TGA infringement notices that reach $106,500 per offence.