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Most cosmetic clinic advertising in Australia is currently non compliant, and most owners running it have no idea.
Not because they are careless. Because the rules moved on 2 September 2025 and the content did not.
What changed in September 2025?
The guidelines closed the gaps rather than inventing a new regime.
Prescription medicine names could never be advertised to the public. What changed is that the workarounds are now treated identically to the names themselves. The category words and the nicknames the industry invented in order to keep advertising are covered, along with the hashtags built from them.
Price lists for those services are gone from advertising. So are specials, packages and anything expressed as a figure attached to the treatment.
Testimonials about a regulated health service are prohibited, and the guidelines make explicit that this includes influencers, paid or gifted.
Images must be real and unedited, and must carry a warning that results vary. Before and after imagery for prescription only injectables is treated as advertising a medicine, which places it under a different act entirely.
Trivialising language is out. The guidelines name the terms: artist, sculptor, magic hands, doll maker, god, queen, master, world's best.
Advertising cosmetic procedures to anyone under eighteen is prohibited outright.
There is also a practitioner standard sitting underneath all of it. A registered nurse now needs a minimum of one year full time general nursing experience plus specialised training before performing cosmetic procedures.
Why is historical content the real trap?
Because the rules apply to what is published, not to when it was written.
A post from 2022 naming a product is live advertising today. So is a pinned highlight, an old story saved to a profile, a results reel from three years ago, a price list still sitting on a services page nobody has opened since the website was built.
The clinic was compliant when it posted. The rules moved. The content did not.
This is the single largest source of exposure in the category and it is almost entirely invisible to the owner, because nobody scrolls back through four years of their own profile.
What is actually left to advertise?
More than most clinics think, and it is better material than what was taken away.
The clinician. Her training, her judgement, the number of times she has done the specific thing and the specific way she assesses a face before touching it.
The consultation. What actually happens, how long it takes, what she is told, what she is talked out of.
The room. What it looks like, how it feels, what it says about the standard being kept.
The position. Why this clinic and not the one four hundred metres away, answered properly rather than asserted.
The rules removed price, product and proof by testimonial. What they left is identity, and identity was always the stronger asset. A clinic that could only advertise a discount was a clinic that had never built anything else.
The studio's own view is that the change advantaged clinics that were already good and disadvantaged clinics that were loud, which is the correct outcome for patients and an uncomfortable one for a large part of the industry.
What are the penalties?
Advertising breaches under the National Law carry financial penalties per offence, higher for a company than for an individual, alongside the regulator's power to require corrective action.
Separately, the Therapeutic Goods Administration enforces its own advertising rules. Infringement notices issued to a single body corporate in one recent enforcement action totalled $106,560.
The commercial risk is generally larger than the fine. A clinic told to remove years of content is a clinic whose entire advertising history disappears in a week.
Where should a clinic start?
Three things, in this order.
Audit what is already published. Everything, including stories, saved highlights, older posts and every page of the website. This is where the exposure is, not in next month's campaign.
Remove product names, category nicknames, prices, packages and testimonials from every surface, including the ones nobody has looked at in two years.
Rebuild on identity. Clinician, consultation, room, position. This takes longer than writing a discount and it is the only version that keeps working.
This article describes the rules in general terms and is not legal advice. The complete guidelines are published by AHPRA on its cosmetic procedures hub, and a clinic with a specific question should take specific advice.
Frequently asked questions
Can cosmetic clinics advertise injectables by name in Australia?
No. Prescription medicine names cannot be advertised to the public, and since September 2025 the common category words and nicknames used to work around that are treated the same way.
Are before and after photos banned for cosmetic clinics?
For prescription only injectables they are treated as advertising a medicine and are not permitted. For other treatments, images must be real, unedited, and carry a clear statement that results vary.
Can a cosmetic clinic use patient testimonials?
No. Testimonials about a regulated health service are prohibited in advertising, and the ban explicitly covers influencers, whether paid or gifted.
Do the rules apply to posts published before September 2025?
Yes. Anything still visible is still advertising, which makes historical content the most common source of exposure in the category.
What can a cosmetic clinic advertise now?
The clinician, the consultation, the room, and the reason a patient should choose this clinic over another. Identity rather than price, product or testimonial.
The Protocol is applied to three to five clinics per season. Apply for an introduction.
Most cosmetic clinic advertising in Australia is currently non compliant, and most owners running it have no idea.
Not because they are careless. Because the rules moved on 2 September 2025 and the content did not.
What changed in September 2025?
The guidelines closed the gaps rather than inventing a new regime.
Prescription medicine names could never be advertised to the public. What changed is that the workarounds are now treated identically to the names themselves. The category words and the nicknames the industry invented in order to keep advertising are covered, along with the hashtags built from them.
Price lists for those services are gone from advertising. So are specials, packages and anything expressed as a figure attached to the treatment.
Testimonials about a regulated health service are prohibited, and the guidelines make explicit that this includes influencers, paid or gifted.
Images must be real and unedited, and must carry a warning that results vary. Before and after imagery for prescription only injectables is treated as advertising a medicine, which places it under a different act entirely.
Trivialising language is out. The guidelines name the terms: artist, sculptor, magic hands, doll maker, god, queen, master, world's best.
Advertising cosmetic procedures to anyone under eighteen is prohibited outright.
There is also a practitioner standard sitting underneath all of it. A registered nurse now needs a minimum of one year full time general nursing experience plus specialised training before performing cosmetic procedures.
Why is historical content the real trap?
Because the rules apply to what is published, not to when it was written.
A post from 2022 naming a product is live advertising today. So is a pinned highlight, an old story saved to a profile, a results reel from three years ago, a price list still sitting on a services page nobody has opened since the website was built.
The clinic was compliant when it posted. The rules moved. The content did not.
This is the single largest source of exposure in the category and it is almost entirely invisible to the owner, because nobody scrolls back through four years of their own profile.
What is actually left to advertise?
More than most clinics think, and it is better material than what was taken away.
The clinician. Her training, her judgement, the number of times she has done the specific thing and the specific way she assesses a face before touching it.
The consultation. What actually happens, how long it takes, what she is told, what she is talked out of.
The room. What it looks like, how it feels, what it says about the standard being kept.
The position. Why this clinic and not the one four hundred metres away, answered properly rather than asserted.
The rules removed price, product and proof by testimonial. What they left is identity, and identity was always the stronger asset. A clinic that could only advertise a discount was a clinic that had never built anything else.
The studio's own view is that the change advantaged clinics that were already good and disadvantaged clinics that were loud, which is the correct outcome for patients and an uncomfortable one for a large part of the industry.
What are the penalties?
Advertising breaches under the National Law carry financial penalties per offence, higher for a company than for an individual, alongside the regulator's power to require corrective action.
Separately, the Therapeutic Goods Administration enforces its own advertising rules. Infringement notices issued to a single body corporate in one recent enforcement action totalled $106,560.
The commercial risk is generally larger than the fine. A clinic told to remove years of content is a clinic whose entire advertising history disappears in a week.
Where should a clinic start?
Three things, in this order.
Audit what is already published. Everything, including stories, saved highlights, older posts and every page of the website. This is where the exposure is, not in next month's campaign.
Remove product names, category nicknames, prices, packages and testimonials from every surface, including the ones nobody has looked at in two years.
Rebuild on identity. Clinician, consultation, room, position. This takes longer than writing a discount and it is the only version that keeps working.
This article describes the rules in general terms and is not legal advice. The complete guidelines are published by AHPRA on its cosmetic procedures hub, and a clinic with a specific question should take specific advice.
Frequently asked questions
Can cosmetic clinics advertise injectables by name in Australia?
No. Prescription medicine names cannot be advertised to the public, and since September 2025 the common category words and nicknames used to work around that are treated the same way.
Are before and after photos banned for cosmetic clinics?
For prescription only injectables they are treated as advertising a medicine and are not permitted. For other treatments, images must be real, unedited, and carry a clear statement that results vary.
Can a cosmetic clinic use patient testimonials?
No. Testimonials about a regulated health service are prohibited in advertising, and the ban explicitly covers influencers, whether paid or gifted.
Do the rules apply to posts published before September 2025?
Yes. Anything still visible is still advertising, which makes historical content the most common source of exposure in the category.
What can a cosmetic clinic advertise now?
The clinician, the consultation, the room, and the reason a patient should choose this clinic over another. Identity rather than price, product or testimonial.
The Protocol is applied to three to five clinics per season. Apply for an introduction.