Is your practice website AHPRA compliant? A self-audit checklist

A page-by-page checklist for reviewing your practice website against the AHPRA advertising rules, TGA guidance and privacy law, current to October 2026.

6 October 20269 min read

Updated 29 October 2026 to reflect the latest rules and guidance.

Your practice website is advertising, and under the AHPRA guidelines the registered practitioner is responsible for every word on it, including pages written years ago or by someone else. Most practices have never reviewed their site from top to bottom with the rules in mind.

This checklist walks you through it page by page. It reflects the rules as they stand in October 2026, including the higher risk non-surgical cosmetic advertising guidelines that took effect on 2 September 2025, the TGA’s June 2026 guidance on prescription medicines, the OAIC’s June 2026 findings on tracking pixels and the ‘podiatric surgeon’ title change that took effect from 5 October 2026. It won’t replace a professional review, but it will help you find the most common problems. Grab a coffee, open your website and work through each section.

The rules your website has to meet

Section 133 of the National Law says advertising a regulated health service must not be false, misleading or deceptive, offer a gift, discount or inducement without stating its terms and conditions, use testimonials, create an unreasonable expectation of beneficial treatment, or encourage the indiscriminate or unnecessary use of health services. The detail sits in Ahpra’s Guidelines for advertising a regulated health service, which have applied since 14 December 2020.

Since 21 October 2022, the maximum penalty is $60,000 per offence for an individual and $120,000 for a body corporate. These rules apply to anyone who advertises a regulated health service, including unregistered owners and companies. Ahpra’s guidelines also say advertisers need to check content produced by others on their behalf, including agencies.

Other layers apply too: the Medical Board’s cosmetic surgery advertising guidelines (from 1 July 2023), the higher risk non-surgical cosmetic guidelines (from 2 September 2025), the TGA’s restrictions on advertising therapeutic goods, the Australian Consumer Law and the Privacy Act.

Home page

Are there any patient quotes, reviews or review widgets showing review text?
Do headlines promise outcomes, like ‘pain-free’, ‘life-changing’ or ‘guaranteed results’?
Are there superlatives you can’t back up, like ‘the best’, ‘leading’ or ‘number one’?
Do any offers or discounts appear without their terms and conditions?
Is there time pressure, like ‘book before Friday’, attached to clinical services?
Do hero images include stock photos that could be mistaken for patient results?

Service and treatment pages

Does each page explain what the service involves, who it may suit and what to expect?
Is risk and recovery information included and easy to find, not buried or missing?
Are claims about results supported by acceptable evidence, or written as descriptions of the service? Ahpra says acceptable evidence mostly means empirical data from formal research, not observations in practice.
Do any pages minimise treatment with words like ‘gentle’, ‘simple’, ‘safe’, ‘quick’, ‘easy’ or ‘painless’?
Do any pages suggest a service is needed when it may not be, or encourage repeat visits without a clinical reason?
Are prescription-only medicines named, abbreviated, nicknamed, pictured or priced anywhere? If so, this needs urgent attention.

Prescription medicine references

The Therapeutic Goods Act prohibits advertising prescription medicines to the public. The TGA’s guidance published on 18 June 2026 lists the kinds of references that are likely to be advertising: trade names, substance names, abbreviations, class terms such as ‘weight-loss injections’, ‘wrinkle reduction injections’, ‘peptides’ or ‘medicinal cannabis’, nicknames, and imagery like syringes, pens or cannabis leaves. It also says disclaimers such as ‘speak to your practitioner’ don’t exempt the material. Pages should promote the consultation and the concern or condition, not the medicine.

Practitioner and team pages

Is ‘surgeon’ used only for medical practitioners with specialist registration in surgery, obstetrics and gynaecology or ophthalmology? Since 20 September 2023 this is a protected title under section 115A of the National Law.
For podiatry practices, has ‘podiatric surgeon’ been replaced with ‘surgical podiatrist’? The old title can’t be used after 5 October 2026.
Do ‘specialist’, ‘specialises in’, ‘specialty’ or ‘specialised’ appear for anyone without specialist registration?
If a non-medical practitioner uses ‘Dr’, is their profession clear, for example ‘Dr Lee (Osteopath)’?
Are qualifications described accurately, without post-nominals that could imply extra qualifications?
For cosmetic procedures, does every advertised practitioner show their registration details, including registration number?
Are there any descriptions like ‘expert’, ‘artist’, ‘magic hands’ or ‘the best in Australia’?
Do names match the public register? Since 1 July 2024, a practitioner’s alternative practising name can appear on the register.

Images

Do you have documented consent for every patient image, separate from treatment consent?
Are any images filtered, retouched or likely to mislead?
Do before and after photos meet the guidelines: genuine patients, matching conditions, time elapsed shown, and a prominent warning that results are specific to that patient?
For higher risk non-surgical cosmetic procedures, is the first or most prominent image either the ‘before’ image or a combined before and after image?
For cosmetic services, are there any images of people under 18?
Are there emojis placed on images, or imagery that trivialises a procedure?

Reviews and testimonials

Is there a review widget showing clinical review text anywhere on the site?
Are there patient stories, case stories or video testimonials about outcomes?
Do blog posts include quotes from patients about their results?
Are on-site reviews edited so only positive parts show? Ahpra says this can be misleading.

Comments that are only about customer service or communication style are not testimonials. Ahpra’s guidance doesn’t specifically address star ratings, so the cautious approach is to link to your Google profile rather than display ratings on the site.

Prices and offers

Is every price accurate and current?
Do offers, discounts or free consultations include clear terms and conditions, such as expiry dates?
Is any time pressure attached to clinical services?
For cosmetic surgery, do prices show the total cost rather than only the consultation fee, as the Medical Board’s 2023 guidelines require?
Are finance or payment plans promoted for cosmetic procedures? The cosmetic practice guidelines prohibit this.
Are booking or service fees shown clearly? From 1 July 2027, the Unfair Trading Practices Act will require unavoidable transaction-based charges to be shown alongside any displayed base price.

Blog and educational content

Is the information accurate and up to date with current guidelines?
Are there older posts making claims you wouldn’t make today?
Does any ‘educational’ content effectively promote prescription-only medicines? The TGA’s April 2026 rewrite of its guidance on what counts as advertising says content is assessed case by case, so an article that names a medicine next to a booking button may be advertising.

Booking pages and forms

Does your online booking menu name or price prescription-only treatments? Bookings for these should be framed as consultations.
Do service names in your booking system match what you’d be comfortable advertising?
For cosmetic surgery, does the booking flow allow for the GP referral, two pre-operative consultations and seven-day cooling-off period in the Medical Board’s guidelines, with no deposit taken early?

Privacy, tracking and forms

Do you use Meta, Google or other tracking pixels on health pages or booking forms?
Does your privacy policy explain them, and do you get consent first?

On 24 June 2026 the OAIC announced determinations finding that two health providers interfered with privacy by collecting sensitive information through third-party tracking pixels without consent. The Commissioner found that tracking visitors to health-related websites and then targeting them with social media ads is a collection of sensitive information that requires consent.

Behind the scenes

Don’t stop at what’s visible on the page. Check:

page titles and meta descriptions, which appear in Google search results
image file names and alt text
old pages that are no longer linked but still live, and old landing pages from past campaigns
your business name and logo, which the TGA says can be advertising if they refer to a prescription medicine

Beyond your website

Your website isn’t the only place you advertise. Run the same checks on your Google Business Profile, health directory listings, social media accounts (including old posts, highlights and hashtags), influencer content and any ads you’re running. For cosmetic procedures, social ads must be labelled adult content and must not be targeted at under-18s.

Common mistakes we see

Review widgets installed years ago that nobody remembers.
Prescription product names in booking menus, alt text or page titles.
‘Specialist’ or ‘surgeon’ in Google Business Profile names and page titles.
Offers that state a price but no terms and conditions.
Old campaign landing pages still indexed in Google.
Tracking pixels on booking pages with no mention in the privacy policy.

What to do with what you find

List every issue, with the page it’s on.
Fix the highest-risk issues first: testimonials, prescription medicine references, protected title misuse and outcome claims.
Rewrite rather than just delete. Most pages can be made compliant and still persuasive.
Remove or redirect old pages you don’t want indexed.
Set a reminder to repeat the review at least once a year, and whenever guidelines change.

Frequently asked questions

How often should we audit our website?

At least once a year, and whenever guidelines change, your services change or a practitioner joins or leaves.

Does Ahpra check websites without a complaint?

It can. Ahpra’s enforcement strategy includes audits, and its 2023 cosmetic enforcement update described proactive advertising audits that led to regulatory action.

What happens if Ahpra finds a problem?

For a low-risk first breach, Ahpra usually writes asking you to fix the advertising. Continued non-compliance can lead to conditions on registration restricting advertising, and high-risk matters can go straight to prosecution.

Are old blog posts really a risk?

Yes. Anything still publicly visible is advertising, whatever its publication date.

Can a disclaimer fix a problem page?

Generally not. A disclaimer won’t fix a misleading overall impression, and the TGA says advising people to speak to a practitioner doesn’t exempt prescription medicine references.

Need a hand?

Prefer a professional review? Our AHPRA compliance audit covers your website and every other channel, with compliant replacement wording for each issue we find. You can also start with our free practice growth audit, which flags the most obvious red flags, and if a rebuild makes more sense, our clinic websites are built with these checks in from the start.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.