On 1 September 2022, the NSW Public Health Regulation 2022 commenced, remaking the state’s codes of conduct for non-registered health practitioners and for “relevant health organisations”. Western Australia followed with its code of conduct for certain health care workers from 27 July 2023, and Tasmania adopted the National Code of Conduct for health care workers with effect from 24 June 2026.
These codes matter for marketing because they reach people and businesses that the national Ahpra advertising rules do not cover: counsellors, naturopaths, many beauty and cosmetic service providers, and registered practitioners who offer services unrelated to their registration. They restrict misleading claims about services and qualifications and, in most cases, require the code and complaints information to be displayed. If your clinic mixes registered and unregistered staff, or offers services outside the registered professions, these codes probably apply to part of your business.
What changed
Each jurisdiction has made its own change, at its own pace.
New South Wales: 1 September 2022
The Public Health Regulation 2022, made under the Public Health Act 2010 (NSW), commenced on 1 September 2022. It contains two codes:
- Schedule 3: a code of conduct for practitioners who are not subject to the national registration scheme (including de-registered practitioners), and for registered practitioners who provide health services unrelated to their registration.
- Schedule 4: a code of conduct for “relevant health organisations”, which NSW Health describes as organisations that provide health services but are not public health organisations or licensed private health facilities.
NSW already had codes of conduct in this area before 2022. The 2022 Regulation remade them. Complaints about breaches can be made to the NSW Health Care Complaints Commission (HCCC), which can investigate. If a breach is found, the HCCC may make a prohibition order against the practitioner or organisation.
Western Australia: 27 July 2023
The Health and Disability Services Complaints Office (HaDSCO) states that WA’s code of conduct for certain health care workers takes effect from 27 July 2023. It does not apply retrospectively, so HaDSCO can only deal with code complaints about conduct after that date.
HaDSCO can investigate complaints about alleged breaches and can begin investigations without a complaint. It can issue an interim prohibition order while an investigation is completed, and a prohibition order at the end of one. HaDSCO notes the code does not restrict entry into practice, but it allows action such as orders to stop practising, or conditions on practice, where there is a serious risk.
Tasmania: 24 June 2026
The Health Complaints (Code of Conduct) Regulations 2026 were made on 25 May 2026 and notified in the Gazette on 3 June 2026. They take effect 21 days after gazettal, which is 24 June 2026. The regulations prescribe the National Code of Conduct for health care workers for Tasmania, with the Health Complaints Commissioner as the complaints body.
Who it applies to
The broad pattern is the same in each state. The codes cover health care workers who sit outside the national registration scheme run by Ahpra and the National Boards, plus registered practitioners when they provide services that have nothing to do with their registration.
- NSW: unregistered practitioners (including de-registered practitioners), registered practitioners providing unrelated health services, and relevant health organisations other than public health organisations and licensed private health facilities.
- WA: health care workers who are not registered under the national scheme, registered workers providing services unrelated to their registration, and student and volunteer health care workers. HaDSCO gives counsellors, naturopaths, nutritionists and reiki practitioners as examples, and notes that registered professions such as nurses and physiotherapists are not covered when practising in their registered profession.
- Tasmania: the code applies to the provision of health services by health care workers. The definition of “health care worker” sits in the Health Complaints Act 1995 (Tas). Check that Act, or ask the Health Complaints Commissioner, if you are unsure whether you are covered.
In practical terms, the people most likely to be affected in a clinic setting include beauty therapists and dermal therapists who are not registered practitioners, counsellors and some therapists, nutritionists and naturopaths, massage and wellness providers, practice staff delivering services that are not regulated by a National Board, and registered practitioners running a side business unrelated to their registration. In NSW, the practice business itself may also be a relevant health organisation.
If you practise outside NSW, WA and Tasmania, check with your own state or territory health complaints body about what applies there.
What the rules require
The specific wording differs between jurisdictions, so read the code that applies to you. Below are the requirements that matter most for marketing, using the wording we have confirmed from each source.
No claims to cure serious illness
In Tasmania, clause 8 of the code says a health care worker “must not claim or represent that the worker is qualified, able or willing to cure cancer or other terminal illnesses”. A worker who claims to treat or alleviate the symptoms of cancer or other terminal illnesses must be able to substantiate those claims.
In WA, HaDSCO describes clause 8 as prohibiting claims to cure certain serious illnesses.
No misinformation or misrepresentation
Tasmania’s clause 9 is the most detailed marketing rule in these codes. A health care worker must not engage in any form of misinformation or misrepresentation about their products, services, qualifications, training or professional affiliations. They must not use a qualification to mislead clients or the public about their competence or ability to provide treatment. They must provide truthful information about their qualifications, training or professional affiliations. And they must not make claims, “either directly to clients or in advertising or promotional materials”, about the efficacy of treatment if those claims cannot be substantiated.
In WA, HaDSCO describes clause 9 as requiring that workers must not misinform their clients.
Display the code and complaints information
This is the requirement most often missed.
- NSW: under clause 15 of Schedule 3 and clause 10 of Schedule 4, most practitioners and relevant health organisations must display a copy of the relevant code and an approved notice about making complaints to the HCCC. NSW Health says this can be displayed at the practice or service premises or on the practitioner’s or organisation’s website.
- WA: clause 17 requires workers to display the code and other information. HaDSCO provides downloadable posters, including an A4 Easy English version and an A3 full-clause version.
- Tasmania: clause 17 requires a worker to ensure that a copy of the code, and a document explaining how clients can make a complaint to the Health Complaints Commissioner, is displayed or made available at all premises where they practise, so that it is easily visible or accessible to clients.
What it means for your marketing
Website
Your website is where claims about qualifications and treatment effects are easiest to check, both for you and for a complaints body. For services delivered by unregistered staff, review:
- Qualification descriptions. Make sure each team member’s qualifications, training and memberships are stated accurately. Do not describe a short course as if it were a degree, and do not imply a professional affiliation that does not exist.
- Treatment claims. Any claim about what a treatment achieves must be something you can substantiate. This is explicit in the Tasmanian code and consistent with the general consumer law prohibition on misleading conduct.
- Serious illness. Remove any suggestion that an unregistered service can cure cancer or other serious or terminal illnesses. Be careful with claims about relieving symptoms, which in Tasmania must be substantiated.
- Code display in NSW. If you rely on the website option in NSW, publish the code and the approved complaints notice somewhere easy to find, such as a page linked from the footer.
Team pages and practitioner bios
Mixed clinics often list registered and unregistered staff side by side. Make the difference clear. A beauty therapist should not be presented in a way that suggests they are a registered nurse or medical practitioner. Titles, uniforms in photos and bio wording all contribute to the overall impression.
Google Business Profile and reviews
Your Google Business Profile services list and description are claims about your services. Keep them factual. Reviews are not directly addressed by these codes, but if your practice includes registered practitioners, the National Law testimonial rules apply to advertising of their services. Consumer law also applies to how you collect and present reviews.
Social media and influencers
Before-and-after posts, treatment explainer videos and captions all count as promotional material. Under Tasmania’s clause 9, unsubstantiated efficacy claims in advertising or promotional material are expressly prohibited. Influencer and ambassador content you commission is still your promotion.
Paid ads
Short ad copy tends to overclaim. Phrases like “fixes”, “cures” or “permanent results” need to be substantiated or removed, whichever state you are in.
Printed and in-clinic material
Display obligations are physical in WA and Tasmania. Put the code poster and complaints information where clients can easily see it, such as the reception area. Brochures and price lists should use the same careful wording as your website.
Common mistakes we see
- Assuming Ahpra rules are the whole picture. Unregistered services in a clinic are not covered by the National Law advertising rules, but that does not mean they are unregulated.
- Not displaying the code. Many clinics simply do not know about the display requirement.
- Blurring roles. Team pages that let readers assume every staff member is a registered practitioner.
- Overstating qualifications. Listing courses, certificates or memberships in ways that suggest more than they are.
- Health claims for wellness services. Claims that a service treats or relieves medical conditions without evidence.
- Forgetting multi-state operations. A group with clinics in several states may face different codes and display rules at each site.
A practical checklist
- List every service your practice offers and who delivers it. Mark which are delivered by registered practitioners in their registered profession, and which are not.
- For each service not covered by registration, identify which state code applies.
- Download the code and complaints information for your state and display it at each premises, or in NSW, on your website if you choose that option.
- Review every team bio for accurate qualifications, training and affiliations.
- Check service pages, social posts and ads for treatment claims, and confirm you can substantiate each one.
- Remove any claim to cure cancer or other serious or terminal illnesses.
- Make sure registered and unregistered roles are clearly distinguished in all marketing.
- Brief staff who post to social media about what they can and cannot claim.
- Diarise a yearly review, and check for new codes if you open in another state.
How this fits with other rules
Ahpra and the National Law. Registered practitioners advertising services within their registration are covered by the National Law advertising provisions and the National Boards’ advertising guidelines. The state codes pick up what falls outside that system, including registered practitioners providing services unrelated to their registration. A clinic with both types of service may need to meet both sets of rules.
Cosmetic procedures. Ahpra’s guidelines for advertising higher risk non-surgical cosmetic procedures, which took effect on 2 September 2025, apply to anyone advertising those procedures, including businesses and individuals who are not practitioners. A beauty or cosmetic business may therefore be covered by both a state code and those guidelines.
Australian Consumer Law. The ACL prohibits misleading or deceptive conduct by all businesses. It sits underneath every other rule here.
TGA. If you advertise therapeutic goods, such as supplements or devices, TGA advertising rules apply as well.
Frequently asked questions
I am a registered nurse who also runs a separate business. Does the code apply to me?
Possibly. In NSW and WA, the codes apply to registered practitioners who provide health services unrelated to their registration. Whether a particular service is unrelated depends on the facts. If you are unsure, ask the relevant complaints body or get independent advice.
Can I display the NSW code on my website instead of in the clinic?
NSW Health says the code and the approved complaints notice must be displayed at the practice or service premises or on the practitioner’s or organisation’s website. The WA and Tasmanian requirements refer to display at premises.
Does the WA code apply to things we did before July 2023?
No. HaDSCO says the code takes effect from 27 July 2023 and does not apply retrospectively.
What can happen if a code is breached?
In NSW the HCCC can investigate and may make a prohibition order. In WA, HaDSCO can investigate and issue interim prohibition orders and prohibition orders, and publishes public health warning statements where there is a risk.
Are symptom relief claims allowed?
In Tasmania, a worker who claims to treat or alleviate the symptoms of cancer or other terminal illnesses must be able to substantiate those claims, and any claims about treatment efficacy in advertising must be capable of substantiation. As a general rule in every state, only make claims you can back up.
Where do I get the poster?
HaDSCO provides downloadable posters for WA. In NSW, see the NSW Health code of conduct page for the code and approved complaints notice. In Tasmania, contact the Health Complaints Commissioner.
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- The NDIA crackdown on “NDIS approved” and “100% NDIS funded” ads
- Bulk billing and fees: how to describe them clearly on your website
- SMS Sender ID Register: what practices need to do for patient texts
Need a hand?
Mixed clinics with registered practitioners, beauty therapists and allied staff are among the hardest to get right, because several sets of rules apply at once. An AHPRA compliance audit can map which rules apply to each service and check your website, bios and ads. If you are a cosmetic clinic or allied health practice, we can also help you rewrite content so it is accurate and clear.
This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the practitioner or business providing the service (and, where they are involved, the registered practitioner), and complex situations may need independent legal advice.