The 2025 cosmetic advertising guidelines, one year on

A year after the higher risk non-surgical cosmetic advertising guidelines took effect: what they require, what’s happened since and where clinics still slip up.

8 September 20269 min read

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

On 2 September 2025, Ahpra and the National Boards’ Guidelines for practitioners who advertise higher risk non-surgical cosmetic procedures came into force. They were published on 3 June 2025 and apply to anyone who advertises these procedures, not just practitioners. They changed what cosmetic clinics can show and say more than any update in years.

A year on, plenty of clinics have updated their websites. Far fewer have reviewed everything else: old social posts, booking menus, influencer content and the way they respond to reviews. Meanwhile the TGA has stepped up its own enforcement on cosmetic injectables. Here’s a refresher on what the guidelines require, what has happened since, and where clinics most often still fall short.

What changed on 2 September 2025

Two sets of guidelines took effect on the same day:

Advertising guidelines for higher risk non-surgical cosmetic procedures, issued by Ahpra and the National Boards and applying to individuals and businesses that advertise these procedures.
Practice guidelines for practitioners who perform non-surgical cosmetic procedures, covering every registered profession except medicine. Doctors already follow the Medical Board’s cosmetic guidelines, which took effect on 1 July 2023.

They sit on top of the general Guidelines for advertising a regulated health service, which have applied since 14 December 2020. Where prescription-only medicines are involved, the Therapeutic Goods Act applies as well, and it doesn’t allow prescription medicines to be advertised to the public at all.

Who the guidelines apply to

The advertising guidelines cover higher risk non-surgical cosmetic procedures. Examples in the guidelines include cosmetic injectables such as botulinum toxin and dermal fillers, injection lipolysis, thread lifts, sclerotherapy and microsclerotherapy, platelet rich plasma procedures, hair transplants, dental veneers and procedures that penetrate the dermis using chemicals, light, laser, heat or cold. Botulinum toxin used to treat medical conditions is outside their scope.

They apply to registered practitioners, including doctors, nurses and dentists, and to non-practitioner businesses that advertise these procedures. Agencies, influencers and ambassadors who produce the advertising are part of the picture too.

What the guidelines require

Practitioner registration details

Advertising must include information about the practitioner’s registration details, including their registration number. The guidelines also list terms such as ‘doll-maker’, ‘magic hands’, ‘sculptor’ and ‘artist’ as trivialising, and say practitioners must not be described in a way that may mislead about their abilities.

No testimonials, including through interaction

The National Law already bans testimonials. The guidelines spell out that a practitioner also uses a testimonial when they re-share stories or posts from patients, or interact with a review on a third-party website or social media page, such as by liking it. Practitioners must take steps not to interact with testimonials, which can include disabling reviews, comments or tagging on their social media pages.

Influencers and ambassadors

The guidelines say using influencers, ambassadors or similar increases the risk of non-compliance, and practitioners must ensure any advertising produced complies with all guidelines.

Images

Before and after images must be genuine, of actual patients who had the procedure.
The most prominent or first image seen should be either a combined image of both ‘before’ and ‘after’, or the ‘before’ image.
Images must be as similar as possible in content, lighting, camera angle and other conditions.
Images must not be edited or enhanced with filters, retouching, grey-scaling or similar techniques.
The ‘after’ image should say how long after the procedure it was taken.
There must be a prominent warning that the outcomes shown are only relevant for that patient.
You need the patient’s fully informed consent to use the images, separate from their consent to the procedure.
Images of people under 18 must not be used.

Risks and recovery

Advertising must give accurate, realistic and educative information about risks, and full information about risks must be easy to find. Minimising terms such as ‘gentle’, ‘simple’, ‘safe’, ‘quick’ or ‘easy’ should not be used, and advertising must not downplay recovery or mislead people about pain.

Nothing that trivialises or idealises

Advertising must not trivialise these procedures. The guidelines give examples such as imagery with music, dancing, singing or comedic comments, emojis on images or used to show an emotional reaction to an image, and encouraging interaction with images in a competitive way. Words such as ‘ideal’, ‘perfect’ and ‘instant’ are flagged, and procedures must not be offered as competition prizes.

Vulnerable people and under-18s

Advertising must not exploit people who may be vulnerable, such as people with low self-esteem or who are unhappy with their appearance, and must not suggest a procedure is the only option. It must not be targeted at people under 18. Social media advertising must be identified as ‘adult content’, and advertisers must not use algorithms, metadata or hashtags to push content towards vulnerable groups. The guidelines also note that excessive posting may contribute to body image dissatisfaction.

No appearance-prediction tools

Advertisers must not use automated apps, websites or tools that predict how a person will look after a procedure.

Financial rules in the practice guidelines

For non-medical practitioners, the practice guidelines ban offering, promoting or recommending financing schemes, free or discounted procedures in exchange for promotion and recruitment commissions. Under-18s must have a seven-day cooling-off period. Prescribers must hold an in-person or video consultation each time they prescribe a cosmetic injectable, and the guidelines say asynchronous prescribing is not acceptable practice. The Medical Board’s 2023 guidelines set similar financial and consultation rules for doctors.

What has happened in the year since

12 September 2025: Health Ministers discussed regulatory challenges in the cosmetic injectables sector, including cross-border and telehealth workarounds, and asked for single-product telehealth prescribing to be reviewed.
5 November 2025: the TGA substantially updated its social media advertising guidance, citing rising unlawful promotion of prescription medicines including cosmetic injectables. It said it requested removal of more than 13,700 unlawful advertisements from digital platforms in 2024 to 2025.
18 December 2025: the TGA announced infringement notices totalling $7,716 to a Queensland individual for allegedly importing counterfeit botulinum toxin and advertising prescription-only cosmetic injectables on social media. Further notices to individuals followed in January 2026.
1 January 2026: the TGA’s Compliance Principles for 2026 and 2027 began to apply, with therapeutic goods used in cosmetic procedures among the first priority focus areas.
28 March 2026: the maximum fixed Australian Consumer Law penalty for companies doubled to $100 million for conduct from that date.
18 June 2026: the TGA published new guidance on the restrictions on advertising prescription medicines to the public. Its examples of references to avoid include trade names, nicknames such as ‘Tox’, abbreviations such as ‘HA injections’ and terms such as ‘wrinkle reduction injections’, along with imagery like syringes, and it says business names and logos can be advertising.
9 July to 3 September 2026: the TGA consulted on targeted changes to the Therapeutic Goods Advertising Code. No outcome had been published at the time of writing.

What it means for your marketing

Website and booking system

Add registration details wherever a practitioner is advertised, check every image against the rules, and make risk and recovery information easy to reach from every procedure page. Online booking menus that list prescription-only treatments by name or price are advertising those medicines, so frame bookings as consultations.

Google Business Profile and reviews

Don’t like or reply approvingly to positive reviews. Keep responses brief and neutral, never discuss treatment, and check your business name and services list for prescription medicine terms.

Social media and influencers

The guidelines apply to everything still publicly visible, not just new posts. Label ads as adult content, switch off age and interest targeting that could reach under-18s, and review influencer content still live.

Paid ads

Ad copy, keywords and landing pages need the same care: no minimising language, no prescription medicine references, no prize promotions, and terms and conditions on any offer.

Where clinics still slip up

Old social media posts

Years of Instagram content, highlights and pinned Stories often contain testimonials, filtered images, emojis on images or trending audio that no longer comply.

Booking systems

Service names in booking platforms are often written by whoever set the system up, and frequently name prescription products.

Review responses

Liking a glowing review, or replying “So glad you love your results!”, is interacting with a testimonial.

Practitioner profiles

Team pages and social bios often name practitioners without registration details, or use the descriptors the guidelines list as trivialising.

Hashtags and captions

Hashtags that name or nickname prescription medicines are still common, and they turn otherwise compliant posts into medicine advertising.

A practical checklist

Every advertised practitioner shows registration details, including registration number.
Before and after images are genuine, unfiltered, consistently taken, show time elapsed, lead with the combined or ‘before’ image and carry a prominent patient-specific warning.
You hold separate, documented consent for every patient image.
No images of under-18s, and social ads are labelled adult content.
No testimonials, re-shared patient posts or liked reviews.
No ‘safe’, ‘quick’, ‘easy’, ‘perfect’ or ‘instant’ language.
No emojis on images, trending audio, dance or comedy content, or competitions.
No appearance-prediction tools on your website or social channels.
No finance or payment plan promotion for procedures.
No prescription medicine names, nicknames, abbreviations or imagery anywhere, including booking menus and hashtags.
Risk and recovery information is easy to find from every post and page.

How this fits with other rules

Ahpra’s guidelines govern how the procedure and practitioner are advertised. The TGA governs references to the medicines and devices used. A post can comply with one and breach the other. The Medical Board’s 2023 guidelines still apply to cosmetic surgery advertising by doctors, and the Australian Consumer Law applies to pricing, offers and reviews for every business.

Frequently asked questions

Do the guidelines apply to clinics owned by non-practitioners?

Yes. The advertising guidelines apply to individuals and businesses that advertise higher risk non-surgical cosmetic procedures, not only to registered practitioners.

Do doctors follow these guidelines?

Yes for advertising. The 2025 advertising guidelines apply to all registered practitioners, including doctors. The 2025 practice guidelines exclude doctors, who follow the Medical Board’s 2023 guidelines for performing cosmetic procedures.

Can we still use before and after photos?

Yes, if they meet every condition: genuine, unedited, consistent conditions, time elapsed shown, the right image first, a prominent warning and separate consent.

Are emojis banned completely?

The guidelines specifically flag emojis on images and emojis used to show an emotional reaction to an image, as part of the wider rule against trivialising procedures. The safest approach is to leave them out of cosmetic procedure advertising.

Can we say ‘anti-wrinkle injections’?

The TGA has not accepted terms like ‘wrinkle reducing injections’ since 7 March 2024 where a reasonable consumer would understand them as promoting a prescription medicine. Promote a consultation for the concern instead.

Need a hand?

Our AHPRA compliance audit covers your website, booking system, social accounts and ads, with compliant replacement wording for every issue we find. Our TGA advertising compliance service handles the medicine side, and you can read more about how we work with cosmetic and skin clinics.

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.