On 18 June 2026 the Therapeutic Goods Administration (TGA) published new guidance, “Complying with the restrictions on advertising prescription medicines to the public”, and substantially updated its health services guidance, now titled “Advertising health services that involve therapeutic goods”. The prescription medicines guidance was updated again on 23 June 2026.
Together these two pages are now the most detailed statement of how the TGA reads the ban on advertising prescription medicines. They give specific examples covering business names and logos, booking systems, price lists, before and after photos, telehealth funnels, email campaigns and influencer content. If your practice promotes any service that involves prescription medicines, this is the guidance your marketing will be measured against.
Status: this is guidance on existing law, not a change to the legislation. The TGA also opened a separate consultation on changes to the Therapeutic Goods Advertising Code on 9 July 2026, which we cover in a separate article.
What changed
The TGA’s media release of 18 June 2026 said the new guidance provides practical examples of advertising and promotional activities likely to be prohibited across websites and social media, business names and logos, booking systems, product catalogues, price information and other materials.
The health services guidance page history records that the 18 June 2026 update changed the title from “Advertising a health service”, added a new section on when an advertisement for a health service also advertises therapeutic goods, moved some content into the new prescription medicines guidance, and added new information for telehealth services. The updated page also includes a section on influencers and content creators.
The TGA said it takes compliance action against illegal advertising and promotion of prescription medicines to the public, particularly online, including advertising of services that prescribe or supply products such as cosmetic injectables, peptides, weight loss injections, medical cannabis, IV drip therapies and erectile dysfunction medicines. It said businesses are expected to promptly review and, where necessary, amend or remove non-compliant content.
Who it applies to
The guidance is written for businesses involved with prescription medicines, including sponsors, health services and relevant third parties. In practice that covers:
- medical, dental, allied health and cosmetic practices
- telehealth services, including single-condition or single-product services
- pharmacies, including compounding pharmacies
- weight loss, men’s health, pain, medicinal cannabis, IV therapy and peptide clinics
- influencers, content creators and agencies working for any of the above
“Prescription medicines” in the guidance covers substances in Schedule 4 and Schedule 8 of the Poisons Standard. The same rules apply to Schedule 3 (pharmacist only) substances unless they are in Appendix H, which lists Schedule 3 medicines that may be advertised to the public.
What the rules require
The basic prohibition
Advertising prescription medicines to the public is prohibited under subsections 42DL(10) and 42DLB(7) of the Therapeutic Goods Act 1989, apart from limited circumstances. The guidance notes that unlawful advertising of prescription medicines may also breach other provisions, including using restricted or prohibited representations without permission, implying government endorsement such as “TGA approved”, promoting off-label use, and failing to comply with the Advertising Code.
The TGA’s release states that penalties include civil penalties of up to $1.65 million per breach for individuals or $16.5 million per breach for corporations, as well as fines or imprisonment.
Direct and indirect references
The prohibition applies when an advertisement includes a direct or indirect reference to a prescription substance or medicine, including colloquial or abbreviated names and class terms. The TGA says an indirect reference, such as “plant-based medicine” or “weight loss injection”, is likely to be a reference to a prescription medicine when viewed in context, even if no specific product or substance is named.
The guidance includes a table of examples. In summary, the categories are:
- product or trade names, or part of them
- direct references to specific substances
- abbreviations or acronyms, with examples including CBD, THC, HA injections, GLP-1 receptor agonists and BPC 157
- class terms, including indirect substitutes, with examples including medicinal cannabis, plant-based medicine, weight-loss injections, wrinkle reduction injections and peptides
- colloquial names or nicknames, with “Tox” among the examples
- images or designs, including in logos, such as graphics of syringes, applicator pens, vials, capsules or pills associated with prescription medicines, and images of a cannabis leaf
Disclaimers do not fix it
The guidance says including a disclaimer or caveat, such as advising the consumer to speak with a health practitioner about appropriate treatment options, does not exempt the material from the restrictions.
The limited exceptions
The guidance describes these situations where the prohibition does not apply:
- Advertising directed exclusively to health professionals. It must be directed only to health professionals, and promoting off-label use is still unlawful.
- Information a practitioner gives directly to their own patient in the course of treatment. The health services guidance says this does not apply to publicly accessible content, where there is no established practitioner and patient relationship, or where minimum standards for being a patient are not met. Mass communications to prospective customers are unlikely to be exempt.
- Advertising authorised or required by an Australian government or government authority, such as some public health campaigns.
- Published permissions and approvals, such as those allowing vaccination providers to say they provide vaccines, subject to conditions.
- Price lists that comply with the Code, which are available only in limited circumstances to certain businesses.
The specific examples, by activity
Business names and logos
A business name that directly or indirectly refers to a prescription medicine may be advertising if it suggests the business prescribes, supplies or uses that medicine. Logos that depict a prescription medicine, whether realistic, stylised or cartoon, may also be advertising. The TGA’s examples include a pain clinic with “Medicinal Cannabis Clinic” in its name, a “Dispensary” with a stylised cannabis leaf, and a men’s health logo featuring a blue pill.
Telehealth and prescribing services
Materials that promote a health service, including telehealth, as a way to obtain specific prescription medicines are likely to be unlawful advertising. That includes saying the service can supply or facilitate supply of specific medicines, can provide prescriptions for specific goods or a class of medicines, or offers consultations for specific medicines where the advertising implies a prescription could or will result.
The guidance’s examples include a pain clinic encouraging bookings with a “specialist medicinal cannabis prescriber”, a wellness centre naming a hair-loss prescription medicine, a cosmetic clinic promoting “natural-looking cosmetic injectables” to smooth lines and wrinkles, and a pharmacy UTI service promoted as a way to get antibiotics without visiting a GP. The TGA adds that promoting conditions and services within a pharmacy’s scope of practice, without referring to therapeutic goods, is unlikely to be advertising of therapeutic goods.
Logins and paywalls
Promoting prescription medicines behind a login, paywall, membership or subscription may still be advertising to the public, unless it is directed exclusively to health professionals or is information shared within an established practitioner and patient relationship.
Booking systems, catalogues and symptom checkers
A publicly available booking system or catalogue that shows which prescription medicines are available may be advertising. So may a form, survey, questionnaire, eligibility checker or symptom checker that lets consumers select conditions and see medicines, and a chatbot that suggests a prescription can be issued for certain conditions. One example is a cosmetic clinic booking system listing prescription medicines by name under “wrinkle-reduction services”.
Price information
Listing prices for treatments or services that involve prescription medicines, whether as a total cost or per unit, is likely to be advertising. The TGA’s example is a cosmetic clinic price list showing per-unit costs and package deals for botulinum toxin and dermal fillers.
Before and after photos
The Act does not prohibit before and after photos for a health service. But if it is expressly or implicitly suggested that the after photo results from a prescription medicine, that is likely to be advertising the medicine.
Pharmacies and in-clinic signage
Promoting that specific prescription medicines or a class of them can be dispensed is unlawful, including in waiting rooms, foyers, windows and retail spaces. General dispensing offers, such as cheaper prescriptions or click and collect, are not advertising therapeutic goods unless they promote specific medicines or classes.
Email and SMS campaigns
Mass emails, texts and webinars about prescription medicines are unlikely to be exempt because they are not information given during treatment. The TGA’s example is a cosmetic clinic emailing former patients about prescription-only injectable products, their benefits and prices, which it says is prohibited.
Links, shares and testimonials
Linking to or re-sharing third-party material that promotes a specific prescription medicine can make your own material advertising. Testimonials and endorsements about a prescription medicine are likely to be unlawful advertising, and Ahpra separately prohibits testimonials in advertising regulated health services.
Influencers and content creators
The health services guidance says informal influencer content can still be advertising. Posts showing or implying use of therapeutic goods, indirect terms such as “anti-wrinkle”, “lip injections” or “weight-loss shots”, tags, links, discount codes or booking directions, and before and after or treatment progress content are all flagged as risks. Clinics that engage creators should give clear instructions, and the TGA says responsibility may extend to both the clinic and the creator.
What it means for your marketing
Website
Audit page titles, URLs, navigation, headings, images and alt text, not just body copy. Remove product, substance and class references for prescription medicines. Restructure treatment pages around consultations and the conditions you treat. The TGA’s own example of acceptable wording is a consultation to discuss treatment options for migraine.
Online booking and intake forms
Check whether your booking categories, intake questionnaires or eligibility tools name or imply prescription medicines. These are now specifically addressed.
Google Business Profile
Your business name, categories, services, products and photos must not refer to prescription medicines. Logos with syringes, pens or pills associated with prescription medicines are a risk.
Social media and influencers
Brief creators in writing, review content before it goes live where you can, and stop discount codes and results content for prescription treatments.
Paid ads
Remove prescription medicine keywords and ad copy, and make sure landing pages do not present your service as a way to get a specific medicine.
Email and SMS
Promotional campaigns to your list about prescription treatments are treated as mass communications, not patient care.
Common mistakes we see
- Relying on “speak to your practitioner” disclaimers.
- Business, domain or service names that point to a prescription medicine.
- Logos and icons featuring syringes, pens, vials or pills.
- Telehealth funnels that imply a prescription for a specific medicine will follow.
- Putting prescription content behind a login and assuming it is private.
- Public price lists for prescription treatments.
- Patient newsletters promoting prescription treatments.
A practical checklist
- Search all content for product names, substances, acronyms, nicknames and class terms for prescription medicines.
- Review business names, domain names, logos and icons.
- Review booking systems, intake forms, symptom checkers and chatbots.
- Remove price lists that reference prescription medicines.
- Review before and after images for implied prescription medicine results.
- Check gated and member-only content.
- Review email and SMS campaigns and automations.
- Check outbound links and shared posts.
- Issue written briefs to influencers and creators.
- Rewrite service descriptions around consultations and conditions.
How this fits with other rules
The TGA does not regulate health service promotion itself, but if service advertising also advertises therapeutic goods, the Act applies. The health services guidance reminds advertisers that the ACCC (Australian Consumer Law), Ahpra (advertising of regulated health services by registered practitioners) and state and territory consumer laws may also apply. Ahpra and the National Boards also provide guidance on telehealth consultations.
Compounded medicines are not exempt from the advertising requirements, and human cell and tissue products are regulated as biologicals that cannot be advertised to the public.
Frequently asked questions
Did the law change in June 2026?
No. The guidance explains how the TGA applies the existing prohibitions in the Therapeutic Goods Act 1989.
Can a telehealth service advertise at all?
Yes, but it should promote consultations and the conditions it treats without presenting itself as a way to obtain specific prescription medicines.
Is information on my patient portal exempt?
Only information given by a practitioner to their own patient during treatment is exempt, within an established relationship. Content behind a login or paywall that is available to non-patients may still be advertising.
Can I show before and after photos?
The Act does not prohibit them for a health service, but not where they suggest results came from a prescription medicine. Ahpra’s rules on images also apply.
Who is responsible for influencer posts?
The TGA says responsibility may extend to both the clinic and the content creator.
Related articles
- TGA updates its social media advertising guidance (November 2025)
- TGA compliance principles and focus areas for 2026 and 2027
- TGA rewrites its guidance on what counts as advertising
- TGA consults on changes to the Therapeutic Goods Advertising Code
Need a hand?
If your website, booking flow or social channels were built around treatments rather than consultations, a structured review is a good next step. Our TGA advertising compliance service audits websites, booking systems and campaigns against this guidance, and our social media for clinics service can help set up compliant creator briefs. We also work with general practices and cosmetic clinics on this.
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.