TGA updates its social media advertising guidance (November 2025)

The TGA’s 5 November 2025 social media update covers hashtags, reposts, influencers, comments, AI content and historical posts.

5 November 202511 min read

On 5 November 2025 the Therapeutic Goods Administration (TGA) published a substantial update to its guidance “Advertising therapeutic goods on social media”. The page, first published on 31 March 2022, now covers which social media activities count as advertising, who is responsible, and how specific tools such as hashtags, tags, reposts, livestreams, podcasts, sponsored ads and AI-generated content are treated.

The TGA said it was responding to an increase in unlawful social media advertising by businesses, health services and influencers promoting prescription-only medicines, naming a prescription weight-loss medicine and botulinum toxin cosmetic injectables. It said these posts often use images, nicknames, hashtags and influencer-style endorsements. For any clinic with a social presence, the update is a clear statement of what the regulator is looking for.

Status update: as at late October 2026 the social media page still shows 5 November 2025 as its last update. Related TGA guidance has changed since: the guidance on determining whether content is advertising was rewritten on 7 April 2026, and on 18 June 2026 the TGA published new guidance on the restrictions on advertising prescription medicines and substantially updated its health services guidance, including a section on influencers and content creators. We cover both in separate articles. Read this guidance alongside them.

What changed

The page history describes the 5 November 2025 change as content “updated to include comprehensive advertising guidelines for social media marketing tools/platforms/channels”, with new resource links. In its media release the TGA said the updated guidance explains:

types of social media activities that may be considered advertising
legal responsibilities of advertisers, including influencers and account holders
common compliance issues and how to avoid them, such as correct use of mandatory health warnings
how to use testimonials and endorsements compliantly.

The TGA encouraged all advertisers to review their social media content, “both historical and newly posted”. It said that in the 2024-25 financial year it requested the removal of over 13,700 unlawful advertisements from digital platforms, and that it also uses powers under the Telecommunications Act 1997 requiring internet service providers to block access to certain sites found to be in breach of the Act. It listed possible enforcement action as infringement notices, directions or prevention notices, or civil or criminal proceedings, with civil penalties of up to $1.65 million per breach for individuals and $16.5 million per breach for corporations.

This is guidance, not new law. The underlying rules come from the Therapeutic Goods Act 1989, the Therapeutic Goods Regulations 1990 and the Therapeutic Goods Advertising Code 2021.

Who it applies to

The guidance is aimed at businesses and social media influencers. It says businesses and social media account holders, including influencers, are responsible for social media content created or managed by them. That covers:

clinics and practices with their own social accounts
practitioners who post about therapeutic goods on personal or professional accounts
influencers and content creators, paid or gifted
agencies and contractors who create or manage content.

It applies to every type of platform, from social communities and professional networks to photo, video and audio platforms, blogs, microblogs and discussion networks. It also applies to “closed channels”, including private groups and dark marketing aimed at specific audiences, unless they meet the requirements for advertising exclusively to health professionals. The guidance gives the example of a private patient support group run by a pharmaceutical company: posts in the group that advertise therapeutic goods are still subject to the rules.

What the rules require

What counts as advertising on social media

The guidance says any statement, pictorial representation or design intended to draw attention to and promote the use or supply of therapeutic goods is likely to be advertising. That includes activities intended to attract new customers, encourage use, build loyalty and trust in a product or brand, sell products or drive website traffic.

Posts are more likely to be seen as promotional when they mention a product name or brand, highlight therapeutic uses or benefits, contain a testimonial or endorsement (including implied ones), or use certain links, tags and hashtags. Posts by someone with a financial interest in sales, such as a manufacturer, sponsor or retailer, are more likely to be promotional.

Advertising must be recognisable

Consumers should be able to recognise content as advertising immediately, without having to click or interact with it. This includes influencer content and paid endorsements, which must be clearly identified as advertising. The TGA notes that failing to do so may also breach the Australian Consumer Law. Where platforms offer a paid partnership disclosure, the guidance says it should be used.

Influencers you engage

The TGA recommends that businesses review content made by the influencers and content creators they engage. Where advertising is paid for and posted on a business’s behalf, the business may be responsible for any non-compliance. Businesses should also tell creators that the product is a therapeutic good and make them aware of the advertising requirements.

Reviews and comments are testimonials

Third-party reviews, including comments on posts by users who claim to have used therapeutic goods, are testimonials and must comply with the advertising requirements. Some goods, such as prescription medicines, cannot be advertised to the public at all, including through testimonials and endorsements.

The guidance says account holders should actively monitor their channels to remove unlawful posts and comments, note potential adverse events reported in comments, and ensure any testimonials comply with the Code. It also points to the ACCC’s view that fake reviews, or excluding genuine negative reviews to skew perception, is deceptive and against the law.

Links, tags and hashtags

Where a post includes links, tags or hashtags, the linked material is considered part of the advertisement, even if it is external, and the account holder is responsible for it. The guidance gives two pointed examples:

hashtags naming a particular disease, used in advertising for a medicine, would likely be advertising the medicine for that disease
hashtags referring to prescription medicines or substances, trade names, abbreviations, acronyms or colloquialisms are likely to be taken as advertising for that medicine or substance.

Tagging government bodies, including the TGA, can imply government endorsement, which is unlawful unless specifically permitted. The guidance says the claim “TGA approved” must not be used in advertising.

Sharing and reposting

Likes, retweets, reshares and tags can all be forms of sharing. Even if the original content is not promotional, resharing it in a context that promotes the goods is likely to be advertising. The guidance’s example is a lavender oil seller resharing a yoga studio’s post about calm and a lavender oil study.

Livestreams, podcasts and sponsored ads

For livestreams, the guidance recommends text overlays for mandatory statements and disclosures, repeated often enough for viewers to read, including those watching without sound. Commercial relationships should be disclosed periodically during a stream. Testimonials and endorsements must not come from people the Code prohibits, including current or former health practitioners, health professionals and medical researchers. Podcasts should make spoken statements clearly heard, without competing music or sound. Sponsored ads for therapeutic goods are considered advertising.

AI-generated content

The guidance says business owners and advertisers are responsible for AI-generated or AI-assisted content they manage and disseminate. Risks it lists include inaccurate or misleading information, unsubstantiated content, and false or misleading reviews and testimonials that are not from genuine consumers, including deep fakes.

Historical posts

All posts, historical and new, must comply. The guidance says each day a contravention is present may be considered a new contravention.

Children

The Code prohibits advertising of therapeutic goods directed to children under 12, and limits advertising to children over 12 to certain goods.

Acceptable use policy template

The guidance includes a template acceptable use policy for social pages. It asks commenters not to endorse products if they are, among other things, a current or former health practitioner, not using their own name, or connected to the business, and not to comment on personal experience if they received payment of any kind, including free products. It also asks people not to comment about serious conditions. The TGA advises registered health professionals to read Ahpra’s advertising hub and the Guidelines for advertising a regulated health service before using the template.

What it means for your marketing

Social media posts and reels

Check every post for direct and indirect references to prescription medicines: product names, ingredients, abbreviations, acronyms, nicknames, images and hashtags. Check that any product you can lawfully advertise is described within its approved purpose, with mandatory statements that are visible without clicking.

Comments and reviews

Set a moderation routine. Comments under clinic posts that describe using a product are testimonials. For registered practitioners, comments praising clinical outcomes also raise the National Law testimonial ban. Note and act on any comment that reports a possible adverse event.

Influencers and content creators

Brief creators in writing, review drafts before posting, and require clear advertising disclosure. Do not engage creators to talk about prescription medicines in any form. Remember that responsibility may sit with the clinic as well as the creator.

Paid social

Sponsored posts are advertising by definition. Apply the same checks to ad copy, images, landing pages and any linked content.

AI tools

If you use AI to draft captions, images or replies, treat its output as your advertising. Check claims, remove invented reviews or testimonials, and never use synthetic people presented as real patients.

Your back catalogue

The TGA asked advertisers to review historical content. Old posts that would breach the rules today are a live issue, not an archive.

Common mistakes we see

Hashtags or nicknames that stand in for a prescription medicine or substance.
Reposting a creator’s content about a treatment without checking what it implies.
Clinic posts captioned “TGA approved” or tagging the TGA alongside a product.
Comments describing product results left unmoderated for months.
Influencer posts with vague or hidden disclosure.
Assuming private groups, close friends lists or disappearing stories are outside the rules.
AI-generated images or captions published without a compliance check.
Livestreams or podcasts where a practitioner endorses a product.

A practical checklist

Audit all historical and current posts, stories, highlights, reels, captions and bios.
Search your accounts for brand names, ingredients, abbreviations, nicknames and hashtags relating to prescription medicines.
Check every link, tag and hashtag, since linked content forms part of the ad.
Remove any “TGA approved” claim and avoid tagging government bodies on product posts.
Publish an acceptable use policy on each page and moderate comments on a schedule.
Record and follow up any comment that may report an adverse event.
Put written briefs and pre-approval in place for every influencer and content creator.
Require clear, immediate advertising disclosure and use platform paid partnership tools.
Check that no current or former health practitioner endorses a product in any content.
Apply the same review to AI-generated or AI-assisted content.
Confirm targeting settings do not direct product advertising to children under 12.

How this fits with other rules

The Act and the Code are the law the guidance explains. The prohibition on advertising prescription medicines to the public is in the Act, and the testimonial and endorsement rules are in Part 6 of the 2021 Code.

Ahpra and the National Law govern how registered practitioners advertise their services on social media, including the testimonial ban. For higher-risk non-surgical cosmetic procedures, Ahpra’s advertising guidelines that took effect on 2 September 2025 add requirements such as restrictions on influencer and ambassador testimonials and rules on images.

The Australian Consumer Law requires that advertising is identifiable and not misleading, and prohibits fake or manipulated reviews. The TGA guidance itself points to the ACCC on both influencer disclosure and reviews.

Frequently asked questions

Is liking or resharing someone else’s post advertising?

It can be. The guidance says sharing includes likes on some platforms, reposts and tags, and that resharing in a context that promotes goods is likely to be advertising.

Are we responsible for comments people leave?

The guidance says responsibility may extend to user-generated content, including third-party comments on your platforms, and that reviews and comments claiming use of goods are testimonials.

Do old posts really matter?

Yes. All posts, historical and new, must comply, and the guidance says each day a contravention remains may be a new contravention.

Can a former nurse who is now an influencer promote a product for us?

Not as an endorser. The Code prohibits endorsements by current or former health practitioners and health professionals, and paid or gifted testimonials are not permitted.

Is a private Facebook group exempt?

No, unless it meets the requirements for advertising exclusively to health professionals. The guidance treats closed channels as subject to the same rules.

Does this guidance cover AI chatbots on our page?

The guidance says advertisers are responsible for AI-generated or AI-assisted content they manage and disseminate, including on social media, and that it must comply with the advertising requirements.

Need a hand?

A full review of your feed, comments and influencer content is the most direct response to the TGA’s call to check historical posts. Our social media for clinics service builds these checks into planning and moderation, and our TGA advertising compliance service audits existing content. For in-house teams, compliance training covers the TGA and Ahpra rules together.

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.