Beauty or Medicine? The Fine Line Every Clinic Must Understand
Nurse or Doctor-Led Skin Clinic - Are You Promoting Skincare or Practising Medicine?
As the demand for aesthetic treatments continues to soar, many clinics now offer both non-medical beauty services and regulated medical procedures—sometimes under one roof. But whether you’re offering LED facials or dermal fillers, the way you market these services depends entirely on who provides them, and how.
Cosmetic Advertising Guidelines
What’s The Difference Between Medical and Non-Medical Treatments?
Non-Medical Treatments may include:
Basic facials
LED light therapy
Microdermabrasion (non-invasive)
Massage or spa services
These can be offered by non-clinical beauty therapists and are not regulated by AHPRA. They still fall under Australian Consumer Law, but do not require a registered health practitioner to deliver or supervise them.
Medical or Regulated Treatments include:
Cosmetic injectables (botulinum toxin, dermal fillers)
Laser resurfacing and Laser Genesis
Chemical peels with prescription actives
Microneedling with PRP or actives
Sclerotherapy, thread lifts, etc.
These must be overseen or prescribed by AHPRA-registered practitioners (doctors or nurses) and fall under AHPRA, TGA, and AMA compliance frameworks.
The Hidden Trap: Even Non-Medical Treatments Are Regulated in a Medical-Led Clinic
Here’s the critical compliance point most clinics miss:
If your business is led, owned, or marketed under an AHPRA-registered health practitioner (doctor, nurse, dentist), _then all advertising—including facials—must comply with AHPRA’s advertising laws.
That means even ads for simple, non-medical treatments:
Cannot use testimonials, even if “just about a facial”
Cannot suggest guaranteed results like “clearer skin” or “youthful glow” without substantiation
Must not blur clinical and non-clinical services under the authority of a medical title (e.g. “Nurse Jane’s Signature Glow Facial”)
Whether or not a procedure requires medical oversight, the moment a registered professional is attached to the brand or advertising, AHPRA rules apply across the board.
Key AHPRA Advertising Rules for Doctor/Nurse-Led Clinics:
No testimonials. Not even for facials or skincare.
No exaggerated promises. Avoid “10/10 results” or “my skin has never looked better.”
Don’t use professional titles casually. “Dr Smith’s Facial” implies clinical oversight—even if none exists.
Avoid mixing unregulated and regulated treatments in one ad unless it’s clearly disclosed. We’ve written a fascinating analysis of just such a predicament here
Why This Matters
The line between beauty and medicine is increasingly blurred—but regulators don’t see it that way. Clinics led by nurses or doctors must maintain professional standards in everything they promote—even if it’s “just skincare.”
Over 70% of cosmetic advertising audited by AHPRA in 2024–25 contained breaches. Most were related to:
Use of testimonials
Unrealistic outcomes
Glamourised visuals
Missing disclaimers
AHPRA and the Medical Board are clear: your professional responsibility doesn’t stop at the treatment room. It extends to your marketing.
What to Do Next
✔ Audit every ad—even the “simple” ones
✔ Separate regulated and non-regulated services visually and contextually
✔ Train your team and external marketers on AHPRA laws
✔ Engage compliance experts if you’re unsure
Need an AHPRA Ad compliance check-up?
Medicom offers AHPRA-compliant audits for websites, social media, printed material and staff communication. We also provide pre-treatment body dysmorphia screening tools, disclaimers, and support packages tailored to cosmetic, medical, and mixed-model clinics.
📩 Contact us for a content review or download our AHPRA Advertising Checklist for Medical-Led Clinics.
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