Are Australian Cosmetic Clinics Compliant with AHPRA and TGA Advertising Rules? Our 2025 Audit Findings
Cosmetic clinics across Australia face increasing scrutiny from regulators, with new AHPRA and TGA advertising guidelines for non-surgical cosmetic procedures coming into effect in September 2025. Yet our mini audit of clinics in Sydney, Melbourne, Brisbane, and Perth shows that widespread non-compliance remains the norm.
In this blog, we break down the findings from our city-by-city review, highlight common advertising mistakes, and explain what this means for clinics trying to stay competitive while staying on the right side of the law.
Why Advertising Compliance Matters More Than Ever
The cosmetic industry in Australia has grown rapidly over the past decade, with more clinics offering injectables, fillers, and non-surgical procedures than ever before. Alongside this growth, regulators have sharpened their focus on ensuring advertising is truthful, balanced, and does not mislead patients.
Importantly, most cosmetic clinics that offer injectables or prescription-based treatments are doctor or nurse-led. This means they fall squarely under:
AHPRA Guidelines for Advertising a Regulated Health Service
Medical Board of Australia’s Guidelines for Cosmetic Surgery and Procedures
TGA advertising requirements for therapeutic goods
Key risks of non-compliance include:
Fines under Section 133 of the National Law
Advertising takedowns and restrictions
Board disciplinary action for registered practitioners
Reputational damage if clinics are named publicly for breaches
With so much at stake, you might expect most clinics to be fully compliant. Our findings suggest otherwise.
How We Conducted the Audit
In September 2025, we reviewed publicly accessible websites of cosmetic clinics in four major cities: Sydney, Melbourne, Brisbane, and Perth. We assessed each clinic against key compliance risk areas, such as the use of restricted terms, presence of before-and-after images, use of promotions or inducements, inclusion of disclaimers, and practitioner transparency.
Audit Results: City by City
Sydney AHPRA Ad Compliance
In Sydney, most clinics continue to rely heavily on restricted terms like anti-wrinkle injections and dermal fillers. Several offered inducements such as discounts or free consultations. While some had taken steps towards compliance—adding disclaimers or shifting detailed treatment information into consultation settings—overall, gaps remained. A small number attempted to differentiate themselves by emphasising doctor-only services, but this alone does not guarantee advertising compliance.
Melbourne AHPRA Ad Compliance
Moving to Melbourne, the picture was even starker. Every clinic reviewed openly used restricted terminology, and promotional inducements were universal. Free consultations, discounted treatments, and sales-driven messaging were common. Disclaimers, on the other hand, were scarce, with only a handful of sites including even basic risk or “results vary” statements. Melbourne clinics stood out as the most promotion-heavy, and therefore the most exposed to regulatory breaches.
Brisbane AHPRA Ad Compliance
In Brisbane, the trend continued: all clinics we reviewed used restricted treatment names prominently in their service menus. Every clinic promoted offers or inducements, ranging from free consults to package-style discounts. Only a small proportion included any kind of risk or disclaimer messaging, and practitioner credentials, while generally present, were often vague about exactly who provided each treatment.
Perth AHPRA Ad Compliance
Finally, Perth showed some slight improvement compared to the other cities. While restricted terms and inducements were still widespread, a larger proportion of clinics included side-effect information or disclaimers in their content. This additional effort suggests some awareness of the regulatory changes, but overall, Perth clinics still fell short of full compliance. Practitioner credentials were consistently highlighted, often with references to doctor-led or advanced injector oversight, yet this was not enough to offset broader advertising issues.
National Comparison: The Numbers Don’t Lie
Despite some differences between cities, the broad patterns were clear. Restricted terminology was nearly universal. Promotions and inducements were present in almost every city, with Melbourne and Brisbane being the most aggressive. Disclaimers were the weakest area across all regions, while practitioner transparency was generally high but often superficial. Crucially, not a single clinic in any city was found to be fully compliant with the current advertising standards.
Common Compliance Mistakes Clinics Are Still Making
Across all cities, we observed recurring mistakes:
Advertising restricted prescription-only medicines by name or class.
Overuse of promotional inducements (discounts, free consults, urgent “book now” calls).
Lack of disclaimers about risks, variability of results, and side effects.
Use of before-and-after images without adequate risk context.
Vague practitioner transparency, where clinics claim “doctor-led” services without clarifying who performs which treatments.
What About Non-Medical Cosmetic Clinics?
This raises an important question: what about cosmetic clinics that are not doctor or nurse-led?
These clinics may not perform injectables, but many still use medical-grade devices such as:
Class 3 & 4 lasers (for hair removal or skin resurfacing)
Medical-grade chemical peels
Energy-based devices marketed as “skin tightening” or “fat reduction”
While these operators may not fall directly under AHPRA’s scope (if no registered health practitioner is involved), they still must comply with TGA advertising rules and Australian Consumer Law.
Should there be a level playing field? Many argue yes. Patients often cannot easily tell the difference between a nurse-led cosmetic injector clinic and a non-medical laser clinic. Both can create unrealistic expectations or minimise risks in their marketing. A more consistent approach to regulation would better protect consumers and create fairer competition.
What This Means for Clinics
Our findings highlight three urgent takeaways for clinics:
Non-compliance is the norm, not the exception. Regulators could easily target multiple clinics in any city with little difficulty.
Promotions are a compliance trap. Discount-driven marketing strategies are among the riskiest practices under current guidelines.
Disclaimers are underused. Even a simple “results vary” or “all procedures carry risk” statement can reduce risk exposure, yet most clinics omit them.
How Clinics Can Protect Themselves
Compliance doesn’t mean abandoning effective marketing. Instead, it requires:
Replacing restricted terms with neutral, educational language.
Using consultation-first models rather than promoting specific treatments.
Including clear disclaimers on every promotional page or post.
Being transparent about who delivers care, including qualifications.
Seeking regular independent audits to ensure alignment with updated guidelines.
Conclusion: A Wake-Up Call for the Industry
Our 2025 mini audit shows that Australian cosmetic clinics are falling behind on compliance. Regulators are watching more closely than ever, and the cost of inaction could be severe.
Whether your clinic is doctor-led, nurse-led, or non-medical, the advertising standards landscape is shifting. Consumers expect honesty, safety, and transparency—and regulators are pushing for the same.
If your clinic is unsure where it stands, now is the time to act. Compliance not only protects you from penalties but also builds patient trust.
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