What counts as "advertising" under AHPRA
The first confusion point for most practitioners is scope: what does AHPRA actually regulate? The answer is broader than most practices expect.
Under the Health Practitioner Regulation National Law, "advertising" covers any communication — in any medium — that is designed to promote a regulated health service and encourage people to use it. This is a deliberately wide definition. It includes:
- Your practice website
- Social media profiles and posts (including personal profiles if they mention your practice)
- Google Business Profile and all directory listings
- Paid advertising on Google, Facebook, Instagram, and elsewhere
- Email newsletters and automated follow-up sequences
- Brochures, flyers, and physical marketing materials
- Press releases and earned media mentions that you facilitate
- Testimonials posted or republished by anyone — even if the patient posted them independently on a public platform
The regulatory framework applies to all 16 registered health professions under AHPRA: medicine, nursing, midwifery, pharmacy, physiotherapy, psychology, chiropractic, osteopathy, optometry, dentistry, podiatry, occupational therapy, Chinese medicine, Aboriginal health practice, paramedicine, and medical radiation practice. It does not apply to dietitians, speech pathologists, social workers, or other non-AHPRA-registered practitioners — though these professions have their own industry codes of conduct that may impose similar constraints.
The key legislative sections are Section 133 of the National Law (prohibited advertising) and AHPRA's published Advertising Guidelines, which provide detailed interpretation. The guidelines were substantially updated in 2020 and again in late 2023 — if you haven't reviewed them since 2022, your compliance posture may be outdated.
Testimonials — the most misunderstood rule
The prohibition on testimonials is the AHPRA advertising rule that catches the most practices, causes the most complaints, and is also the most consistently misunderstood.
The rule: advertising for a regulated health service must not use testimonials about the service or business.
What this means in practice is that you cannot use patient statements — in any form — that describe their clinical experience, express satisfaction with a treatment, describe a health outcome they experienced, or recommend your services based on their own treatment journey.
- "After six sessions with [Practitioner], my chronic back pain was gone." — outcome statement
- "I'd tried everything before I found this clinic. Nothing worked until I came here." — comparative outcome
- "The physiotherapy I received here changed my life." — benefit claim via patient voice
- "Five stars — I can't recommend [Practice] highly enough for post-surgical rehab." — review with treatment reference
- Before-and-after photos or case study descriptions attributable to a real patient experience
- Video testimonials or patient story content on your website or social media
- "The staff were professional and the booking process was easy." — experience, not outcome
- "Friendly clinic, clean facilities, on-time appointments." — administrative experience
- "I always feel heard and respected in my consultations." — communication quality, not clinical outcome
- Star ratings without accompanying text (though this has nuance — see below)
The Google Reviews problem
One of the most common compliance scenarios we encounter with new clients is a Google Business Profile full of patient reviews that contain outcome statements, treatment descriptions, and clinical endorsements. The practice didn't solicit them explicitly — patients just wrote them — and the practice has been encouraging people to "leave a review" without guidance on what is and isn't permitted.
Here is the key point: AHPRA's prohibition applies to testimonials that are "used in advertising" — which includes testimonials that you facilitate, encourage, leave up knowingly, or republish. Simply asking for reviews without content guidance creates exposure. Sharing or republishing a non-compliant review amplifies that exposure.
Best practice:
- Develop a standard review request that explicitly asks patients to comment on their experience of the practice (service, communication, facilities, admin) rather than on clinical outcomes or treatment results
- Do not reshare or republish reviews that contain outcome content
- Monitor your Google, Facebook, and directory profiles for non-compliant reviews and seek removal where possible
- Do not respond to reviews in a way that validates or amplifies prohibited content
Outcome claims and before-and-after content
Section 133 prohibits claims that could encourage inappropriate use of a health service, create an unrealistic expectation, and mislead patients about the likely outcomes of treatment.
In practical terms, this means your marketing cannot state or imply that patients who use your service will achieve specific outcomes — even if those outcomes are common, well-evidenced, or genuinely representative of your patient results.
| Statement | Status | Why |
|---|---|---|
| "We help patients recover from ACL surgery faster." | Prohibited | Specific outcome claim — "faster recovery" — not achievable by all patients |
| "Evidence-based physiotherapy for ACL recovery." | Permitted | Describes approach, not outcome |
| "Our patients report high satisfaction with their outcomes." | Prohibited | Outcome-based aggregated claim, not demonstrably accurate for individual prospective patients |
| "Specialised treatment programs developed with current clinical evidence." | Permitted | Describes practice standards, not patient outcomes |
| "Voted Gold Coast's best physio 2025." | Caution | Comparative claim — must be substantiated from a genuinely independent process |
| "Before and after: patient's scar at 6 weeks vs 12 weeks." | Prohibited | Combines testimonial, identifiable patient, and outcome claim |
| "Our approach to pelvic floor rehabilitation." | Permitted | Educational content describing a service without outcome claims |
The "appropriate use" clause
The prohibition extends beyond explicit outcome claims. Marketing that could cause a patient to seek treatment they don't need — through exaggerated problem descriptions, fear-based messaging, or claims designed to create anxiety about untreated conditions — also violates the guidelines, even if no specific outcome is claimed.
This applies to content that describes conditions in a way designed to alarm readers into booking, rather than inform them about when professional assessment is appropriate.
Social media compliance
Social media sits inside AHPRA's advertising definition entirely. Every post on a practice account — regardless of platform — that mentions health services, patient experiences, or clinical capabilities is subject to the same rules as your website.
AHPRA's scope extends to personal social media profiles if you are using them to promote a regulated health service. A physiotherapist who posts "another great day at the clinic — helped three post-surgical patients get back on their feet" on their personal Instagram is advertising a regulated health service. The fact that it is a personal account does not create an exemption.
Platform-specific considerations
Instagram and Facebook: Patient photos, treatment shots, and case content are the most common compliance breach on these platforms. Before-and-after posts, patient transformation content, and treatment result photography — even with patient consent — are generally prohibited. Educational content explaining conditions, modalities, or anatomy is permitted.
TikTok and short-form video: The same rules apply. Educational health videos are fine. Practitioner-patient content that shows treatment processes or implies clinical outcomes is not. Sharing or boosting content created by a patient about their treatment at your practice — even on their account — raises questions about whether you are "using" that content in advertising.
LinkedIn: More commonly used for practitioner authority and professional networking. The rules still apply to any content that promotes a regulated health service — including posts describing treatment approaches, patient outcomes (even anonymised), or practice capabilities in clinical terms.
User-generated content
When a patient creates content about their experience at your practice and shares it on their own social media, you are not automatically responsible for that content — unless you reshare it, embed it, or otherwise incorporate it into your own advertising. The moment you repost or republish it, you are using a testimonial in advertising and the prohibition applies.
Google Business Profile and reviews
Your Google Business Profile is advertising under AHPRA. The description, the services list, the posts, and the reviews section are all in scope.
The reviews challenge
Google does not provide a compliant review structure for health practices — its review system allows freeform text, which means patients can and do write outcome-based content, testimonials, and clinical endorsements without any guidance. Managing this is an ongoing operational responsibility, not a one-time fix.
Steps to bring your GBP into compliance:
- Audit all current reviews. Flag any that contain outcome statements, treatment descriptions, or clinical endorsements as potentially non-compliant.
- For non-compliant reviews: you can flag them to Google for removal on the basis of spam/fake content in some cases. For legitimately written but non-compliant reviews, AHPRA's position is that the practice should not actively solicit or republish them — the review itself may not create direct liability if you didn't solicit it, but legal advice is appropriate for higher-risk content.
- Update your review request process. Any practice communication asking for reviews should specify the types of feedback that are appropriate — experience of service, communication quality, administrative processes — without soliciting clinical outcome statements.
GBP business description
The business description field is frequently non-compliant. "We help patients recover from injury" — prohibited. "Our physiotherapists provide evidence-based treatment for musculoskeletal conditions" — permitted. Review yours against the outcome claims framework above.
Website content
Your website is the highest-scrutiny advertising channel from a compliance perspective — it is permanent, searchable, and the most likely source of formal complaints.
Service pages
Service pages should describe what each service involves, who it may be appropriate for, and how it works — without making claims about what patients will experience or achieve. The distinction is between describing a service (permitted) and promising an outcome (prohibited).
Condition-specific pages that explain a condition's characteristics, typical presentations, and how your service addresses it are generally compliant, provided they don't imply guaranteed outcomes or use fear-based framing to drive unnecessary bookings.
Practitioner bios
Bios are among the cleanest areas of a health website from a compliance perspective — they describe qualifications, clinical interests, and experience. The main risk areas are:
- Describing case outcomes in practitioner bio copy
- Using superlative language ("the best", "Gold Coast's leading") without substantiation
- Including patient quotes or case study references in bio copy
FAQ and educational content
FAQ content and educational blog posts are excellent compliance-safe content formats. Explaining conditions, treatment modalities, when to seek care, and what to expect in a consultation is informative content that does not constitute advertising in the same way promotional content does — provided it is genuinely educational rather than a thinly-disguised promotional piece.
Paid advertising
Google Search ads, Meta ads, and other paid placements are advertising under AHPRA — the rules apply with equal force to paid as to organic content. In some respects, paid advertising creates higher exposure because it involves active promotion rather than passive discovery.
Google Search ads
Headlines and description copy must comply with the same rules as website content. Outcome-based claims ("Feel better fast", "Get pain-free results"), testimonial extensions, and before-and-after assets are prohibited. Ad extensions — review snippets, callout extensions — should be reviewed for compliance before activation.
Meta advertising
Facebook and Instagram ads for health services sit at the intersection of AHPRA compliance and Meta's own health and wellness advertising policies, which add a further layer of restriction (notably around before-and-after content and body image claims). Practices running Meta ads should be compliant with both frameworks simultaneously.
Retargeting
Retargeting ads that serve to people who visited your website are advertising a regulated health service to a known audience. The compliance requirements are the same — the targeting method does not create an exemption.
The 8 most common compliance mistakes
These are the violations that appear in most practice audits we run on the Gold Coast and nationally — often on sites that have been live for years:
- Google reviews with outcome content left visible and unaddressed. The practice didn't write them, but they're on the profile and the practice knows about them.
- Instagram posts showing patient results. Usually posted with patient consent — but consent doesn't make an outcome-based testimonial compliant.
- Website service pages with transformation language. "We help you return to the activities you love" — prohibited. "We provide physiotherapy for musculoskeletal rehabilitation" — permitted.
- FAQ content that overstates treatment benefits. Condition explainer pages that end with "book now to get relief" or imply that your service will solve the described problem.
- Practitioner bio copy with clinical case references. Including even anonymised case outcomes in bio sections.
- Award claims without substantiation. "Gold Coast's top physio" or "best-rated clinic" without an independently verified, reproducible source.
- Sharing patient-generated content. Reposting a patient's Instagram story about their treatment outcome — prohibited regardless of the patient's enthusiasm.
- Generic marketing agency copy. Copy written by an agency that doesn't understand AHPRA, applying standard "results-focused" language to health services.
What happens if you breach the guidelines
AHPRA receives complaints from patients, competitors, and members of the public. It also conducts its own advertising monitoring — proactively reviewing websites, social media, and directory listings for non-compliant content. Being found non-compliant is not a minor administrative matter.
The regulatory response to a first-time, lower-severity breach is typically a direction to remove or amend the non-compliant content, with no formal sanction. However, this still involves correspondence with a regulator, potential public record, and the time and cost of a formal response process.
For repeat breaches, higher-severity content (false qualifications claims, dangerous health information), or practices that fail to respond to initial AHPRA contact, the consequences escalate: formal cautions, conditions on registration, public statements on the AHPRA register, and in the most serious cases, suspension or cancellation of registration.
The advertising guidelines are not obscure. AHPRA publishes them clearly, provides compliance checklists, and offers informal guidance. Claiming unawareness of the rules is not a mitigating factor in the regulatory process.
What good, compliant marketing actually looks like
The most common misunderstanding about AHPRA compliance is the belief that compliant marketing means boring marketing. It does not. The rules restrict a specific set of tactics — outcome-based testimonials, before-and-after content, false impressions. They do not prevent you from building a compelling, distinctive, high-performing online presence.
Compliant health marketing that works uses a different set of tools:
Authority through expertise, not endorsements
Instead of patient testimonials describing clinical outcomes, build authority through practitioner credentials, published content, and clinical education. A physiotherapist who writes a detailed, evidence-referenced post on post-surgical rehabilitation earns credibility from the quality of the content — not from aggregated patient ratings. That content also ranks, gets cited, and keeps working long after it's published.
Educational content that ranks
Condition explainer pages, FAQ content, and clinical education articles are fully compliant and represent some of the highest-value SEO content a health practice can produce. A well-written 1,500-word page on endometriosis management — written by a gynaecologist, explaining the condition, typical presentations, and what an assessment involves — ranks for high-intent searches and builds trust without making a single prohibited claim.
Experience-based reputation
Compliant reviews describe the experience of being a patient at your practice — the communication quality, the environment, the admin efficiency, the feeling of being heard. This is credible, AHPRA-safe, and what most prospective patients actually read before booking. Build a review request process that asks for experience-based feedback explicitly, rather than leaving patients to write whatever comes to mind.
Practitioner visibility
LinkedIn content, published articles, and podcast appearances from named practitioners build the entity-level authority that drives both traditional SEO rankings and AI search citations. A practitioner who publishes regularly on their specialty becomes a citable source — which is exactly what you need for AI search visibility in 2026. Our allied health SEO service is built around this framework — compliant content that ranks and builds entity authority simultaneously. Practices focused on female health conditions should also read how our women's health marketing approach applies the same principles to a higher-trust audience.
Get a free AHPRA compliance audit.
Thinkbig reviews your full online presence — website, Google Business Profile, social media, and review content — against AHPRA's advertising guidelines, and delivers a prioritised compliance brief. You'll also get a clear picture of what compliant growth looks like for your practice specifically.
Book a free 20-minute callDisclaimer: This guide is produced by Thinkbig Media for general information purposes. It summarises AHPRA's published advertising guidelines as at April 2026. It is not legal advice. Practices with specific compliance questions or existing regulatory matters should obtain independent legal advice from a health law practitioner. AHPRA's advertising guidelines are subject to update — always check the current version at ahpra.gov.au.