Your checklist. Twenty items.The AHPRA and TGA website check.

The 20 things a clinic website gets flagged for. By Amisha Sharma, Commas and Chaos. Under Australian law, every word on a clinic website counts as advertising, including your blog, your FAQs and your reviews. Work through your site with this list open and tick what you find.

Before you start

Each item shows what to look for and the rule behind it. The compliant rewrite is judgement work for your specific practice, and that is the work I do.

I write to the AHPRA advertising guidelines, the TGA advertising code and the NDIS Code of Conduct, and show you the checks. That is not legal advice, a compliance sign-off or an AHPRA ruling. The practice stays responsible for what it publishes.

0 of 20 ticked
Part 1

Proof and testimonials

  • 01

    Patient testimonials that mention treatment or results

    Any review, quote, or story that touches symptoms, diagnosis, treatment, or outcomes is banned in health advertising. "The team was friendly" is fine. "My back pain is gone" is a breach.

    Rule: National Law s133. Check: read every testimonial on your site. Does any mention a clinical result?

  • 02

    Google reviews re-shared on your site or socials

    You are not liable for what patients post on Google. You become liable the moment you embed, screenshot, or quote a clinical review in your own marketing. Re-sharing is publishing.

    Rule: AHPRA advertising guidelines. Check: do you have a review widget or a "what patients say" section?

  • 03

    Before and after photos

    Restricted in cosmetic advertising, and high risk everywhere else. Edited or "enhanced" images and results galleries count too.

    Rule: Medical Board cosmetic guidelines, AHPRA guidelines. Check: search your site and Instagram for any paired images.

Part 2

Claims and outcomes

  • 04

    Guaranteed or implied outcomes

    "Get lasting relief." "Walk out pain free." "Results you can see." If a sentence promises what the patient will get, it is a breach, because no clinician can guarantee an outcome.

    Rule: s133, misleading advertising. Check: find every sentence that describes the patient after treatment.

  • 05

    Timelines and certainty

    "Most patients improve within six weeks." Unverifiable statistics and recovery timelines imply a promised result.

    Rule: s133. Check: search your site for numbers of weeks, percentages, and the phrase "most patients".

  • 06

    Restricted treatment framings

    Some claims cannot be advertised to the public at all when tied to a treatment. Weight loss, anti-ageing, tissue and joint repair are the common ones on clinic sites.

    Rule: TGA Advertising Code, restricted representations. Check: do your service pages sell the condition and the outcome, or the consultation?

  • 07

    Superlatives

    "Best physio in Brisbane." "Leading clinic." "Top rated." All flagged, no matter how true they feel.

    Rule: AHPRA guidelines, creating unreasonable expectations. Check: search for best, leading, top, premier.

  • 08

    Comparisons

    Claiming you are better than other clinics, or better than seeing a GP, is a breach in both directions.

    Rule: AHPRA guidelines. Check: does any page mention other providers, "unlike other clinics", or going around the GP?

Part 3

Words and titles

  • 09

    "Specialist" or "expert" without specialist registration

    These words are protected. A general dentist calling themselves a "cosmetic dentistry specialist" is a title breach, and it carries criminal penalties, including substantial fines and possible imprisonment.

    Rule: National Law s115 to s118. Check: search every page, including your bios, for specialist and expert.

  • 10

    "Surgeon" without specialist surgical registration

    Since 2023, "surgeon" (including "cosmetic surgeon") is restricted to practitioners holding specialist surgical registration.

    Rule: National Law s115A. Check: who on your site is called a surgeon, and what registration do they hold?

  • 11

    "AHPRA-registered" used as a badge

    It reads as an endorsement, and every practising clinician must be registered anyway, so it also misleads. Same for "TGA approved" on anything.

    Rule: AHPRA and TGA guidance on regulator names in advertising. Check: search your marketing pages for AHPRA and TGA.

Part 4

Medicines

  • 12

    Naming prescription medicines or brands

    Prescription medicines cannot be named anywhere the public can read, brand names included, and that covers your blog. Nicknames and abbreviations count. This is the expensive one: TGA penalties stack per breach.

    Rule: Therapeutic Goods Act s42DL. Check: search your whole site, including old blog posts, for brand and substance names.

  • 13

    Indirect references to prescription medicine classes

    "Anti-wrinkle injections", "dermal fillers", "skin boosters", "fat dissolving". The TGA confirmed in 2025 that class references promote the substances too.

    Rule: TGA guidance, 2025 clarification. Check: your cosmetic service names and menus.

  • 14

    A blog post that names a medicine and ends with a booking button

    That combination turns an article into drug advertising. A "general information only" disclaimer does not cure it. Disclaimers never neutralise a breach.

    Rule: TGA guidance on advertising via editorial content. Check: every blog post that mentions any treatment, then look at its call to action.

  • 15

    Pharmacy and delivery language

    "Scripts delivered to your door", named pharmacy partners, "compounded and dispensed for you". Patients must have free choice of pharmacy, and this language is treated as channelling.

    Rule: TGA and Pharmacy Board guidance. Check: any mention of a pharmacy, dispensing, or delivery in your marketing.

Part 5

Offers and money

  • 16

    Urgency and inducements

    "Limited spots." "Book this month and save." For cosmetic procedures, discounts, bundles, and gift vouchers are flagged outright. Elsewhere, any offer needs clear terms and a value that does not push people into treatment.

    Rule: AHPRA guidelines, Medical Board cosmetic guidelines. Check: every offer, discount, and countdown on your site and socials.

  • 17

    Medicare and rebate absolutes

    "Medicare rebates available." "Bulk billed." Stated flat, these promise something that depends on each patient's eligibility, and that makes them misleading conduct.

    Rule: Australian Consumer Law. Check: your fees page and footer.

  • 18

    Operational absolutes

    "No waitlist." "Same-day appointments." "Immediate access." If it can ever be untrue, it is a misleading claim.

    Rule: Australian Consumer Law. Check: your booking page and any banner text.

Part 6

The fine print

  • 19

    A generic privacy policy on a health website

    Health information is sensitive information under the Privacy Act, and it comes with obligations a template policy does not cover: data breach notification, clinical record retention, overseas disclosure, and more.

    Rule: Privacy Act 1988, Australian Privacy Principles. Check: does your privacy policy mention health records specifically, or could it belong to any business?

  • 20

    Forms that collect health information without consent

    A booking or intake form that asks about symptoms needs a ticked consent checkbox and a collection notice at the form, and a marketing opt-in must be a separate box.

    Rule: APP 3 and APP 5, Spam Act 2003. Check: submit a test enquiry on your own site and look at what you were asked to agree to.

Your score

What the ticks mean

0 items ticked. Genuinely rare. Keep it that way, and re-check after every site update.

1 to 4 items. Typical for a clinic site that a generalist built. Each tick is a discrete risk, and the title and medicine items (9, 10, 12) carry the biggest penalties. Fix those first.

5 or more. Your site is carrying real regulatory exposure, and the fixes interact. Rewriting one page in isolation often moves the problem rather than removing it.

So what does the list not do?

The limit

What this checklist cannot do

It shows you where the flags are. It cannot tell you what to write instead, because the compliant version depends on your registration type, your services, and what you can prove. Two clinics with the same tick can need opposite rewrites.

That judgement is the work I sell. The GhostRank audit, one fixed price, on the audit page, checks up to 20 pages of your site against 226 checks, covering AHPRA, TGA, Google and AI search. Every flag comes with the rule cited and a compliant rewrite included. Full refund if it finds nothing worth fixing.

The small print

This checklist is general information, current at August 2026. It is a guide to where risk sits on clinic websites and a starting point for a proper review. That is not legal advice, a compliance sign-off or an AHPRA ruling. The practice stays responsible for what it publishes.

Rules cited: Health Practitioner Regulation National Law s133 and s115 to s118, the TGA Therapeutic Goods Advertising Code 2021, the Australian Privacy Principles, and Australian Consumer Law. The official guidance lives at the AHPRA advertising guidelines and the TGA advertising code.

Amisha Sharma is the healthcare copywriter behind Commas and Chaos. Based in Delhi, working Australian hours, writing for Australian clinics.

The next step

Ticked a few?

Send your website address. The GhostRank audit runs 226 checks across up to 20 pages, cites the rule behind every flag, and includes the compliant rewrite. Full refund if it finds nothing worth fixing.

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