AHPRA Advertising Rules for Optometrists: The Myopia Claim That Needs a TGA Permission

Yes, AHPRA advertising rules apply to you as an optometrist, through Section 133 of the National Law. Most practices know that part. The part they get wrong sits in a different law. A claim that a lens slows a child's myopia is a restricted representation under the TGA's ad code. That means it is an offence to put it in a public ad, unless the TGA has given permission. The TGA did give one. It is the Contact Lenses and Spectacle Lenses Permission 2025, and it comes with conditions. So your fastest growing service is also the most tightly controlled sentence on your website.

Can an optometrist advertise myopia control to parents?

Yes, you can. You just have to be careful, and nobody hands you the rulebook when you register.

Myopia control is the big growth area in Australian optometry. It covers special contact lenses, special spectacle lenses and orthokeratology. Practices are building whole service pages around it. Those pages are aimed at parents of short-sighted children.

Every one of those pages falls under 2 separate laws at once.

You probably know the first one. Section 133 of the National Law covers how you advertise your health services. Your eye test is one. So is your consultation.

Most practices miss the second one. The lens itself is a therapeutic good, which means a health product the TGA regulates. Once you make a claim about what the lens does, you have moved into a different law. It is the Therapeutic Goods Act. And a claim that a lens slows myopia in children is no ordinary claim.

It is a restricted representation.

What is a restricted representation?

The TGA explains it plainly. It is a claim that points to a serious form of a disease, condition, ailment or defect. It counts whether you say it outright or only hint at it.

"Serious" has its own test. The TGA treats a form as serious if it needs a qualified health professional to diagnose it, treat it or keep an eye on it. There is a second part too. It also counts if there is a test for it that needs an expert to read the results.

Now hold childhood myopia up against those 2 tests. It needs a qualified professional to diagnose it. It needs ongoing care. It has a test that needs an expert to read it. So it fits.

Here is what that means for you. The TGA says it is an offence to use a restricted representation when you advertise health products to the public. The only way through is a TGA approval or a TGA permission.

So the sentence on your service page is more than a marketing choice. You first need to know if you have permission to say it.

What does the 2025 lens permission actually do?

It opens the door that the TGA's ad code closes.

The permission has a long name. It is the Therapeutic Goods (Restricted Representations, Contact Lenses and Spectacle Lenses) Permission 2025. The TGA lists it with its other advertising permissions.

It covers lenses with a certified purpose in one of 2 areas. The first is lenses that correct how the eye focuses. The second is lenses that slow the progress of myopia.

For those lenses, you may use the claims set out in the permission in your ads. That is what it allows.

Now for the part people skip. The permission only applies under the conditions written into it. So treat it like a licence with terms, and read the terms closely. That is where you stay safe.

This has 2 practical effects on your website.

• Your claim has to match the lens. The permission covers lenses with a certified purpose. A lens certified for myopia control can carry the claim. A lens without that certification cannot. Clever wording on your page does not change that.
• The permission only covers what it says. It does not cover a wider claim about eye health. It says nothing about what your young patient's sight will be at 30.

For the bigger picture of how the code treats claims, we broke it down in the guide to the TGA Advertising Code. The same rules turn up in advertising prescription medicines. There the ban is total, and you cannot apply for permission.

Why are glasses and contact lenses regulated differently?

The rules for them split in June 2024, and a lot of website copy has not caught up.

Contact lenses are medical devices. The TGA puts them at Class IIa, the low to moderate risk level. To sell them legally in Australia, they must be listed on the Australian Register of Therapeutic Goods (the ARTG).

Prescription glasses lenses used to sit in the same system. That changed on 15 June 2024. They no longer need to be on the ARTG before you import, export or sell them.

So you now run 2 sets of rules inside one practice and one dispensary.

The change was about selling the lens. It did not change what you may claim about it. A restricted claim about a glasses lens is still restricted.

Here is the trap. Practices read "exempt" and hear "deregulated". The exemption is only about getting the product onto your shelf. The ad rules are a separate matter, and they did not move.

What does Section 133 still cover?

It covers your service rather than the product. And it covers more than testimonials.

Section 133 bans you from advertising a health service in a way that:

• is false, misleading or deceptive, or is likely to mislead or deceive.
• offers a gift, discount or other reward. That is allowed only if you state the terms and conditions of the offer.
• uses testimonials about the service or business. Things dressed up to look like testimonials count too.
• raises hopes of a benefit that are not reasonable.
• pushes people to use health services they do not need.

Read that last one again with your shop in mind. Say your page pushes more eye tests than the clinical need supports. That is a Section 133 problem, as well as a pricing one.

On testimonials, the rule reaches further than most practices think. It catches reviews you publish. It catches quotes you pick out. It catches patient stories you write up. We set out where the line falls in what actually counts as a testimonial.

The penalties are no longer small. AHPRA states that a 2022 change raised the maximum fine for each advertising offence. For a person it went from $5,000 to $60,000. For a company it went from $10,000 to $120,000. As of July 2024 those higher penalties apply in every state and territory.

Is a free eye test an inducement?

It can be. This is where optometry differs from every other AHPRA profession.

You are a clinician and a shopkeeper at the same counter. A physio does not sell you a product on the way out. You do.

So one offer can be a health service claim and a shop claim in the same sentence.

Section 133 does not ban discounts or offers. It only bans them when the terms and conditions are missing. So this rule is about how you word the offer. Most practices fail it by leaving something out. They rarely mean any harm.

Here are 3 examples of the same mistake:

• A bundled offer sits on a home page banner. The conditions sit on another page, or nowhere.
• An offer has an end date in the small print. The copy that promotes it never says so.
• A free eye test is promoted without saying what you have to buy to get it.

Fixing this usually takes a paragraph, and you do not need a new site. Put the terms where the offer is. If they are too long for the banner, say where they are. Then check the link works.

The Australian Consumer Law reads the shop half of your page too. It does not care that you are a health practitioner. Bundle prices, comparison claims and "was" prices are its ground.

Why does optometry get so few advertising complaints?

Almost nobody complains about optometry ads. That is the good news and the risk in one go.

Optometry Australia gave the figure when AHPRA announced its advertising audit. In 2018 to 2019, AHPRA received 515 low-risk to moderate-risk advertising complaints. Exactly 1 was about an optometrist.

The current data is just as quiet. AHPRA's 2024/25 annual report puts registered optometrists at 7,340. That is up 4.1 per cent in the year to June 2025. Across all professions the figure is 959,858. Optometry recorded 81 notifications (formal complaints) involving 71 practitioners. That is under 1 per cent of registered optometrists.

Here is why the quiet is a problem for you. Attention follows complaints. Cosmetic injectables get close checks because the complaints keep coming. Optometry does not. So there is little guidance written for your profession, and practices build websites from general marketing advice.

AHPRA has not left it all to chance, though. You sign a declaration each time you renew your registration. It says that if you advertise as an optometrist, your ads meet Section 133 and the Board's advertising guidelines.

So you have already signed something about your website. It is worth knowing what your website says.

Who is liable when the agency wrote the page?

You are, and so is the agency.

Section 133 does not say "a registered health practitioner must not advertise". It says a person must not. That one word does a lot of work.

It reaches your practice. It reaches the company that owns your practice. It reaches the agency writing your copy. Nobody at that agency needs to be registered for it to apply.

This matters because most optometry websites are not written by optometrists. Agencies write them from a brief. Those briefs rarely mention the TGA's ad code. We have written about what happens when an agency does not know the rules. The pattern is the same in every profession we audit.

The fix is a habit, and you rarely need a rewrite. Whoever signs off your copy needs to know which rulebook each sentence falls under. And that sign-off has to happen before you publish, well before any letter arrives.

What should a practice fix this quarter?

Here are 5 things to fix, in this order. None of them needs a new website.

1. Find every myopia sentence. Look on your service pages, home page, blog and social bios. Check each claim against the certified purpose of the lens you sell. Then check it against the conditions in the 2025 permission.
2. Put terms where the offers are. Every discount, bundle or free eye test needs its conditions right next to the offer. Two clicks away does not count.
3. Strip the quotes. Any patient words you picked and published are testimonials under Section 133. The heading above them makes no difference.
4. Separate the clinic from the shop. Go page by page. Mark which sentences are about a health service and which are about a product. They answer to different watchdogs, so you need to word them differently.
5. Write the sign-off step down. Choose one named person and one checklist. Use them before anything goes live. That turns a lucky record into one you can defend.

Want the wider picture first? Start with the AHPRA advertising guidelines explained. To see the same split in another registered profession, read the podiatry rules.