Your pharmacy is the only AHPRA-regulated business that is also a shop. So you answer to three sets of ad rules at once. The National Law covers your service. The Therapeutic Goods Act and Advertising Code cover every product on your shelf. State medicines law sits under both. On 10 September 2026 we ran the AHPRA term register across 20 live Australian pharmacy websites. A clear-cut flag showed up in 8.4% of their sentences. Clinic pages we checked the day before ran at 7.7%. The bigger finding is what pharmacies have learned and what they have not. None of the 20 named a prescription brand on its main page. Yet 6 of the 20 named prescription hormones in a compounding pitch. Under the TGA's rules, those are the same mistake.
Run your own practice? Then your website counts as advertising, and these rules apply to it. I write website copy for Australian health practices, to the ad rules for your profession. Tell me about your site on a free 30-minute call.
Why is a pharmacy the hardest AHPRA profession to advertise?
The habits that make a good shop are the ones the medicines law was written to stop.
A shop names what it sells. It shows the price. It tells you the item is in stock. It rewards you for coming back. If your pharmacy does those 4 things with the wrong products, you have just broken the Therapeutic Goods Act 4 times.
You also have to meet the National Law, the same law that covers a physio or a dentist. That is because your pharmacy is a health service under that law, and your pharmacists are registered. There were 42,941 of them in March 2026, on the Pharmacy Board's figures as reported by the Australian Journal of Pharmacy.
Here are the 3 sets of rules and what each one covers.
| Rulebook | Who enforces it | What it governs on a pharmacy website |
|---|---|---|
| National Law, s133 | AHPRA and the Pharmacy Board of Australia | Your pharmacy as a service. You cannot mislead. You cannot hide the terms of a deal. You cannot use testimonials. You cannot raise false hopes about treatment. The top penalty is $60,000 for a person and $120,000 for a company. |
| Therapeutic Goods Act 1989 and the Advertising Code 2021 | The TGA | Every medicine. You cannot advertise prescription (Schedule 4) medicines to the public. You can advertise pharmacist-only (Schedule 3) medicines, but only if they are in Appendix H of the Poisons Standard. You cannot advertise compounded medicines. Retail pharmacies may show price lists, but the rules are tight. |
| State and territory medicines law | Each health department | Scheduling and supply. Some states add their own ad limits. This post does not cover that layer in detail. |
The 5 parts of section 133 are set out in our AHPRA advertising guidelines explainer. The TGA layer is where your pharmacy is different. It is also where the fines have landed. Each time the TGA has acted against a pharmacy, the problem was the product. It was never the service.
What did we find on 20 live pharmacy websites?
We took one public page from each of 24 Australian pharmacy websites. Some were local chemists, some were compounding pharmacies and some were online. They were in Melbourne, Sydney, Brisbane and Adelaide. Three sites blocked us with a 403 error, and one showed an empty page. So we measured 20 pages.
We split each page into sentences of 5 words or more and took out repeats. Then we ran two checks over them. The first is the AHPRA term register we used on 21 clinic pages in yesterday's measurement of what a compliant rewrite changes. That means you can compare the two numbers directly. The second is a pharmacy list we wrote for this post. It looks for named prescription drugs, ads for compounded medicines, script prices, deals and boasts about pharmacists. Then we read every flagged sentence by hand.
| Measure | Pharmacy websites (10 Sep 2026) | Clinic pages (9 Sep 2026) |
|---|---|---|
| Pages measured | 20 | 21 |
| Qualifying sentences | 1,624 | 1,360 |
| Sentences with a clear-cut AHPRA flag | 136 (8.4%) | 105 (7.7%) |
| Median page | 8.0% | 6.8% |
| Worst page | 23.7% | 31.2% |
| Pages with zero clear-cut flags | 2 of 20 | 0 of 21 |
So pharmacy websites carry a little more of the clinic problem. Two of them carried none of it. The split by type of pharmacy is where it gets interesting.
Compounding pharmacies flagged at 10.1% of sentences. Community pharmacies flagged at 6.9%. There is a reason for the gap. A compounding pharmacy sells something nobody else can make. So its copy leans on words like specialised, expert and tailored. It also names what goes into the capsule. That second habit is the one the TGA has been fining.
Why is naming a hormone the same mistake as naming Ozempic?
This finding should change how you read your own homepage.
Zero of the 20 pages named a prescription brand. No page named Ozempic, Wegovy, Mounjaro or Viagra. None named any of the 13 brand and ingredient names we scanned for. Pharmacies have learned that lesson, and it is easy to see why. The TGA gave Myers Pharmacy an infringement notice of $18,780 for in-store signs advertising Ozempic. Your Solution Compounding Pharmacy agreed to a 3-year promise that a court can enforce. Its website had carried order forms for semaglutide and tirzepatide between 23 November 2023 and 20 June 2024. Every pharmacist in the country has read those headlines.
Even so, 6 of the 20 pages named prescription hormones. Five of the 8 compounding pharmacies did it. So did one community pharmacy with a compounding lab. The copy promoted bioidentical hormone replacement therapy and HRT troches and creams. Two pages listed the ingredients they compound: oestrogen, progesterone and testosterone.
Read the TGA's own words, from its guidance on compounded medicines:
"Advertising unapproved therapeutic goods to the public, including compounded medicines, is prohibited under subsections 42DL(12) and 42DLB(9) of the Act, unless the advertising is authorised or required by a government or government authority."
"While you cannot advertise compounded medicines to the public, you can advertise your compounding service... To ensure your health service advertisement is not an advertisement for therapeutic goods, avoid referring to specific products manufactured, supplied or used in the delivery of the service."
In plain words, you can promote your compounding service. You cannot name what you make. Oestrogen, progesterone and testosterone are Schedule 4 substances, which means prescription only. A compounded hormone cream is an unapproved product. So if you write we compound bioidentical oestrogen and progesterone, you are advertising a compounded prescription medicine. The same part of the Act that caught the Ozempic signs applies to you.
The TGA has already acted on this. It gave a Victorian pharmacist 12 infringement notices totalling $30,240. Its media release said the website ads were for prescription-only goods "such as peptides and hormones". The ads also mentioned serious conditions.
Your shop instinct says to name what you make, because that is what customers search for. The rule says to name the service and never the substance. On 6 of 20 pages, the shop instinct won.
One more detail matters if you still compound for weight loss. From 1 October 2024, pharmacists can no longer compound GLP-1 receptor agonist products such as semaglutide. That comes from the same TGA release on the enforceable undertaking. You cannot advertise a product you are no longer allowed to make.
What can a pharmacy say about prescribing, vaccines and compounding?
You can say more than most pharmacies think. The rule is simple. Your sentence must be about the service and never about the medicine. The TGA has published worked examples for the exact services pharmacies are adding. The table quotes them.
| Service | Non-compliant, per the TGA | Allowed, per the TGA |
|---|---|---|
| Pharmacist prescribing | "Our pharmacists can assess and prescribe treatment for urinary tract infections, so you can get the antibiotics you need without visiting a GP." The TGA says this sells the service as a way to get antibiotics. It "is likely to amount to unlawful advertising of prescription medicines to the public." | "Promoting the conditions and services that are within a pharmacy's scope of practice, without directly or indirectly referring to therapeutic goods, is unlikely to constitute advertising of therapeutic goods." So you can say UTI consultations with a pharmacist. Stop there. |
| Vaccinations | A poster reading "Brand X influenza vaccinations available here. Book an appointment within the next 2 weeks and receive a 10% discount." It names a trade name. | A TGA permission lets an approved provider say it offers influenza vaccines, COVID-19 vaccines or meningococcal vaccines. You cannot name brands, trade names or ingredients. You cannot claim the vaccine is safe or free of side effects. |
| Compounding | Any mention of a specific compounded product or its active ingredient. This includes order forms, ingredient lists and lines like "We compound bioidentical oestrogen." | The service itself. You compound to prescription. You can make capsules, creams and liquids. You work with the patient's prescriber. You can mention turnaround and delivery. |
| Scripts and stock | A notice that a named prescription medicine is in stock, with strengths and dosage. The TGA calls this promoting the supply of a specific prescription medicine. | General service offers. The TGA says "cheaper prescriptions" or "click and collect prescriptions" are fine. They only become a problem if they push one medicine or one type of medicine. |
| Pharmacist-only medicines (Schedule 3) | Any Schedule 3 substance that is not listed in Appendix H of the Poisons Standard. | Schedule 3 substances that are in Appendix H. Section 15 of the Advertising Code then asks you to show this line clearly: ASK YOUR PHARMACIST ABOUT THIS PRODUCT. |
Look at what the allowed column has in common. Every allowed line describes a service, a category or a form. Every banned line names a thing you can buy. That is the whole test. You can apply it to a page in an afternoon.
Which words trip the National Law on a pharmacy site?
The same words that trip it everywhere else. Pharmacies add one twist of their own.
| Word | Sentences (of 1,624) | Pages (of 20) |
|---|---|---|
| specialised / specialise / specialist | 42 | 13 |
| trusted / trust | 38 | 13 |
| expert | 32 | 9 |
| best | 20 | 10 |
| top | 8 | 4 |
| leading | 6 | 3 |
The pharmacy twist is the phrase our expert pharmacists. The scanner found expert, leading, best, top or specialist next to the word pharmacist or pharmacy on 8 of the 20 pages. We read all 10 sentences. One was about training students to become the best pharmacists they can be. That is not a claim about the business. So the real count is 7 of 20.
Section 133 of the National Law says health ads must not be "false, misleading or deceptive or likely to be misleading or deceptive". They must not "create an unreasonable expectation of beneficial treatment". In plain words, do not mislead and do not raise false hopes. Expert compares your pharmacist to others. But registration is already the qualification. The word adds nothing the register does not already say. It only adds a claim you would have to prove. So swap it for a fact. Say how many pharmacists are on shift. Say how long you have been open. Say what services you run.
Specialised is the compounding word. It appeared on 13 of 20 pages. On a page that also lists hormone ingredients, it causes 2 problems. Under the National Law, it is a boast you cannot prove. Under the medicines law, it also forms part of an ad for a compounded script drug. So one sentence can catch the eye of 2 regulators.
Do discounts, loyalty points and free checks break the rules?
Not on their own. They break the rules when the terms are missing or the product is scheduled, which means it is a controlled medicine.
Section 133(1)(b) of the National Law bans advertising that "offers a gift, discount or other inducement to attract a person to use the service or the business, unless the advertisement also states the terms and conditions of the offer". A loyalty program on retail lines is a deal with terms. State the terms, or link to them, and you meet the National Law.
The Advertising Code then draws 2 lines that only a pharmacy will ever hit.
- Section 25, samples. Your ad must not offer a sample of a product that contains a Schedule 2, 3, 4 or 8 substance. A sample "means any goods given for free". The Code's note adds that buy-one-get-one-free is not a sample, as long as the free goods are the same as the goods bought.
- Section 26, incentives. Your ad must not offer "any personal incentive or commission to a pharmacy assistant, or any retail salesperson who is not a health professional, in exchange for recommending or supplying the goods". So staff cannot get a reward for pushing a product.
Price is the third line. Part 9 of the Code lets you show the public prices for prescription medicines. It also covers pharmacist-only medicines outside Appendix H. But only a retail pharmacy, its agent or buying group, or a section 92 doctor may publish it. It must be a price list that follows the layout rules in section 33. It can never run on radio, TV, billboards or digital screens. This is the one place you may put a prescription medicine's name in front of the public. The rules even set the format, right down to alphabetical order.
The strongest line in our whole sample came from a banner group's homepage, in the middle of its rewards copy. It said points cannot be earned or redeemed on prescription purchases. Our scanner flagged it because it contains the word rewards. In fact, that sentence keeps the program safe under section 133(1)(b) and the Code. A scanner finds lines to check. A person makes the call.
Then there is the word free. One page offered a free sit-down with a pharmacist to review your medicines. That is a service, and no controlled medicine is involved. So the National Law applies here, and the Code does not. Free has to mean free, and the terms have to be there. If the review is paid for another way, say so.
What does the rewrite look like, line by line?
Each pattern below appeared on more than one of the 20 pages. The rewrites say more and claim less. Each one keeps you on the right side of both regulators.
| Before | After | Rule engaged |
|---|---|---|
| Our expert pharmacists ensure high-quality, personalised care. | Two registered pharmacists on every shift. Bring your medicines list and ask either of them. | s133(a) misleading claim. s133(d) false hopes about treatment. |
| We specialise in compounding bioidentical hormone replacement therapy tailored to your body's needs. | We compound medicines to your doctor's prescription, in strengths and forms that are not sold commercially. Capsules, creams and liquids. | TGA ban on advertising compounded medicines. s133(a). |
| Brand X flu vaccinations available here. Book within two weeks for 10% off. | Influenza vaccinations available. Book online or walk in. | Vaccine permission: no brand names. s133(b) terms of a deal. |
| Our pharmacists can prescribe for UTIs so you get the antibiotics you need without seeing a GP. | Pharmacist consultations for urinary tract infections. No appointment needed. | TGA ban on advertising prescription medicines, by hinting at one. |
| Many consider us a leading pharmacy in the area and a trusted choice. | Open seven days since [year]. Scripts, vaccinations and compounding under one roof. | s133(a), a comparison you cannot prove. |
| Earn rewards points on every purchase. | Earn rewards points on retail purchases. Points are not earned on prescriptions. Full terms here. | s133(b) terms of a deal. Code s25 and s26. |
None of the after lines is bland. Each one carries a fact a competitor would have to match. That is the trade a compliant rewrite makes. It is why compliant copy is not boring when you do it properly.
What can this measurement not tell you?
There are 5 limits, and they matter as much as the numbers.
- One page per site. We measured the page the site's own search result led to. That was usually the homepage or a services page. We did not scan product pages or online catalogues. That is where a pharmacy's product ads really live. So the true figure is likely higher than 8.4%, not lower.
- Keyword matching cannot see a photo. A term scanner cannot see a product photo of a prescription medicine. It also misses a before-and-after shot for a cream, or a patient quote that is not marked as one.
- We are not saying any page breaks the law. Section 133 turns on whether you can prove a claim. The TGA's tests depend on context. We flagged sentences. A regulator reads whole pages.
- The state layer is not covered. State and territory medicines law can add its own ad limits. Check yours.
- No pharmacy is named. We recorded the 24 domains in the measurement file so the count can be rerun. They appear nowhere else.
The scripts, the domain list and the result files sit in the site's code folder beside yesterday's clinic measurement. You can rebuild both counts from scratch. For the TGA side, start with our guide to the TGA Advertising Code and the rules on advertising prescription medicines. If you compound for weight loss, read whether you can advertise weight-loss medication in Australia.
Sources. The National Law for health practitioners, section 133, as scheduled to the Queensland Act. Therapeutic Goods (Therapeutic Goods Advertising Code) Instrument 2021, sections 15, 25, 26 and 31 to 33 (F2021L01661). TGA guidance: Manufacturing, supplying and advertising compounded medicines lawfully. Complying with the restrictions on advertising prescription medicines to the public. Advertising health services that involve therapeutic goods. Advertising price lists for pharmacy and prescription-only medicines. TGA media releases on Myers Pharmacy, Your Solution Compounding Pharmacy and the Armadale pharmacist. Australian Journal of Pharmacy, "Pharmacy by the numbers", 25 July 2026, citing Pharmacy Board March 2026 registration data. Our own measurement, 10 September 2026.
Frequently Asked Questions
Which advertising rules apply to a pharmacy in Australia?
Three sets apply at once. Section 133 of the National Law covers your pharmacy as a health service. AHPRA and the Pharmacy Board enforce it. The Therapeutic Goods Act 1989 and the Advertising Code 2021 cover every medicine on your shelf. The TGA enforces those. State and territory medicines laws sit under both. A clinic usually only has to think about the first.
Can a pharmacy advertise compounded medicines?
No. The TGA's guidance says you cannot advertise unapproved medicines to the public, including compounded ones, unless a government allows it. You can advertise your compounding service. But you must not mention the specific products you make, supply or use. If you name oestrogen, progesterone or testosterone in a compounding pitch, you are naming the product.
Can a pharmacy say it has Ozempic in stock?
No. The TGA's guidance gives that exact example. A pharmacy posts that a prescription diabetes medicine is in stock, with strengths and dosage. The TGA says this promotes the supply of a specific prescription medicine. In our sample of 20 pharmacy websites, none named a prescription brand on its main page. Pharmacies have learned that lesson.
Can a pharmacy advertise its pharmacist prescribing service?
Yes, if you promote the condition and the service and do not mention the medicine. The TGA's own example is a pharmacy that said its pharmacists can prescribe for urinary tract infections, so you can get the antibiotics you need without visiting a GP. The TGA says that is likely unlawful, because it sells the service as a way to get antibiotics. Promote the consultation. Leave the script out.
Can a pharmacy advertise flu vaccinations?
Yes, under a TGA permission. An approved vaccine provider may say it offers influenza, COVID-19 or meningococcal vaccines. Your ad must not name a brand, trade name or ingredient. It must not say or hint that the vaccine is safe or free of side effects. The TGA's example of what not to do is a poster naming a vaccine brand and offering 10% off for booking within 2 weeks.
Are loyalty points and discounts allowed on a pharmacy website?
On retail lines, yes, if you state the terms. Section 133 of the National Law bans a gift, discount or other deal unless the ad also states the terms and conditions. The Advertising Code adds 2 more limits. You cannot give samples of any Schedule 2, 3, 4 or 8 medicine. You cannot reward a pharmacy assistant for recommending a product. One banner group's homepage in our sample says rewards points cannot be earned on prescription purchases. That is the line done properly.
How much of a pharmacy website does a compliant rewrite change?
On our 20-site sample, 8.4% of sentences carried a clear-cut flag under the AHPRA term register. The 21 clinic pages we measured the day before ran at 7.7%. The median pharmacy page was 8.0%. Two pages had no clear-cut flags at all. Compounding pharmacies ran at 10.1% and community pharmacies at 6.9%. An All Clear Audit covers every page of your site. It quotes every flagged line with the rule it breaks and a suggested rewrite.
