There is no new AHPRA enforcement strategy for 2026. The written strategy dates from December 2020. What changed is what AHPRA does with it. In 2024/25 its advertising team assessed 775 complaints. Of the registered practitioners it wrote to, 74% fixed their advertising early. Only 8 ended up with conditions on their registration. The harder path, referral to the Criminal Offences Unit, took 356 matters, mostly about companies and unregistered people. AHPRA also trialled AI to scan websites for breaches. So the question is no longer whether a patient complains. It is what a scan finds.
Is there an AHPRA enforcement strategy for 2026?
No. There is one strategy paper, and it is old.
AHPRA's advertising compliance and enforcement strategy took effect on 14 December 2020. It has not been rewritten since. It still prints the old penalty figures. We covered that quirk in our post on what happens after an AHPRA advertising complaint, which walks through the letter, the 30 days and the steps after that.
So if you have seen a headline about a "2026 crackdown", be careful. The rules did not change. The paper did not change.
What did change is the practice. And the practice is counted. Each year AHPRA tables an annual report in state parliaments. The 2024/25 report covers the year to 30 June 2025. It gives the real numbers: how many complaints, how many letters, how many audits, how many conditions, how many court cases.
That report is the nearest thing to a live enforcement strategy. This post reads it for you.
How many advertising complaints did AHPRA handle in 2024/25?
775. That is the number the annual report gives for complaints its advertising team assessed in the year.
The split inside that number is the whole story.
419 were "lower-risk complaints about registered health practitioners". Those went down the soft path. A letter, a chance to fix it, and in most cases nothing more.
356 were "complaints about corporate entities or unregistered persons, or assessed as serious-risk complaints". Those went to AHPRA's Criminal Offences Unit. Of them, 107 were about the advertising of regulated health services. The rest were about specialist title use, or people posing as registered practitioners.
Source: Ahpra and the National Boards annual report 2024/25, pages 50, 51 and 84. Bars are drawn to scale against 775, in a single unit, number of matters. The 86 and the 8 come from the registered practitioner path. The 107 sits inside the 356.
Read the bottom two bars again. Of 775 complaints, 8 people ended the year with conditions on their registration because of their advertising. Three more were cautioned.
That is not a soft regulator. It is a regulator that says, in its own words, "In most cases we take an educative approach to achieve compliance quickly." The numbers show it means it.
What happens to a registered practitioner who gets flagged?
A letter, then a check, then conditions if you ignore both.
The report says it plainly. When AHPRA finds a registered practitioner's advertising is non-compliant, "we provide them with information about where they have fallen short, along with an opportunity to correct it. We generally only take further regulatory action when this approach is unsuccessful."
Then it gives the rate. "Of the practitioners we contacted because of non-compliant advertising, 74% corrected their advertising early, such that further intervention was not required."
The other 26% got audited. AHPRA "audited 86 practitioners whose advertising remained non-compliant after being given an opportunity to correct it. Of these, 75 subsequently corrected their advertising."
That leaves 11. National Boards acted on them. 8 had conditions put on their registration. 3 were cautioned.
So the shape of it, for a registered person, is this. You get a letter. If you fix it, it ends. If you do not, you get audited. If you still do not, a condition goes on your registration and limits how you can advertise.
The 8 people with conditions were not the ones with the worst copy. They were the ones who did not fix it after being asked twice. In this system the breach is rarely what hurts you. Ignoring the letter is.
Why do companies go through a different door?
Because a company has no registration to put a condition on.
Every lever in the section above works on a registered person. A letter carries weight because the next step is a condition on their registration. A company that trades a clinic is not registered with anyone. Neither is a marketing agency. So AHPRA cannot condition them. Its remaining tool is a court case.
That is why the report sends "complaints about corporate entities or unregistered persons" straight to the Criminal Offences Unit, along with the serious-risk matters. It is not a view that companies are worse. It is that the soft ladder does not reach them.
The unit's own figures for 2024/25 show where its time went.
- 474 criminal offence complaints came in across all offence types, a 13.3% decrease on the year before.
- 107 new complaints about advertising were considered. Most related to "the advertising of corporate entities or unregistered persons". That was a 23.6% decrease on the year before.
- 77 advertising complaints were closed during the year.
- Of the offence complaints still open at 30 June, 61.0% were title protection offences and 36.0% were "advertising offences by corporate entities or unregistered persons".
- 15 court cases were completed. 14 ended in a finding of guilt. One ended in a finding of not guilty after a trial. 12 more were still running at 30 June.
Two honest caveats. The report does not say how many of the 15 cases were about advertising. Its own examples lean on fake practitioners and people who kept working while suspended. And fewer complaints coming in is not less enforcement. It is fewer people writing in.
The top penalties have not changed. The report states them: up to three years' imprisonment and/or a $60,000 fine for an individual, and a fine of up to $120,000 for a company. Those are the figures in section 133 of the Health Practitioner Regulation National Law. They are the maximum per offence. The 2024/25 outcomes above are what the year actually produced.
For a practice owner the lesson is about structure. Who is named as the advertiser on your site decides which door a complaint goes through. If the page reads as the practitioner's advertising, the letter path applies. If it reads as the trading company's, or an agency wrote and approved it, the company path applies. We cover how the advertiser is identified in who is liable when a marketing agency writes your copy.
Which professions drew the most advertising offence complaints?
Medicine, by a distance. Then nursing.
Table 29 of the report breaks the 107 advertising offence complaints down by profession. These are the ones that reached the Criminal Offences Unit under section 133. So they are the serious end, not the letter end. The six largest are below.
| Profession | Section 133 advertising complaints received | Share of the 107 |
|---|---|---|
| Medical practitioner. | 68. | 63.6%. |
| Nurse. | 13. | 12.1%. |
| Psychologist. | 6. | 5.6%. |
| Occupational therapist. | 5. | 4.7%. |
| Physiotherapist. | 4. | 3.7%. |
| Dental practitioner. | 4. | 3.7%. |
The table counts the profession attached to the complaint. That includes companies and unregistered people selling that profession's services. So the medical figure is not 68 doctors in trouble. It is 68 matters where a medical service was advertised in a way someone thought was unlawful, and the matter was serious or corporate enough to be referred.
The year before, the same table recorded 140 received and 88 closed. In 2024/25 it was 107 and 77. Fewer went in.
What changed in 2025, and what is coming?
Three things, and only one of them was announced.
The cosmetic guidelines. AHPRA published advance copies of the Guidelines for advertising higher risk non-surgical cosmetic procedures in June 2025, ahead of their start in September 2025. In the same year it assessed 59 complaints about cosmetic procedure advertising. Its targeted audit of cosmetic surgery advertising "assessed advertising for 93 practitioners and health services". If you run a cosmetic clinic, you are inside a named focus area. Our AHPRA guide for cosmetic clinics covers the rules themselves.
The website that helped cancel a registration. The report describes a June tribunal decision in Queensland that cancelled a doctor's registration after a cosmetic procedure went badly wrong. Among the findings: "the clinic website gave misleading information about his credentials". The website was not the whole case. It was part of it. That is worth sitting with, because a credentials page is the page most clinics never review.
The AI trial. This is the one that matters for every clinic, and it is one sentence in the CEO's introduction. AHPRA has "trialled the use of artificial intelligence to scan social media and websites for advertising breaches".
Everything in the ladder above starts with a complaint. Someone has to write in. A scan changes that. A scan does not need an unhappy patient or a rival with a grudge. It reads the page.
The report calls it a trial and gives no numbers. Do not expect a wave of letters tomorrow. But the direction is clear. The regulator has started looking for breaches without waiting to be told.
What does risk-based enforcement mean for your website?
It means your website is the evidence, and a scan reads all of it at once.
Risk-based enforcement sorts matters by the harm they could do and by the advertiser's history. Low risk plus a quick fix ends in a closed file. High risk, or a company, or a repeat, ends in the Criminal Offences Unit. So the goal is not zero mistakes. It is to never be the practice that leaves a known breach live.
Five things follow from that.
Fix the whole pattern, not the flagged page. AHPRA checks by audit. 86 people were audited in 2024/25 because their advertising "remained non-compliant" after a letter. If the same claim lives on six pages and you fix one, the audit finds the other five.
Treat the letter as the whole game. 74% of those who fixed early never heard from AHPRA again on that matter. The 8 with conditions are the ones who did not.
Know whose advertising it is. If your trading company or your agency is the advertiser, the soft ladder may not apply. That is a reason to get the copy right before it goes live, because the letter-and-30-days safety net is thinner for a company.
Review the pages a scan would read first. Credentials, testimonials, before and after galleries, discounts and anything that promises a result. Those are the section 133 categories, and they are what a scanner is built to look for. What sets off a review is explained in why your website got flagged.
Write the compliant version, not the blank version. Most flagged lines can be replaced with something factual that still sells the practice. The table below shows the swaps that come up most.
| Line that draws a letter | Why it is a problem | What to publish instead |
|---|---|---|
| "Our patients say the results are life changing." | A testimonial about clinical care, which section 133 bans outright. | "Your first appointment covers your history, your goals and what the treatment involves." |
| "Safe, painless and guaranteed." | Creates an unreasonable expectation of benefit. No procedure is risk free. | "We explain the risks, the expected recovery and the alternatives before you decide." |
| "Dr Lee, cosmetic surgeon." | Section 115A says a medical practitioner who is not a member of a surgical class must not take or use the title "surgeon". | "Dr Lee, medical practitioner. AHPRA registration number shown on the team page." |
| "20% off all treatments this month." | A discount with no terms is a breach on its own. | "Fees are listed on the pricing page. Any offer states its conditions and end date." |
| "Before and after: see the transformation." | An image that shows a result is a claim about outcomes, and it must not create an unreasonable expectation of benefit. | "A description of what the procedure involves, how long it takes and what recovery looks like." |
Every line in the right-hand column is held to the same standard as client copy. None uses a testimonial, promises an outcome, or implies a registration the person does not hold. They are also better marketing. A patient wants to know what happens in the room, and that page can be written fully within the rules.
The short version
The strategy paper is from 2020. The 2024/25 numbers are the strategy in practice. 775 complaints. 74% fixed after a letter. 86 audited. 8 conditions. 356 matters sent to the Criminal Offences Unit, mostly companies and unregistered people. And a trial of AI that reads websites for breaches without waiting for a complaint.
So the practice that gets hurt is not the one with a mistake on its site. It is the one that leaves the mistake up. Read your own pages the way a scan would. Then fix all of them, not one.
The full set of rules is in our AHPRA advertising guidelines guide for 2026.
This article summarises figures published in the Ahpra and the National Boards annual report 2024/25, as tabled in the Queensland Parliament. It is general information, not legal advice. If you have received a letter from AHPRA, get advice from your professional indemnity insurer or a health law practitioner.