Yes. AHPRA's advertising rules apply to your clinic's social media in the same way they apply to your website. Instagram, Facebook, TikTok and LinkedIn all count as advertising once a post promotes your health service. The slips clinics make most often are patient reviews and comments on pages they control, before-and-after photos, paid influencers, and naming prescription-only medicines. Section 133 of the National Law carries penalties up to $60,000 for a person and $120,000 for a company, per offence. Here is what breaks the AHPRA social media guidelines, and how you fix each one.
Do AHPRA's advertising rules apply to social media?
Yes, and this is where most clinics get caught. Many people quietly assume AHPRA's rules cover only your website and printed ads. They treat social media as a casual, personal space where the rules relax. The rules do not relax there.
The main rule book is AHPRA's “Guidelines for advertising a regulated health service”. They have been in force since 14 December 2020. They apply to advertising "in any form," and AHPRA lists social media as one of those forms. AHPRA also has separate social media guidance, and it is blunt. It says the National Law, your Board's code of conduct and the ad guidelines all apply to your social media "just as when you interact in person."
It does not matter where the post sits. It could be on your clinic's business account or a practitioner's personal profile. If the post promotes your health service, the ad rules apply to it. The platform changes, but the law stays the same.
What does Section 133 actually ban?
Every social media rule below goes back to one section of the law. That is Section 133 of the National Law, the law that governs registered health practitioners. It makes it an offence to advertise a health service in a way that:
- is false, misleading or deceptive, or likely to be;
- offers a gift, discount or other inducement without stating the terms and conditions;
- uses testimonials or “purported testimonials” about the service or business;
- creates an unreasonable expectation of beneficial treatment; or
- encourages the indiscriminate or unnecessary use of “regulated health services”.
In plain words, you cannot mislead people. You cannot offer a deal without the fine print. You cannot use patient reviews, real or made up. You cannot raise false hopes, and you cannot push people to book care they do not need. Those 5 parts are the whole game. A glowing patient comment about their results is a testimonial. A dramatic before-and-after raises false hopes. "Book now, only two spots left" pushes people to book. Social media just makes each one easier to do by accident.
The penalties are real. Breaking Section 133 is a criminal offence. The top penalty went up to $60,000 for a person and $120,000 for a company, per offence. It used to be $5,000 and $10,000. Each state and territory sets the penalty in its own version of the National Law, so check the current figure where you are. A breach can also count as unsatisfactory professional conduct. That puts a practitioner's registration at risk. For the full picture of what the rules cover, see my guide to the AHPRA advertising guidelines for 2026.
Are reviews and comments on your own pages a problem?
Yes, and this rule confuses more people than any other. So read it slowly.
You cannot use a testimonial about clinical care in your ads. On a social page or profile you control, comments and reviews count as part of your ads. That makes you responsible for them. Say your clinic's Facebook page has reviews switched on. Or say a patient comments "Dr X fixed my back pain, life-changing" under your post. That comment now sits inside your ads. AHPRA says you may need to switch off reviews. You may also need to hide or remove comments that describe clinical care.
Here is the part that saves clinics a lot of worry. AHPRA has said you are not expected to police reviews you did not ask for on sites you do not control. Google reviews are the usual example. You did not invite them and you cannot switch them off. So they do not count as your ads. The line is control. The review function on your own page is your job. An independent review site generally is not.
So you do not need to beg patients to stop being nice. Switch off review functions on the pages you control. Then keep an eye on comments under your own posts. I go deeper on testimonials in what you can actually publish under the AHPRA testimonial rules.
What about before-and-after photos, shares and reposts?
Before-and-after posts are everywhere on clinic Instagram, and they are risky. These photos easily break Section 133. They can raise false hopes. They also become misleading the moment you add a filter or a flattering angle. AHPRA's rules say these photos must not be edited, airbrushed or filtered. They must show typical results, with the right context. Most posts fail that test straight away.
The 2025 cosmetic procedure guidelines went further for cosmetic clinics. They have been in force since 2 September 2025. Before-and-after photos of under-18s are banned outright. Digital touch-ups of ad images are limited too. If you run a cosmetic account, the bar is now much higher than a nice grid. I break down the rules in before-and-after photos under AHPRA.
Sharing and reposting count too. Say a patient posts praise for their clinical result, and you share or repost it. You have now made that testimonial your own ad, and you are responsible for it. Reposting a happy patient's story does not get you around the rule. It simply means you publish the testimonial yourself.
Can your clinic use influencers or paid partnerships?
Only with care, and for cosmetic clinics, mostly no. One rule applies to every health service. You are responsible for content that someone else makes for you. If an agency or an influencer makes a claim about your service, that claim counts as your ad. Handing your account to a marketing team does not hand over the risk. That is the trap I describe in what happens when a marketing agency meets AHPRA compliance.
For cosmetic procedures, the 2025 guidelines are even stricter. You cannot use influencer testimonials to advertise them. You also cannot pay for posts, and that includes free or cheap procedures in return for a post. The old "we gave the influencer a free treatment and she posted about it" deal is now clearly banned for cosmetic clinics.
Other services have a rule too. An influencer saying a treatment fixed their symptoms is still a testimonial about clinical care. It still breaks the rule. Safe influencer posts talk about the practitioner, the process and the practical details. They never talk about the clinical result.
The social posts that breach the rules, and the fix
Here is the pattern in one view. The left column shows an everyday clinic post. The middle column shows the rule it breaks. The right column shows a safe version that does the same job without the risk.
Here are 6 everyday clinic posts, and the rule each one breaks. The offences are set out in the National Law. AHPRA enforces them, and the TGA enforces the rules on prescription medicine ads.
None of this means your clinic has to go quiet. The safe version of each post is more specific and more useful than the one it replaces. I make the same point for websites in what your clinic can actually post under the TGA rules. It pairs well with this piece.
How do you make your clinic's social media compliant?
You do not need a lawyer on call to get most of the way there. You need to run one honest check and fix the obvious problems. Here is a working checklist.
1. Turn off review functions on pages you control
Switch off the reviews tab on your Facebook page. You are responsible for testimonials there, so the simplest fix is to remove the function. Leave independent sites you cannot control, like Google, alone.
2. Moderate the comments under your own posts
Set a routine. When a patient comments about their treatment results, hide or remove that comment. You are still grateful. But that comment is now an ad you are responsible for.
3. Retire the before-and-after grid
Swap result photos for process posts. Show the room, the equipment, the steps and the team. These posts follow the rules. They are also what nervous patients want to see before they book.
4. Strip the superlatives and the urgency
Search your own captions for "best," "safest," "painless," "guaranteed" and "spots left." Each one is a rule waiting to be enforced. Swap them for plain facts.
5. Never name the prescription product
Talk about the consultation, the check-up and the practitioner. Do not name Schedule 4 (prescription-only) medicines to the public. The TGA takes this one very seriously, and it enforces it hard.
6. Put your agency and influencers on a written brief
You carry the risk for what they post. So your brief has to spell out the rules. That means no testimonials, no claims about results, no boasts and no product names. Get it in writing.
The rules are enforced, and not gently. In one recorded case, a NSW practitioner pleaded guilty to 30 charges of unlawful advertising, including using testimonials. The practitioner was fined $45,000 plus costs in the Downing Centre Local Court in October 2018. AHPRA said it reached its 100th criminal ad prosecution in May 2023. Social media raises that risk. Posts are public and fast, and anyone can screenshot them.
Following the rules does not mean going silent. You can still be useful, easy to find and clear, within rules that exist to protect patients. Get the check right once and build the habits. Then your social media stops being a risk and starts working for you.
This article is general information for education, not legal advice. For a ruling on a specific post, page or account, ask a lawyer who knows health advertising law. You can also check AHPRA's advertising hub directly.
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