Audiology Clinic Marketing: Selling a Device Without Selling a Cure

If you market a hearing clinic in Australia, 4 rulebooks apply to you at once: the TGA Advertising Code for the device, the HPCCB Code of Conduct for member audiologists, the Hearing Services Program's own ad rule, and consumer law for everyone. We read the homepage and hearing aids page of 30 Australian hearing clinic websites, half expecting cure claims. There were none, and the gap turned out to be one phrase. Of the 30, 18 described Program services or subsidised devices, and only 2 printed the wording the Program's rules require. Both were national chains.

Who regulates audiology marketing in Australia?

AHPRA does not regulate audiologists today. Audiology Australia says it plainly: "Currently Audiology in Australia is self-regulated". So for now, your profession sets its own rules.

That will change, but slowly. Trade press reported on a Health Ministers Meeting in Perth on 12 September 2025. The ministers confirmed that audiology would join the national scheme that AHPRA runs. Audiology Australia now expects the law changes to pass in late 2028. Registration will follow 24 to 36 months after that.

So for the next few years, 4 other rulebooks apply to your website.

We cover the wider TGA Code in the TGA Advertising Code in 2026.

One result surprises clinic owners. If you are a member audiologist, the testimonial ban already applies to you. Standard 8.2(c) of the Code of Conduct covers testimonials "about the clinical aspects of the hearing service, including regarding the efficacy of aids and devices". That rules out patient praise about your care, or about how well a hearing aid works. AHPRA's version for registered professions is set out in what you can actually publish.

What did we measure on 30 hearing clinic websites?

We searched for hearing clinics in 6 city groups and read 30 private provider sites. The mix was 25 independent clinics, 2 national chains, 2 medical-led practices and 1 not-for-profit.

On each site, we read the homepage and the hearing aids page, which made 60 pages. Before reading a word, we wrote down 5 guesses about what we would find. A simple word search picked out lines worth a closer look, and a person read every one in full.

Do hearing clinics sell a cure?

No. That was our first guess about what we would find, and I'm glad it was wrong.

The word search flagged 30 sentences on 15 sites for words like restore, cure and reverse. More than half weren't claims at all. My favourite false alarm was ear impression material, which "cures" while it sets.

What was left was mild stuff. No site claimed to cure hearing loss. Three sites used restore with no qualifier across 5 sentences, and always in the same way: the device restores clarity, or it restores access to sound.

And 6 sites went the other way, saying plainly that hearing aids do not restore natural hearing, or that tinnitus has no cure. I'd put a line like that on every hearing aids page, because it tells people what to expect before they walk in.

Clause 1.2(d) of the HPCCB Code of Conduct says members must "Not make claims to cure hearing loss and associated disorders." Section 9(3)(d) of the TGA Advertising Code bans a statement that "exaggerates, or is likely to exaggerate, the efficacy or performance of the goods". So you cannot overstate what a hearing aid does.

The ACCC has tested a softer claim in court. In its 2018 case against Oticon and Sonic, the court looked at 3 misleading claims. One said any user of the hearing aid "would no longer miss any conversations". The Federal Court ordered penalties totalling $2.5 million. Restore sits one step short of cure. If you use it, it is the first word to swap.

The Hearing Services Program rule 16 of 18 sites missed

If you only fix one thing on your site this week, make it this one.

The Program is large: the Department of Health reports that 834,048 Australians got Program support in 2024-25. In the same year, 446,226 hearing devices were fitted.

The Program's Voucher Instrument has an ad rule. Section 32(3) says a contracted service provider "must use the phrase ‘conditions apply under the Australian Government Hearing Services Program’ in any advertisement or statement published" by it. This applies when the ad mentions a service or device that voucher holders can get. So if you are a provider and your page mentions the Program, you need that exact phrase.

Of the 30 sites, 18 described Program services or subsidised devices in their main text. Very few of them printed the phrase the rules ask for.

Both sites with the exact phrase were national chains. None of the other 16 printed it.

Some of those clinics may not be contracted providers, and we did not check contracts. But 6 sites said on the page that they are an accredited or approved Program provider, and none of those 6 printed the phrase. That was the result that surprised me most.

A second rule matters for the word free. Section 32(4)(b) bans any claim that "suggests that fully subsidised hearing devices are provided free by the contracted service provider rather than by the Australian Government". So you cannot make it look like the free device comes from you. The fix for both rules is one sentence beside each Program mention, and it credits the Government.

Does a hearing aids page need a TGA mandatory statement?

In most cases it does. Section 20 of the TGA Advertising Code says what an ad for a medical device must carry. It needs the trade name, an accurate description and an accepted purpose. It also needs one of 2 statements. The statements are ALWAYS FOLLOW THE DIRECTIONS FOR USE, or ALWAYS READ THE LABEL AND FOLLOW THE DIRECTIONS FOR USE.

If your goods are only supplied through a health professional, section 16 asks for a different statement. It reads THIS PRODUCT IS NOT AVAILABLE FOR PURCHASE BY THE GENERAL PUBLIC.

Only 2 of the 30 hearing aids pages carried either statement. They were the same 2 national chains that printed the Program phrase.

There is one limit, because section 14 makes an exception for an ad that only shows the name, a picture, the price or where to buy it, with no health claim. We did not test each page against that exception. But if your page explains what hearing aids do for hearing loss, it is unlikely to fit.

What does independent mean on a hearing clinic website?

Our fourth guess was that most clinics would call themselves independent, and few would say what it means. We got the first half right. Of the 30 sites, 26 used independent, unbiased or a close variant.

The second half was wrong, and happily so. Of those 26, 20 said what it meant: no maker owns them, they take no sales commission, or they offer a range of brands because of it. Six sites left the word to do the work alone.

A loose claim like this carries real risk. In 2018, Australian Hearing paid penalties totalling $37,800 after the ACCC issued 3 infringement notices. One claim was that its Hearing Help service was "unbiased". In fact, Australian Hearing owned and ran Hearing Help.

In our sample, 9 sites used unbiased or impartial. If you use the word, name the fact behind it.

Can a clinic link hearing aids to dementia?

Our fifth guess held. Of the 30 sites, 8 mentioned dementia or cognitive decline. On 6 of them, it was a reason to treat hearing loss or wear hearing aids. On the other 2, it was a heading or a menu link.

We are not judging the research here. The rules ask you for 2 things, which are evidence and naming your source. HPCCB Standard 8 says members "must only make claims in advertising about their hearing services that are supported by acceptable evidence". Section 11(3) of the TGA Advertising Code covers ads that mention research. You must name the researcher, and the funder too if you know who paid.

Fear is its own problem. Section 9(2)(a) bans an ad that causes, or is likely to cause, "undue alarm, fear or distress". So do not use dementia to scare people into booking.

What did most sites leave out?

Your buyers check 2 things before they book. Most pages skipped both.

Price. Only 8 of the 30 sites printed any dollar figure for a hearing aid, either their own price or a market range. The Code of Conduct already expects you to give clients "information regarding the likely cost of the hearing services before providing these services or entering into any contract". A price range on your page starts that talk early. Price is also one of the first things people search, as what patients google before booking shows.

Credentials. Audiology Australia explains who can get government funding through Medicare, HSP and NDIS. It says "an audiologist is required to be an accredited member of a professional practitioner body (PPB), either Audiology Australia or the Australian College of Audiology." Only 8 of the 30 sites named that membership. Your funding depends on it, yet most pages kept it quiet. We found the same gap on general clinics in what patients read on a clinic's About page.

Incentives. Three sites offered a prize draw or a gift card for coming in or referring someone. Clause 8.3 of the Code of Conduct allows a gift or reward only where "the advertisement also states the terms and conditions of the offer". So if you run a promotion, put the full terms beside it.

What should an audiology clinic write instead?

Swap each claim for a fact your buyer can use.

Each row answers a question your buyer was already asking. You can see how I approach this work on the audiology clinics page. If you would rather hand the pages over, that is website copy.

What this measurement can't tell you

• We looked at a sample of 30 sites. It shows a pattern. It does not measure the whole industry.
• We read 2 pages per site. We did not see any separate Program page or fees page. Section 32(3) asks for the phrase where the page mentions the service, and that was on the pages we read.
• We read text only. We did not see images, video or review widgets that load by script.
• We did not check contracts. The provider count rests on what each site says about itself.
• This is not legal advice. The findings describe what the pages print.

You can find a short version of this study on the web story.

Method. We read 30 Australian hearing clinic websites. We fetched the homepage and hearing aids page of each on 14 September 2026. We fetched 2 corrected pages on 15 September 2026.

Sources.

• Audiology Australia, regulation for audiologists.
• Audiology Australia, regulation moves into active development.
• Hearing Practitioner News, 12 September 2025.
• HPCCB Code of Conduct for audiologists and audiometrists.
• Hearing Services Program (Voucher) Instrument 2019, section 32.
• TGA Advertising Code 2021, sections 9, 11, 14, 16 and 20.
• ACCC media release, 28 September 2018.
• ACCC media release, 1 November 2018.
• Department of Health, Hearing Services Program.

Related reading:

• The TGA Advertising Code in 2026: what your brand can and cannot say
• Patient testimonials and AHPRA: what you can actually publish
• What patients read on a clinic's About page before they book
• Website writing for audiology clinics
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