A healthcare copywriting brief has to carry the evidence, because the law wants it before the copy goes out. The Therapeutic Goods Advertising Code says an advertisement must only contain information that is substantiated by the advertiser prior to publication. We read 14 of the most widely used creative and content brief templates, 46,035 words in all. Two named a field for sourcing. None named a field for legal, regulatory or clinical review. That missing field is where most non-compliant clinic copy starts, and one document fixes it.
What does the law want you to hold before you publish?
Two rulebooks apply to a clinic website in Australia, and they want different things.
The first is the Health Practitioner Regulation National Law. Section 133 makes it an offence to advertise a regulated health service in a way that is false, misleading or deceptive, that offers a gift or discount without stating the terms, that uses testimonials about the service, that creates an unreasonable expectation of beneficial treatment, or that encourages the indiscriminate or unnecessary use of a service. Five limbs. The maximum penalty is $60,000 for an individual and $120,000 for a body corporate.
The second is the Therapeutic Goods Advertising Code. Section 8 is the one that should change how you brief. It says an advertisement must be accurate, balanced and not misleading, and must only contain information that is substantiated by the advertiser prior to publication or dissemination.
Read that last clause slowly. Not substantiated when somebody complains. Substantiated before it goes out. The evidence has to exist first.
Two more clauses matter for a brief. Section 9 says an advertisement must not represent goods as safe or without side effects, as effective in all cases or a guaranteed cure, or as infallible. Section 11 says that if an advertisement refers to scientific or clinical research, it must identify the researcher, identify the financial sponsor where the advertiser knows or ought to know it, and cite the research well enough for a consumer to go and read it.
So before a single line is written, somebody has to know which claims will appear, what backs each one, and who checked. That is a document. Most clinics do not have it.
What do standard brief templates actually ask for?
We wanted to know whether the standard tools even ask.
So we took the creative and content brief templates a clinic is most likely to reach for. The ones that rank, the ones from the big project tools, the ones handed to freelancers every day. Fourteen pages, 46,035 words of guidance on how to brief a writer.
They agree on a lot. Thirteen of the fourteen ask for a goal, an audience, a tone and a deliverable. Eleven ask for a timeline. Eight name somebody who approves the work. That is a sound brief for a mattress company.
Then we asked two narrower questions of each page.
Does it name a field for the evidence, source or citation behind a factual claim? And does it name a field for legal, regulatory, compliance or clinical review of the copy?
Two of the fourteen get close. HubSpot's content brief guidance has a section on sourcing, and suggests asking the writer for links to the sources they used. Uplift Content recommends supplying research links, because accuracy affects whether people believe you.
Both are about the writer finding sources. Neither is the advertiser holding evidence before publication, which is the thing section 8 asks for.
And not one of the fourteen has a line for who reviews the copy against a rule.
What did we measure, and how?
The method is plain enough to repeat, and plain enough to argue with.
We fetched each template page on 16 September 2026 and saved the raw HTML. Four of the first twelve URLs had moved and returned a 404 page. Those bodies are error chrome, not templates, so they were dropped and the current URLs fetched instead. Pages under 400 visible words were excluded as JavaScript shells. Two pages came from the Internet Archive because the live fetch was blocked. That left 14 pages.
Then a scanner counted two fixed term lists across every page. It returned 11 hits.
Then we read all 11 in context, because a scanner cannot read. Eight were wrong. Wordtune's "Proofreading tool" is a product in the navigation. Victorious's "AI citations" is a services menu. Three separate "Disclaimer" hits were footer links. Semrush's page describes people who write technical content, not anyone who reviews it against a rule.
That is a 72.7% false positive rate, which is why the number we publish is three and not eleven.
Method. 14 creative and content brief template pages, 46,035 visible words, fetched 16 September 2026. Two fetched via the Internet Archive. Legal text quoted from the Health Practitioner Regulation National Law as in force in Queensland, and from the Therapeutic Goods (Therapeutic Goods Advertising Code) Instrument 2021 on the Federal Register of Legislation.
One thing this test is not: a criticism of those templates. None of them claims to be a healthcare compliance document. They are general marketing tools, and they are good ones. The problem is that a clinic picks one up, fills it in honestly, hands it to a writer, and every party assumes somebody else is holding the evidence.
Why does a missing field turn into a penalty?
Because the missing field is exactly where the five limbs of section 133 bite.
Nobody writes "we guarantee a cure" on purpose. What happens is smaller. A practice manager fills in a brief that says the goal is more implant enquiries and the tone is warm and reassuring. A writer who has never read the National Law writes warm and reassuring copy. The copy says patients leave with their confidence back. Nobody lied. Nobody checked.
That line is now a representation about the outcome of a regulated health service, with no evidence behind it, published. Under section 8 of the Advertising Code the substantiation had to exist before publication. It never existed at all, because the brief never asked.
| The clause | What it needs someone to have decided | The brief field that carries it |
|---|---|---|
| National Law s133(1)(a). Not false, misleading or deceptive. | Every factual claim, and what backs it. | Claim and evidence table |
| s133(1)(b). No gift, discount or inducement without its terms. | Whether an offer appears, and the full terms if it does. | Offers and terms |
| s133(1)(c). No testimonials about the service. | Whether reviews, quotes or star ratings appear anywhere on the page. | Social proof, allowed and not |
| s133(1)(d). No unreasonable expectation of beneficial treatment. | What the copy may and may not promise about results. | Outcome language boundary |
| s133(1)(e). No encouraging unnecessary use. | How the call to action is phrased. | Call to action wording |
| Advertising Code s8(1)(b). Substantiated before publication. | That the evidence exists now, not later. | Evidence held, with date |
| Advertising Code s11(3). Research must be identified and cited. | Researcher, sponsor and a citation a reader can follow. | Research citations |
| National Law s133(3). A court may have regard to a Board guideline. | Which profession's Board guideline applies. | Practitioner and profession |
Eight rows. Eight fields. That is the whole brief.
What are the eight fields a healthcare brief needs?
Here it is, in the order it is easiest to fill in. Copy it into a document and keep it next to the standard brief you already use. It does not replace the audience, tone and deliverable sections. It sits under them.
- Practitioner and profession. Who is registered, under which National Board, and their registration number. This decides which Board guideline a court would look at under section 133(3).
- Claim and evidence table. One row per factual claim the page will make. Claim on the left, the evidence on the right, and the date it was checked. If a row has an empty right-hand cell, that claim does not go in the copy.
- Outcome language boundary. The specific words this page may use about results, and the words it may not. Write both lists. "Reduces the appearance of" is a different promise from "removes".
- Social proof, allowed and not. Section 133(1)(c) rules out testimonials about the regulated service. Decide in the brief what may appear instead: practitioner credentials, years in practice, membership of a college, a published outcome that you hold evidence for.
- Offers and terms. If a discount, bundle or free consultation appears, the full terms and conditions go in the brief, written out. Section 133(1)(b) needs them stated in the advertisement itself.
- Research citations. For anything drawn from a study: the researcher, the funder if you know it, and a link a patient could open. Section 11 of the Advertising Code asks for all three.
- Call to action wording. The exact words. "Book an assessment" and "Don't wait, spaces are limited" sit on opposite sides of section 133(1)(e).
- Reviewer and date. The named person who reads the copy against the rules before it goes live, and when they will do it. Not a team. A person.
None of these fields are difficult. Seven of the eight can be filled in by the practice manager in twenty minutes. The eighth takes a decision about who is accountable, which is why it is usually the one left blank.
What does each field stop from going wrong?
The point of a field is that it forces a decision early, when changing your mind is free.
The claim and evidence table is the one that pays for itself. A clinic sits down to fill it in and discovers that three of the seven things it has been saying for two years have nothing behind them. That discovery costs nothing on a Tuesday morning. It costs a great deal if it arrives in a letter.
The outcome language boundary stops the most common rewrite we see. Copy comes back warm, confident and unusable, and everybody blames the writer. The writer was never told where the line was, because the brief said the tone should be reassuring and said nothing else.
The social proof field stops the second most common one. A clinic hands over a folder of glowing reviews as "supporting material", the writer weaves them in, and the whole page has to come down.
The reviewer field stops the failure that is hardest to undo, which is nobody reading the copy against a rule at all. A brief that names a reviewer and a date turns compliance from a vague shared intention into a task with an owner. That is the entire trick.
Who signs the brief off, and when?
Sign-off has to happen twice, and the brief is the first time.
The first sign-off is on the brief itself, before writing starts. The practitioner confirms the claim and evidence table is true and that the evidence named is evidence they actually hold. This is the step that satisfies "substantiated by the advertiser prior to publication", and it is the step almost nobody does, because the standard template has nowhere to record it.
The second is on the finished copy, before it goes live. Same named person. They are not checking whether the writing is good. They are checking each line against the eight fields they already approved.
If the same person cannot do both, say so in the brief and name two people. What does not work is "marketing will check it", because marketing is not a person and cannot be asked what they relied on.
A practical note on timing. Put the reviewer's date in the brief, not in a calendar invite. A brief that says review by 24 September gets reviewed. A brief that says review before launch gets reviewed at 6pm on launch day, by whoever is still online.
What does this look like on a real page?
Take a single sentence that appears on hundreds of Australian clinic pages: our treatment restores your natural smile.
Run it through the eight fields and it stops being an argument about taste.
Field 2 asks what evidence supports "restores". There is a real answer for some procedures and no answer for others, and the brief makes you say which. Field 3 asks whether "restores" is inside the outcome boundary for this profession, which is a question for the practitioner, not the writer. Field 7 asks how the page then asks for the booking.
By the time the three cells are filled in, the sentence has usually become something more specific and more persuasive. That is the part clinics do not expect. The compliant line is often the better line, because a vague promise is what you write when you have not decided what you can prove.
We measured what a compliant rewrite actually touches in an earlier piece on rewriting a clinic page, and it is a smaller share of the page than most people fear.
What does this measurement not show?
Three limits, stated plainly.
It measures published guidance pages, not the private brief documents clinics actually send. Some clinics certainly do brief evidence well, and a template page is not a survey of practice. What the count shows is that the widely available guidance offers no prompt to do it.
It is a term count with a hand read, not a semantic reading. A template could imply evidence gathering without using any of the words we searched for. We read every hit in context to strip false positives, but we did not read all 46,035 words line by line, so a buried prompt could have been missed.
And the legal text here is general information about advertising rules, not legal advice about your practice. Section 133 is quoted from the National Law as in force in Queensland, which is the version most easily readable in full. The Advertising Code applies to therapeutic goods, so how much of it touches your page depends on what you sell and say. If a specific claim is close to a line, get advice on that claim.
What should you do before the next job?
Do one thing, and do it before the next piece of copy is commissioned.
Open the last page you published. Write down every factual claim on it, one per line. Next to each, write what backs it and the date you checked. Leave the cell blank where nothing does.
The blank cells are your brief. They are also, right now, live on your website.
That exercise takes about half an hour and tells you more about your compliance position than any audit summary will. Once it is done, the eight fields above turn it into a document you can hand to a writer, and the next piece of copy comes back right the first time.
Related reading:
- How to hire a compliance-first copywriter in Australia
- What a compliant website rewrite actually changes
- AHPRA advertising guidelines, explained for clinics
- The TGA Advertising Code, in plain English
- What non-compliant healthcare marketing actually costs
- Freelance healthcare copywriter or agency?
- View all services →
