The TGA advertising code applies to your clinic's social media. A post on Instagram, Facebook, or TikTok is an advertisement if it promotes the use or supply of a therapeutic good. You cannot name prescription medicines, run patient testimonials about treatment, or make outcome claims, even in a caption or a reel. You can post factual content about your consultation, your team, your hours, and how to book. You are also responsible for the comments on your own posts, so a follower's testimonial or product mention has to be removed. The advertiser is liable, which includes the clinic and the person who runs the account.
Key takeaways
- Social media counts as advertising. There is no organic or educational exemption.
- You cannot name a prescription medicine, run treatment testimonials, or promise outcomes in any post.
- You can post factual content about the consultation, the team, and how to book.
- You own your comments section. A follower's testimonial or product mention has to be hidden or removed.
- The advertiser is liable. That includes the clinic and the person managing the account, not only the doctor.
Do the TGA rules apply to social media?
Yes. This is the part most clinic marketers get wrong, so let me make it plain. The TGA advertising code applies to social media in the same way it applies to your website.
The code is the Therapeutic Goods Advertising Code 2021. It sits under the Therapeutic Goods Act 1989 and is run by the Therapeutic Goods Administration (TGA). An advertisement is anything that promotes the use or supply of a therapeutic good. That definition does not care about the channel.
So a caption, a reel, a story, a carousel, a pinned comment, and a paid ad are all advertising if they promote a product. The TGA has published specific guidance on advertising therapeutic goods on social media, so this is not a grey area. There is no "we were just educating people" exemption, and there is no "it was only an organic post" exemption.
The core idea: if a post promotes the use or supply of a medicine, device, or supplement, it is an ad. The platform does not change that. Instagram, Facebook, and TikTok all sit under the same rules.
What can your clinic actually post?
The code limits your claims, not your right to show up. You can run a strong, active account that brings in real enquiries. Here is what stays on the safe side.
- The consultation. You can post that your clinic offers appointments to discuss health concerns, who provides them, and what happens at a visit. A service is not a therapeutic good, so the goods rules do not catch it, as long as the post does not name or hint at a prescription medicine.
- Your team and your practice. Introduce a clinician by name and qualification. Show the rooms. Share opening hours, location, and how to book.
- General health education. You can talk about a health topic in plain terms, as long as the post does not promote a specific product or point readers toward getting one.
- Behind the scenes and culture. Team days, community work, and clinic news are all fine, because none of it promotes a product.
Notice the pattern. Every safe post is about the service and the people, not the substance or the result. If your content calendar is built around the consultation, most of your compliance risk disappears before you ever hit publish.
What can your clinic never post?
This is the list that turns a normal account into a breach. None of these are allowed, on any platform, in any format.
- The name of a prescription medicine. You cannot advertise prescription-only (Schedule 4) or Schedule 8 medicines to the public. That covers the brand name, the active ingredient, a nickname, and a hashtag. My post on advertising prescription medicines in Australia walks through this rule in full.
- Testimonials about clinical care. A patient quote about symptoms, treatment, or results is banned, even when a happy follower posts it for free.
- Before-and-after content. Side-by-side images, transformation reels, and result-led carousels are all out.
- Outcome promises. No "you will feel better", no timelines, no superlatives like "best" or "leading", and no claim that a product treats a serious condition.
- Urgency and inducements. No "limited spots", no countdowns, no "book this week and save". These push the public toward a product and breach the code.
If a post does any of these, it is a risk, whatever the disclaimer in the bio says. A "general information only" line in your profile does not cure a non-compliant caption.
Are you responsible for comments and DMs?
Yes, and this is the trap that catches careful clinics. You are responsible for content on a page you control. That includes the comments on your own posts.
The reasoning is simple. The TGA and AHPRA treat the page owner as the advertiser for content on a page they manage. If a follower drops a comment that names a prescription product, or writes a glowing testimonial about their treatment, that comment now sits on your advertising. Leaving it up can be treated as the clinic advertising the product.
So you need a routine. Check your comments. Hide or delete any comment that names a prescription medicine or tells a clinical story. Reply to the person off the post if you want to help them book. You cannot control what a stranger types, but you can control what stays visible on your page.
Direct messages are private, so they are not advertising in the same way. The caution there is different. Do not use a DM to do what you cannot do in public, like naming a product or promising a result. The platform changes, the rules do not.
Quick routine: build a weekly check of every post's comments. Hide product names and treatment testimonials on sight. Keep a short note of what you removed, so you can show you were active if a regulator ever asks.
What about testimonials and tagged posts?
This is where social media gets its own special headache. A testimonial about clinical care is banned under the AHPRA advertising guidelines, and the ban follows the content wherever it lives.
That means all of the following count as a testimonial you cannot use:
- A patient review you reshare to your story or feed.
- A post a happy patient tags you in, if you then share, pin, or feature it.
- A reel where a patient talks about their symptoms or results.
- An influencer or creator post you arranged, because a post you organise is your advertising.
The line sits at clinical content. A review that only mentions the booking, the staff, or the facility, with no reference to symptoms, treatment, or outcomes, is a service-experience review and is generally fine. The moment the review touches care, it is a testimonial you cannot publish.
One more catch. If a patient tags you in a result post and you do nothing, you are usually safer than if you reshare it. Sharing it makes it yours. So the rule with tagged content is to leave the genuine ones where they are and never amplify a clinical story.
Say this, not that: five social rewrites
Here are five common social posts that breach the code, each with a compliant version. Every "say this" line is written to the full standard, so it works for the TGA and for AHPRA at the same time.
| Not this (breach) | Say this (compliant) | Why it works |
|---|---|---|
| "Our weight-loss injection clients are loving their results. DM us to start." | "We offer weight management consultations. Tap the link in our bio to book an appointment." | Advertises the consultation. Names no product, shows no result, and uses no testimonial. |
| "'Best decision I ever made.' Swipe to see her transformation." (patient reel) | "Meet Dr Lee, who runs our skin consultations. Here is what happens at your first visit." | No testimonial and no before-and-after. Introduces the clinician and the service. |
| "Only 3 spots left this week for our anti-wrinkle treatment. Book fast." | "Book a consultation to talk through facial treatment options with our team." | No urgency, no class reference, no outcome. Frames it as a professional service. |
| A comment reads "Did [prescription product] work for you?" left on the post. | Hide the comment, then reply: "Great question. Book a consultation and our doctor can talk you through your options." | Removes the product name from your advertising and points to the consultation. |
| "Tag a friend who needs this! Natural relief that actually works." (giveaway) | "We are open for new appointments this month. Book online or call the clinic." | No inducement, no vague product hint, no outcome promise. Factual and service-led. |
Who is liable when a post breaches the code?
Breaching the code on social media carries the same weight as breaching it anywhere else. The TGA can issue warnings and infringement notices, and it can take court action. As of 2026, a single infringement notice for unlawful advertising can run to tens of thousands of dollars per breach, and court penalties for serious or repeated offences reach into the millions. The TGA publishes the figures in its guidance on what can and cannot be advertised.
The detail that matters for a marketer is who is liable. The advertiser is responsible, and the law reads "advertiser" broadly. That includes the agency and the person who writes and schedules the posts, not only the clinic that owns the account. If you run the account, you carry the risk with the client.
For a registered practitioner, there is a second door. A breach can also become a complaint to AHPRA, which can affect their registration. One non-compliant reel can trigger two separate problems at once. For more on how the two systems overlap, my guide to the TGA advertising code in 2026 covers the full picture.
The fix is not to go quiet. It is to build your social plan around the consultation from the first draft, run a weekly comment check, and never reshare a clinical story. Done that way, your account stays active, ranks, and brings in patients, without ever putting the client or yourself at risk.
