Aged care marketing compliance

The new Act never says advertising. Not once.

The Aged Care Act 2024 started on 1 November 2025. Its full text never uses the word advertising, or the word marketing. That silence is not permission.

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The count

Zero, in a law that replaced three others

I ran a word count over the full text as it commenced. Registered provider appears 1,091 times. Information 620. Complaint 288. Rights 107. Advertising appears 0 times. So does marketing.

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What it does police

Misleading appears 26 times, and none of it is about you and a family

Every one of those provisions is about information you give the regulator. Sections 529 and 530 set civil penalties for false or misleading information and documents. Section 129(1)(b) lets the Commissioner suspend your registration over a false registration application.

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The handover

Three regulators the Act never names

The Australian Consumer Law. Section 133 of the National Law, through AHPRA. And the Aged Care Quality and Safety Commission, reaching your marketing through your registration conditions rather than any advertising rule.

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The precedent

$6 million, for a features list

On 12 May 2020 the Federal Court ordered $6 million in penalties against Bupa Aged Care Australia Pty Ltd for misleading claims. It had taken payment for extra services it did not fully supply, at 20 homes. Bupa said it would pay back around $18.3 million.

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The list

It reads like a website

Dementia-designed gardens. Physiotherapy rooms. Talking book libraries. Leisure facilities. Hot breakfasts. Travel escorts. Climate control. None of them wild claims. The breach was the gap between the sentence and the service.

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The one nobody talks about

Your home page may be advertising a regulated health service

Nursing, physiotherapy, occupational therapy and podiatry are all registered professions. Promote them and Section 133 applies. No testimonials about clinical care. No claims that promise a result. No comparison you cannot prove.

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The correction

Nobody can sue you over the Statement of Rights

Section 24(3) says nothing in that Division creates rights or duties enforceable in a court or tribunal. Marketing blogs that warn otherwise are wrong. The risk runs through Section 144(1), a condition of your registration, and Section 358, a complaint.

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The verdict

Advertising your compliance is itself a claim

Say on your site that you uphold the Statement of Rights and you have handed a complaints officer a benchmark written in your own words.

Tap through for the claim-by-claim table, the worked rewrite, and the six fixes to make this quarter.

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