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Healthcare Advertising Guidelines in 2025: What Changed(& What Didn't)

End-of-year wrap-up for healthcare organisations

As we head into the Christmas break and close out 2025, it’s worth taking a moment to reflect on what’s happened in the regulated healthcare services advertising landscape this year.

If you’ve felt like the ground has been shifting beneath your feet, you’re not alone.

Healthcare advertising in Australia looks a little different at the end of 2025 not because we’ve been drowning in new advertising guidelines, but because regulators shifted how they interpret, enforce, and expect compliance with the rules that already existed.

The Cosmetic Procedures September Update Everyone Was Talking About

Let’s start with the most visible change of the year.

On 2 September 2025, AHPRA and National Boards imposed clarified guidelines for advertising higher-risk non-surgical cosmetic procedures.

For clinics advertising injectables, fillers, thread lifts, laser, fat freezing and similar services, the changes marked an important shift in how these treatments are expected to be presented to the public.

Here’s what changed:

Reaffirmed Obligations

Advertisements must avoid misleading language, can’t trivialise procedures, and must include relevant practitioner details. Nothing new here, but the emphasis was obvious.

Before/After Images

To be used under tightly controlled conditions, and testimonials from influencers are explicitly restricted.

  • Images must not mislead the public by implying results that are not genuine or typical. This includes the use of airbrushing, filters, retouching, or other enhancements that create an idealised outcome, as well as using models or celebrities unless it is clearly established they have undergone the advertised procedure.
  • Any image intended to show treatment outcomes must include a clear disclaimer stating that results are specific to that patient and may not be representative of others.
  • ‘Before and after’ images must be genuine patient images and both images should be shown together or with the ‘before’ image most prominent, captured under consistent conditions such as lighting, angle, and styling.
  • The timing of the ‘after’ image should also be disclosed, so viewers understand when the result was captured.

Under-18s Are Off-limits

Advertising for higher-risk cosmetic procedures must not be directed at people under 18. Therefore, clinics are required to limit young people’s exposure by avoiding media channels or publications with a significant under-18 audience.

Furthermore, on social media, this advertising must be clearly marked as adult content to restrict access by minors.

Additionally, the practice guidelines (which came into effect the same day) introduced a mandatory seven-day cooling-off period between consultation and procedure for anyone under 18.

Training & Scope Expectations Are Clearer

The advertising guidelines require that claims about training, qualifications, and competence must be accurate and not misleading.

Additionally, the practice guidelines (released the same day) established specific training and experience requirements, for nurses performing cosmetic procedures.

The convergence of these requirements means practitioners can only advertise what they’re genuinely qualified to deliver.

Medicinal Cannabis & Compliance

While cosmetic procedures grabbed the September headlines, July saw another regulatory development: AHPRA’s guidance on medicinal cannabis prescribing.

However, this wasn’t just about clinical practice. It was equally about advertising and business models in the medicinal cannabis space.

AHPRA raised serious concerns about profits being prioritised over patient safety in some medicinal cannabis prescribing practices including:

  • Misleading advertising and marketing practices, particularly on social media.
  • Websites that “coach” patients on what to say to justify prescription.
  • Single-purpose clinics creating inherent conflicts of interest.

As of July 2025, action had been taken against 57 medical practitioners, pharmacists and nurses related to medicinal cannabis prescribing and advertising. Therefore, this represents a clear signal that regulators were and are watching this sector closely.

The advertising prohibitions are strict: medicinal cannabis products cannot be advertised to consumers at all under the Therapeutic Goods Act, and health services involving medicinal cannabis must be advertised carefully to avoid promoting the products themselves.

What About Everything Else?

Outside of the July guidelines for medicinal cannabis and September guidelines for cosmetic procedures, AHPRA didn’t publish a whole series of new advertising guideline documents in 2025.

Therefore, this year wasn’t defined by constant releases of new rules but by reinforcement of existing obligations under the National Law.

The Penalty Reform That Changed the Conversation

One of the most significant developments affecting healthcare advertising this year wasn’t a 2025 change at all.

It was penalty reform that started in 2022 and reached full implementation by mid-2024.

Let’s put this in perspective: maximum penalties for breaching advertising requirements increased from around $5,000 to as much as $60,000 for individuals and $120,000 for corporations per offence.

Consequently, this shift seems to have elevated advertising compliance from “something marketing handles” to “something the leadership team needs visibility on.”

The stakes are higher so suddenly, that testimonial or overstated claim wasn’t worth the risk anymore.

Enforcement Became A Real Story

This year, enforcement was more visible.

AHPRA took concrete steps against non-compliant practitioners in high-risk areas like cosmetic procedures and medicinal cannabis prescribing.

In parallel, detailed guidelines clarified how advertising laws apply to digital marketing, and influencer content, making it clear that misleading marketing isn’t tolerated.

Scope, Training & Advertising Became One Conversation

A key theme that emerged clearly in 2025 was the convergence of scope of practice, training, and advertising expectations, particularly for cosmetic and aesthetic services.

Regulators underscored that practitioners must:

  • Only advertise services they are legitimately trained and competent to deliver.
  • Clearly represent qualifications and scope of practice.
  • Avoid claims that imply expertise beyond their credentials.

Advertising accuracy became inseparable from professional standards. If you’re not qualified to perform a procedure, you can’t advertise it.

If you don’t have the training, you can’t make the claim.

Looking Ahead to 2026

As we move into the new year, it seems that advertising compliance might need to be thought of differently than it has been in the past.

Meeting advertising compliance obligations is increasingly being treated as something that needs to be embedded in marketing processes, clinical oversight, and risk management conversations at the leadership level.

Healthcare organisations that appear to be navigating this landscape most successfully are those treating advertising compliance not as an afterthought or a box-ticking exercise, but as a core part of how they protect their brand, their patients, and their licence to operate.

Action Item

Heading into the Christmas break, it might be worth taking a moment to review your:

  • Current advertising content across all channels.
  • Approval processes for new marketing materials.
  • Team’s understanding of the current requirements.
  • Documentation of practitioner qualifications and scope.

Because when everyone returns in January, the regulatory environment won’t be any more forgiving.

So enjoy the break, you’ve earned it. However, make sure your advertising practices can stand up to an audit when you return.

FAQs

How does penalty reform affect advertising compliance?

Maximum penalties rose up to $60,000 per individual offence and $120,000 per corporate offence.

This makes non-compliance far riskier.

Advertising higher-risk cosmetic procedures aimed at minors is prohibited.

There’s also a mandatory seven-day cooling-off period for anyone under 18 between consultation and procedure.

Advertising medicinal cannabis products to consumers is prohibited.

Clinics must also be careful with marketing health services in this space to avoid implying promotion of the product itself.

Treat compliance as an operational discipline, not a one-time audit.

Embed checkpoints into content creation workflows, keep practitioner qualifications documented, and ensure marketing and clinical governance teams collaborate closely.

No. This content is for informational purposes only. For specific guidance, consult a healthcare regulatory lawyer or compliance specialist.

Disclaimer: This article provides general information and observations only, it doesn’t constitute legal advice. Tuesday Logic are not lawyers.

For specific guidance on your situation, consult with your lawyer or compliance specialist.

Last updated on May 26th, 2026 at 10:50 pm

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