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Healthcare marketing for clinics within AHPRA's advertising rules

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Guide cover: healthcare marketing for clinics within AHPRA's advertising rules, channel by channel

Short answer: if you advertise a service from an AHPRA-registered profession (physio, chiro, podiatry, psychology, dental, OT and others), section 133 of the National Law covers every channel, from your website to recall reminders. Your advertising must not mislead, offer a deal without its terms, use testimonials, create unreasonable expectations of benefit, or encourage unnecessary treatment. A testimonial is any positive comment about a clinical aspect: a symptom, diagnosis, treatment or outcome. Massage therapists and exercise physiologists aren’t AHPRA-registered; consumer law and state codes apply to them.

Healthcare marketing has one extra layer of rules. Our small business marketing guide summarises each profession’s rules. This post goes deeper on health. It isn’t legal advice.

What counts as advertising

AHPRA’s advertising guidelines cover “all forms of verbal, printed and electronic communication” that promote a regulated health service provider. That includes websites, social media, business cards, office signs, “public and professional directory listings” and “patient recall notices”. Information you give a patient in a consultation doesn’t count.

The advertiser is whoever controls the content, including when you direct “a third party, staff member or marketing agency”. Advertisers “need to check any content produced by others on their behalf”, and we’d treat AI-drafted copy the same way.

For registered practitioners, the rules cover all your advertising. AHPRA’s example is a physio who is also a naturopath: the rules apply “including advertising solely about their naturopathic services”.

The five s 133 rules in plain English

Advertising must not…

In plain English

What AHPRA flags

(a) be false, misleading or deceptive

Back claims with “acceptable evidence” (mostly peer-reviewed research), not anecdotes

Unqualified lists of conditions you “treat”; claims of superior service

(b) offer a gift, discount or inducement without its terms

State the terms in plain language, or link to them

“$20 off your first visit” with no terms

(c) use testimonials

No positive comments about clinical aspects, real or made up

“my back pain disappeared after three sessions”

(d) create an unreasonable expectation of benefit

No “guaranteed” or “sure cure”. No “safe”, “risk-free” or “pain-free” without mentioning possible adverse reactions

Patient journeys; unrealistic images

(e) encourage indiscriminate or unnecessary use

No health-linked urgency, no routine check-ups without clinical need, no prizes that greatly outweigh the treatment’s cost and risk

“Regular check-ups, ideally every month”

The maximum penalty is $60,000 per offence for an individual and $120,000 for a body corporate, applying in every state and territory since July 2024. Practitioners can also face conditions on their registration. The guidelines in force date from 14 December 2020 (their appendix shows older penalties). On 14 October 2026 we found no newer version and no open consultation.

Testimonials and reviews

AHPRA defines testimonials as “recommendations or positive statements about the clinical aspects of a regulated health service used in advertising”. A clinical aspect is any of:

  • Symptom: the symptom, or the reason for seeking treatment.

  • Diagnosis or treatment: what the practitioner diagnosed or did.

  • Outcome: the result, “or the skills or experience of the practitioner either directly or via comparison”.

So a comment comparing your skill with other practitioners’ counts. Comments about customer service or communication style don’t: AHPRA’s acceptable example praises the parking.

Its testimonial tool asks three questions. Is the review about a regulated health service? Is it used in advertising? Does it mention a clinical aspect? Three yeses mean it’s not permitted.

  • Editing. Making a negative review positive, or keeping only the good parts of a mixed one, is misleading. So is trimming a clinical review “so it only contains non-clinical comments”. Publish complete, unedited reviews that aren’t testimonials.

  • Sharing. Reposting a clinical comment from another site “could be considered advertising”.

  • Your own pages. Remove testimonials people post there. If you can’t, disable the review function.

  • Ratings. A review site’s star rating or award is “not likely” to breach the ban, unless you republish the reviews behind it.

Google reviews you don’t control. AHPRA says you “do not have to remove or try to remove” reviews on sites you don’t control, and doesn’t expect you to monitor the internet. Google removes only reviews that break its policies: “Do not report a review just because you disagree with it.” The ACCC warns that removing genuine negative reviews can mislead.

“Specialist” and titles

Only medical practitioners, dental practitioners and podiatrists can hold specialist registration. Without it, AHPRA says “specialist”, “specialises in”, “specialty” and “specialised” are likely to mislead. “Substantial experience in” or “working primarily in” are less likely to. AHPRA’s examples:

  • Chiro: not “a specialist in paediatric chiropractic care”, but “substantial experience working with musculoskeletal issues in children”. “Sports chiropractor” is fine: it isn’t a recognised specialty.

  • Physio: a college-awarded title is acceptable with the award named, as in “Specialist Sports Physiotherapist (as awarded by the Australian College of Physiotherapists in 2010)”. This applies to physio only.

  • Psychology: “Clinical Psychologist” needs the clinical psychology endorsement. “Behavioural disorder specialist” isn’t acceptable.

  • “Dr”: if you aren’t a medical practitioner, add your profession, as in “Dr Lee (Osteopath)”.

Accurate qualifications are fine, but post-nominals mustn’t suggest more training than you have.

Prices, offers and gift vouchers

Prices must be “clear, easily understood, accurate, honest” and show the total, “not just initial costs or prices of certain consultations”. An instalment price needs the total cost.

“Free” means absolutely free. AHPRA says an offer isn’t free if its cost is recouped through a price rise elsewhere “or through other sources such as Medicare”. Patients often check rebates before booking, for example in our patient guide to the GP chronic condition management plan. If your ads mention a Medicare rebate, we’d show the full fee too.

Offers need their terms in the ad or a link to where they’re “easily found”, including limits such as expiry and eligibility. AHPRA’s sample: “This offer is only available to new clients. Limit of one per client.” Packages are riskier: AHPRA’s example is offering four treatments when two would be effective. So is “don’t miss out” when linked to unsupported claims that health will suffer.

Gift vouchers aren’t mentioned by name in AHPRA’s guidance. If a voucher comes with a deal, such as bonus value, treat it as an offer and state the terms. The ACCC’s gift card rules also apply: at least 3 years to redeem, the expiry date “prominently displayed”, and no fees after purchase. Cards sold at a genuine discount are exempt from the 3-year rule, as in the ACCC’s “$60 card for a massage valued at $100”.

Before-and-after images

AHPRA says these are less likely to mislead if the photos match in angle, background, framing, exposure, lighting, posture, clothing and make-up; any changes are explained; and the treatment is the only visible change. Edited images, or images that don’t show how the treatment caused the result, may breach the law.

Higher-risk non-surgical cosmetic procedures, such as injectables, have their own AHPRA guidelines from 2 September 2025. If an ad also promotes medicines or devices, the TGA’s advertising rules apply too.

Channel by channel

Website.

  • Conditions pages: say how the treatment helps each condition. AHPRA’s corrected example is “Managing symptoms such as muscular tension often associated with asthma”. Its chiropractic examples say ear infections, indigestion, behaviour disorders and immune function “do not justify a reference” in a chiropractor’s ads.

  • Review widgets: a widget that imports Google reviews republishes them, so the testimonial rule applies to each one.

Google Business Profile. Your description, services, photos and updates are advertising you control. The reviews aren’t (see above), but don’t repost clinical ones elsewhere.

Social media. A page “used to promote a regulated health service” is advertising, and so are paid posts. Remove testimonials or turn reviews off, and don’t share patient stories with clinical details. AHPRA’s social media guidance warns that “the sum of published information online could be enough to identify a patient”, so check photo backgrounds.

Directory and booking-platform profiles. Listings are advertising. Where you can’t control a platform’s reviews, the platform owner is responsible for them. You’re responsible for your bio, services and prices, so update old profiles when you fix your website.

Review replies. AHPRA says to “take care” when engaging with reviews on other sites, because a reply “may be considered using a testimonial”. The OAIC says health information includes “information about a health service you’ve had or will receive”. A public reply confirming someone was your patient, or describing their care, can disclose it. The cautious option is a general reply that confirms nothing.

Recalls. AHPRA lists recall notices as advertising, and warns against encouraging regular appointments with no clinical indication. Our small business marketing guide covers the Spam Act.

Massage and other unregistered therapists

Massage therapy and exercise physiology aren’t among the 16 professions in AHPRA’s protected-titles table.

  • Titles. Don’t use a protected title or imply registration. “Physical therapist” is protected for physiotherapy.

  • Shared clinics. AHPRA’s rules cover services “provided by, or usually provided by” a registered practitioner. Whether that reaches your service is a question for AHPRA or a lawyer.

  • ACCC. Claims must be “accurate, truthful and based on reasonable grounds”, including therapeutic claims such as its example “the fastest pain reliever”. Prices must show the total “as a single figure”.

  • Reviews. There’s no blanket testimonial ban like s 133’s, but the ACCC says reviews “should be independent and reflect the genuine opinion” of the reviewer.

  • State codes. Queensland’s National Code of Conduct for Health Care Workers names massage therapists. Clause 9 bars claims “in advertising or promotional materials about the efficacy of treatment” that “cannot be substantiated”. The NSW code (Public Health Regulation 2022, Schedule 3, clause 10) says the same. Both also cover registered practitioners’ services unrelated to their registration.

Self-check

Check

Ask yourself

Rule

Testimonials

Do reviews or stories on pages you control mention a symptom, diagnosis, treatment or outcome?

s 133(1)(c)

Edits and shares

Trimmed, cherry-picked or reposted reviews?

Testimonial tool; FAQ

Titles

“Specialist” without specialist registration? “Dr” without profession?

Guidelines 4.1.4

Claims

Unqualified condition lists? “Safe”, “pain-free”, “guaranteed”?

s 133(1)(a), (d)

Prices

Total price shown?

Guidelines 4.2

Offers

Terms stated or linked? “Free” truly free? Vouchers valid 3 years?

s 133(1)(b); ACCC

Urgency

“Don’t miss out”, packages, routine recalls?

s 133(1)(e)

Unregistered services

Efficacy claims substantiated?

Qld cl 9; NSW cl 10

AHPRA “cannot provide advice about whether specific advertising is compliant” and won’t pre-approve ads. It points you to your legal adviser, indemnity insurer or professional association, and to its self-assessment and testimonial tools.

Where Localdex fits

Localdex is our product, so weigh this section with that in mind. It’s a directory built for AI assistants as well as people.

  • Its free website check scores how much an AI assistant can learn from your site, out of 35.

  • A free profile can earn up to 65 more as you add structured details.

  • Customers, or their assistants, send requests, and the customer approves each one before it goes to at most three businesses.

  • For health categories, the request form asks only for the service needed, not symptoms or medical history.

  • It’s free to list during the pilot, and covers South East Queensland and Northern Rivers NSW.

A Localdex profile is advertising too, so the same AHPRA rules apply to what you write on it. We can’t promise patients, rankings or AI recommendations.

Check your website free · How Localdex works for businesses

FAQ

Can I reply to a Google review that mentions treatment? Take care: AHPRA says engaging may count as using a testimonial. Don’t repeat the clinical comment or confirm they were your patient.

Can I advertise a free first consultation? Yes, with the terms stated or linked. It must be genuinely free, not recouped through a later price rise or Medicare.

Do AHPRA’s rules apply to the massage therapist in my physio clinic? They cover the clinic’s physio advertising. The massage therapist follows the state code and consumer law. Whether AHPRA’s rules also reach the massage service is a judgement call: ask AHPRA or a lawyer.

Sources

Current as of 14 October 2026.

Written by Localdex

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