What does AHPRA s.133 require of a cosmetic or aesthetic clinic's website and advertising?
Section 133 of the Health Practitioner Regulation National Law applies to every cosmetic and aesthetic clinic that holds itself out as providing a regulated health service — surgical, injectable, laser or skin. Cosmetic is the most-prosecuted vertical under the provision. Testimonials about clinical care, before-and-after imagery that fails the authenticity rules, and use of the title "cosmetic surgeon" by anyone other than a Specialist Plastic Surgeon all sit on the wrong side of the line.
Reviewed 2026-05-03Health Practitioner Regulation National Law (Queensland) Schedule, s.133.
A person must not advertise a regulated health service, or a business that provides a regulated health service, in a way that — (a) is false, misleading or deceptive or is likely to be misleading or deceptive … (c) uses testimonials or purported testimonials about the service or business … (d) creates an unreasonable expectation of beneficial treatment.
Source: Health Practitioner Regulation National Law — Schedule
The substance, in plain English.
Cosmetic is the regulator's loudest case file. AHPRA's standing Cosmetic Surgery Enforcement Unit was funded for $4.5 million and had closed more than 200 notifications by April 2024, with 35-plus practitioners facing regulatory action and 315 active investigations underway. The provision binds the practitioner and the corporate entity, and applies to the website, Google Ads, Instagram captions, TikTok, before-and-after carousels, sponsored creator posts and any third-party listing the practice controls.
Testimonials about clinical care are categorically prohibited. The cosmetic sector breaches this limb more than any other — five-star Google reviews quoting outcomes, syndicated review widgets pulling clinical comments, patient "journey" videos and case-study quotes that comment on results all fall on the wrong side of s.133(1)(c). Reviews about non-clinical aspects (parking, reception, booking experience) are permitted but must not be selectively curated to imply clinical endorsement.
Before-and-after images are not banned, but the conditions are tight: authentic, contemporaneous, similarly lit and posed, with a clear statement that results vary. From 2 September 2025 the cosmetic-procedure overlay adds further constraints — the imagery must be unedited, not airbrushed, and accompanied by the results-may-vary warning. Most cosmetic non-compliance findings on the public AHPRA register involve before/after content that fails one of these conditions.
Title use is policed independently. Since 1 July 2023 only holders of the Medical Board's specialist registration in surgery (incl. Specialist Plastic Surgeons) may use the title "surgeon" or "cosmetic surgeon" — title protection runs through s.119 of the National Law and the September 2023 amendments. A general practitioner or non-specialist medical practitioner who advertises as a "cosmetic surgeon" breaches both s.133 (misleading) and the title-protection regime. "Dr" used by non-medical practitioners requires the field of doctoral qualification to appear with the title.
Inducements (free consultation vouchers, $100-off coupons, payment plans) require the terms and conditions to be displayed prominently in the same advertisement. "Mention this ad for $50 off" without the conditions is itself the breach, not the discount. Time-limited urgency offers ("24 hours only") have been flagged by AHPRA as a particular cosmetic-sector risk because the conditions are usually buried.
Maximum penalty: $60,000 per offence for an individual practitioner; $120,000 per offence for a body corporate. Each non-compliant advertisement is a separate offence..
Recent enforcement under this provision:
- 2021
Daniel Lanzer registration surrender
High-profile cosmetic surgeon surrendered his medical registration on 2 December 2021 following the ABC Four Corners broadcast and the joint AHPRA / Sydney Morning Herald investigation. His earlier Federal Court application to restrain the program had been refused.
- 2022
Daniel Aronov practice + social-media conditions
AHPRA imposed conditions barring the most-followed cosmetic surgeon on TikTok (13M+ followers) from any cosmetic or surgical procedure, and required removal of cosmetic content from his social accounts. AHPRA stated there was no time limit on the conditions until revoked by the Medical Board.
- 2024
Cosmetic Surgery Enforcement Unit — 200th notification closed
The standing $4.5M unit had closed more than 200 notifications by April 2024, with 35+ practitioners facing regulatory action, 315 active investigations underway, and 514 calls received via the dedicated cosmetic surgery hotline in 2023–24.
AHPRA — Cosmetic surgery crackdown closes 200th notification
- 2022
Lanzer-network practitioners — register conditions
Senior associates of Daniel Lanzer carry conditions on the public register: Dr Aronov restricted to supervised general practice, Dr Darbyshire suspended, and Dr Fallahi required to obtain Medical Council of NSW approval before changing scope and to practise under supervision for any cosmetic surgery procedure.
A worked example.
A Melbourne cosmetic clinic runs a homepage hero reading "Dr [name], Cosmetic Surgeon — Australia's most-loved transformations" with a slider of before-and-after images, a five-star Google Reviews carousel quoting clinical outcomes, and a banner offering "$500 off rhinoplasty this week only". The headline breaches s.133(1)(d) ("most-loved" creates unreasonable expectation) and the title-protection regime (the practitioner is a GP, not a Specialist Plastic Surgeon). The slider breaches the before-and-after authenticity conditions if the images are airbrushed or non-contemporaneous. The reviews carousel breaches s.133(1)(c). The discount banner is non-compliant on inducement terms. Each non-compliant element on the page is a separate offence at $60,000 individual / $120,000 corporate maximum. The clean version: a credentialed practitioner identifier, an unedited before-and-after gallery with the results-may-vary statement, non-clinical operational reviews framed as such, and a discount footer with full terms.
The questions that come next.
Can a GP or cosmetic physician advertise as a "cosmetic surgeon" in Australia?
No. Since 1 July 2023, the title "surgeon" — including "cosmetic surgeon" — is restricted to medical practitioners with specialist registration in surgery, obstetrics and gynaecology, or ophthalmology. The Medical Board's separate cosmetic-surgery endorsement does not, on its own, confer the title. A non-specialist medical practitioner who advertises as a "cosmetic surgeon" breaches both s.133 (misleading) and the title-protection rules in s.115–119 of the National Law.
Can we publish patient before-and-after photos on our cosmetic clinic website?
Yes, but tightly constrained. From 2 September 2025 the cosmetic-procedure overlay requires images to be real and unedited (no airbrushing or filters that mislead), with a results-may-vary warning. They must also be authentic, contemporaneous, similarly lit and posed. Most cosmetic non-compliance findings on the public AHPRA register involve before/after content that fails one of these conditions.
Are paid creator or influencer posts about our clinic permitted?
From 2 September 2025, no. The cosmetic-procedure advertising guidelines specifically prohibit testimonials and endorsements from social-media influencers about cosmetic procedures. The ban applies whether the post is paid, gifted or unpaid. Sharing or reposting an influencer's content about your clinic carries the same exposure as commissioning it directly.
We syndicate Google Reviews on our site — does that comply with s.133?
Only if every visible review is about non-clinical operational aspects (parking, reception, booking, accessibility). Reviews quoting clinical outcomes, recommendations to others or comparative quality fall on the wrong side of s.133(1)(c) regardless of the source. AHPRA's published Testimonial Tool walks through the line; the safer pattern is human-curated non-clinical reviews framed as such, not an unfiltered widget.
How much time does a clinic have to fix non-compliant cosmetic advertising once notified?
AHPRA's compliance and enforcement strategy generally provides a remediation window — typically 30 days — before escalation. Cosmetic notifications are reviewed by the Cosmetic Surgery Enforcement Unit and the threshold for escalation is lower than other verticals because of the unit's standing focus. Failure to remediate, or repeat breaches, escalates to formal investigation, conditions on registration, and prosecution.
Read it for yourself.
Brief us with the regulator already in line one.