What does AHPRA s.133 require of a dental practice's website and advertising?
Section 133 of the Health Practitioner Regulation National Law applies to every dental practitioner and practice in Australia. It prohibits advertising that is false or misleading, uses testimonials about clinical care, omits the terms of any inducement, creates unreasonable expectations of treatment, or encourages indiscriminate use of dental services. The Dental Board of Australia, working through AHPRA, enforces it across websites, Google ads, Instagram reels, before-and-after carousels and the patient-review widget on the homepage.
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 … (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.
Every public surface a dental practice publishes is in scope. The provision binds the individual dentist and the corporate practice entity, and applies equally to a fee schedule on the website, a Google ad for crowns, a sponsored Instagram post showing a smile-makeover result, a Facebook review carousel, an SEO landing page targeting "dentist near me" and a TikTok promoting same-day implants. AHPRA's published guidance treats the practice website as the primary advertising surface.
Testimonials about clinical care are categorically prohibited. The Dental Board's published guidance is that patient reviews about clinical outcomes — alignment, whitening shade, the look of veneers, pain levels during treatment — fall on the wrong side of s.133, even when syndicated from Google. Reviews about non-clinical operational aspects (booking experience, reception, accessibility, parking) are permitted, but selective curation of only positive reviews can imply clinical endorsement and trigger the limb anyway. Before-and-after images are not banned outright, but the Dental Board has expressly warned that they can themselves be interpreted as testimonials when accompanied by claims about results.
Before-and-after imagery for dentistry — alignment, whitening, veneers, smile makeovers — must be authentic, contemporaneous, similarly lit and posed, and accompanied by a clear statement that results vary. A 2023 Australian Dental Journal study (Jensen et al.) audited Australian dental practice websites and found 85% breached at least one advertising rule, with before-and-after content one of the dominant failure modes.
Fee disclosures must be specific enough not to mislead. "Crowns from $1,500" without specifying that the headline price is for a single posterior porcelain crown — and that anterior, full-arch or full-mouth work is materially different — is the breach pattern AHPRA flags repeatedly. Inducements ("$200 off your first visit", "free whitening with check-up") require the terms and conditions in the same advertisement, prominently. Time-limited urgency offers without conditions are a particular risk.
Specialist title rules are strictly enforced. Only dentists registered with the Dental Board in one of the recognised specialties (orthodontics, periodontics, oral surgery, prosthodontics, paediatric dentistry, endodontics, oral medicine, oral pathology, special needs dentistry, dento-maxillofacial radiology, public health dentistry) may use the words "specialist", "specialises in", "specialty" or "specialised". A general dentist with a clinical interest in orthodontics may say they have a "special interest" in that area, but cannot describe themselves as an orthodontist or specialist.
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 under National Law..
Recent enforcement under this provision:
- 2024
Dental Board advertising compliance push (super-funded dental)
On 6 May 2024 the Dental Board urged compliance with advertising rules amid a sharp rise in patients accessing superannuation to fund dental treatment, after AHPRA received 13 notifications about super-funded dental work — five of which related directly to recommendations or advertising encouraging patients to access their superannuation to fund treatment. AHPRA placed conditions on the registration of a dentist linked to the activity.
AHPRA — Dental Board urges compliance with advertising rules
- 2024
AHPRA 2023–24 advertising and criminal-offence reporting
AHPRA's annual reporting recorded 547 criminal-offence complaints in 2023–24 (up 23.8% year on year), with 26 complaints made specifically about dental practitioners. 36% of all completed criminal prosecutions in the period related to advertising offences under s.133.
- 2023
Jensen et al. — ADJ website-compliance audit
Peer-reviewed audit of Australian general-practice dental websites, published in the Australian Dental Journal, found 85% breached at least one National Law advertising requirement — with testimonials, unrealistic outcome claims and unconditioned before-and-after imagery the most common failures.
Jensen et al., Australian Dental Journal — practice-website compliance audit
- 2024
AHPRA advertising compliance and enforcement strategy
AHPRA's published strategy confirms website + social-media surfaces are the priority for compliance action over print, that AI tooling is now used to identify problem advertising, and that practices are typically given a remediation window before formal action — failure to remediate escalates to prosecution.
A worked example.
A Brisbane group practice runs a Meta carousel ad headlined "Brisbane's best smile makeovers — see why our patients love us". The carousel is built from before/after photos with patient first names and quotes about how a veneer course "changed their life". The landing page leads with five-star Google reviews — most commenting on the dentists by name — and a fee block reading "Veneers from $850" with no clarification that the headline price is per tooth and not the standard package. The headline trips s.133(1)(d) ("best" creates unreasonable expectation), the patient-quote slides trip s.133(1)(c) (testimonials about clinical care), the unconditioned before/after carousel runs into the Dental Board's published before/after guidance, and the misleading fee anchor trips s.133(1)(a). Each of those is a separate offence per ad surface; the ad set keeps spending while AHPRA's notification proceeds.
The questions that come next.
Can a dental practice publish patient reviews on its website if the reviews don't mention treatment?
Yes — reviews about non-clinical operational aspects of the practice (booking experience, reception staff, accessibility, parking, wait times) are permitted under the Dental Board's guidance. The risk is selective curation: showing only positive reviews can imply clinical endorsement even when the words don't. Reviews that comment on alignment, whitening shade, pain levels or treatment outcomes are testimonials about clinical care and prohibited.
Are before-and-after photos of teeth alignment, whitening or veneers banned outright?
No, but they are tightly constrained. Images must be authentic, contemporaneous, similarly lit and posed, and accompanied by a clear statement that results vary. The Dental Board has separately warned that before-and-after images can themselves be interpreted as testimonials when paired with outcome claims. From 2 September 2025, where dental work crosses cosmetic territory (veneers, smile makeovers), additional restrictions under the cosmetic procedure guidelines also apply.
Can a general dentist describe themselves as a "cosmetic dentist" or "orthodontist" without specialist registration?
No. Only dentists holding specialist registration in one of the Dental Board's recognised specialties (orthodontics, periodontics, prosthodontics and others) may use the protected titles "specialist", "specialises in", "specialty" or "specialised". Cosmetic dentistry is not a recognised dental specialty, so the term "cosmetic dentist" is permissible, but "orthodontist" without specialist registration is title-protection breach. A general dentist with a clinical interest may say they have a "special interest" in the area.
How specific does fee advertising need to be?
Specific enough not to mislead. "Crowns from $1,500" is permitted only if the headline price is genuinely available and the ad doesn't omit material differences (single posterior crown vs. anterior crown vs. full-arch). "Veneers from $850 per tooth" is cleaner than "Veneers from $850" because it states the unit. Inducements such as "$200 off your check-up" require the conditions (eligibility window, exclusions) in the same advertisement, prominently displayed.
What happens if a third-party Google or Facebook review breaches s.133 — is the practice liable?
If the practice has reasonable control over the surface — its own Google Business Profile, its own Facebook Page reviews — AHPRA's published view is the practice is responsible for monitoring and, where possible, addressing non-compliant reviews. Embedding or syndicating reviews onto the practice's own website is treated as the practice publishing them. Reviews on neutral third-party platforms over which the practice has no control are treated differently, but linking to or amplifying them on owned channels brings them back into scope.
Read it for yourself.
Brief us with the regulator already in line one.