What does AHPRA s.133 require of a medical clinic's website and advertising?
Section 133 of the Health Practitioner Regulation National Law prohibits advertising of regulated health services that is false, misleading, uses testimonials about clinical care, creates unreasonable expectations of beneficial treatment, or encourages indiscriminate or unnecessary use. It applies to every public surface a medical clinic publishes — website, Google ads, Instagram captions, before-and-after images, and the five-star 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 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.
Every public claim a medical clinic makes is in scope. The provision binds the practitioner and the corporate entity, and applies to a fee schedule on the website, a Google ad, a sponsored Instagram post, a Facebook review carousel, an SEO landing page or a recorded testimonial in a podcast trailer. AHPRA's published guidance treats the website itself as the primary advertising surface for most practices.
Testimonials about clinical care are categorically prohibited. The line is whether the statement comments on the clinical aspects of the service — outcomes, recommendation of a treatment, comparative quality. Five-star reviews on the homepage, even if syndicated from Google, fall on the wrong side of the line if the review text comments on clinical care. Reviews about non-clinical aspects (parking, reception, wait times) are permitted but must not be selectively curated to imply clinical endorsement.
Before-and-after images are not banned outright but are heavily constrained — they must be authentic, contemporaneous, similarly lit, and accompanied by a statement that results vary. Most non-compliant medical advertising on the public AHPRA register involves before/after content that fails one of these conditions.
Inducements (gifts, discounts, gift vouchers) 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. AHPRA has flagged time-limited urgency offers as a particular risk because the terms are usually buried.
Unreasonable expectations of beneficial treatment is the catch-all. Words like "safe", "painless", "guaranteed", "life-changing" applied to a clinical procedure trigger this limb. So does any creative that implies a single intervention will resolve a complex condition.
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:
- 2024
AHPRA Cosmetic Surgery Enforcement Unit
Standing enforcement unit established with $4.5 million in funding had closed more than 200 notifications by April 2024, with 35+ practitioners facing regulatory action and 315 active investigations underway across the cosmetic and broader medical sector.
AHPRA — Cosmetic surgery crackdown closes 200th notification
- 2021
Daniel Lanzer registration surrender
High-profile cosmetic surgeon surrendered his medical registration on 2 December 2021 following the ABC Four Corners broadcast and AHPRA investigation. His earlier Federal Court application to restrain the program had been refused.
- 2025
AHPRA 2024–25 advertising compliance report
AHPRA's annual reporting recorded 775 advertising complaints assessed in the year, 356 of which were treated as criminal offences for prosecution under s.133. The compliance and enforcement strategy makes clear AHPRA prioritises website + social-media advertising over print.
A worked example.
A Sydney general practice runs a Google Ad headline reading "Best GP in Glebe — patients rave about our care" with a sitelink to a homepage Reviews section pulling five-star Google Reviews verbatim. The headline is on the wrong side of s.133(1)(d) ("best" creates unreasonable expectation), the homepage review carousel is on the wrong side of s.133(1)(c) (testimonials about clinical care), and the ad budget keeps spending while AHPRA's compliance team compiles the notification. The fix is rewriting the headline around a specific service and credentialed practitioner, and replacing the review carousel with non-clinical operational reviews (booking experience, accessibility) clearly framed as such. None of this is hypothetical — practices have been notified and prosecuted on each of these limbs.
The questions that come next.
Does s.133 apply to my website if I'm a sole-practitioner GP, not a corporate clinic?
Yes. The provision binds the individual practitioner directly. Sole practitioners are personally liable for advertising on their own websites, social profiles and any third-party listing they control. Corporate-entity practices add a second corporate liability under s.133, but individual liability does not transfer.
Can I publish reviews if they don't mention clinical care?
Yes — reviews about non-clinical operational aspects of the practice (parking, reception staff, wait times, booking experience) are permitted. AHPRA's published Testimonial Tool walks through the line. The risk is selective curation: showing only positive reviews can imply clinical endorsement even when the words don't. The safer pattern is showing non-clinical reviews framed as such.
Are before-and-after images banned outright?
No, but they are tightly constrained. AHPRA's guidance requires images to be authentic, contemporaneous, similarly lit and posed, and accompanied by a clear statement that results vary. Cosmetic and dental practices use before/after extensively — most non-compliance findings on the public register involve before/after content that fails one or more of these conditions.
What if Google or Meta shows the ad — does that mean it complies with s.133?
No. Platform approval is a separate, weaker check. Meta and Google review for their own policies, not for the National Law. An ad that runs without platform rejection can still breach s.133 and lead to AHPRA action against the practitioner. The platform never signs the AHPRA notification.
How long do I have to fix non-compliant advertising once notified?
AHPRA generally provides a remediation window before escalating to formal action — typically 30 days under the published compliance and enforcement strategy. Failure to remediate within the window, or repeat breaches, escalates to formal investigation and prosecution. The cleanest position is remediating proactively, not waiting for a notification.
Read it for yourself.
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