Where the rules apply on social media
Advertising means any public communication that promotes a regulated health service. On social media that includes posts, stories, reels, live video, event listings, profile details and paid boosts. A boosted post is advertising because you paid to promote it. A post that only mentions a treatment in passing can also qualify.
Content you share from somewhere else follows the same rules. Reposting a patient's review, or a photo of a patient's result, makes it your advertising once it sits on your page.
Testimonials on your own feed
Section 133 prohibits testimonials, and purported testimonials, in advertising. In this sense a testimonial is a statement about the clinical side of care: the treatment, the outcome, or the practitioner's clinical skill.
A patient comment such as "my knee has been so much better since the third visit" is a testimonial. Screenshotting it, quoting it in a caption or turning it into a graphic all put it into your advertising.
Comments about non-clinical matters sit outside that definition. Praise for your reception team, your parking, your opening hours or a quick booking process can be used. Check each comment against the line before you reuse it. One sentence about the result can turn a friendly comment into a prohibited testimonial.
Comments and replies on your own posts
Patients sometimes describe their treatment in the comments under your posts. Your page is material you control, so treat clinical comments there the way you would treat a testimonial you chose to publish. Do not pin, highlight or share them, and keep them out of highlight reels and story collections.
Your replies count too. A reply such as "so glad the treatment worked" repeats the clinical outcome under your name. Keep replies to the non-clinical side: thank the person, confirm booking or front-desk details, or invite them to call the clinic.
If a comment raises a clinical concern, move the conversation to a private channel. A public reply about someone's care can breach their privacy as well as the advertising rules.
Replying to reviews
Reviews left on Google, Facebook or other platforms you do not control are not generally treated as your advertising, for as long as the review stays where the patient left it.
Responding is a different act. Engaging with a review on a third-party site may be treated as using a testimonial to advertise, so keep your replies within the same limits as your own comments. A good reply does three things:
- It thanks the reviewer or acknowledges their feedback.
- It addresses any booking, billing or service matter.
- It leaves out the treatment, its outcome and your clinical skill.
Do not ask patients for reviews about their treatment to use in marketing. Do not reshare a review from a third-party site into a post, story or ad.
Content created by staff
You are responsible for what your team posts about the clinic. A receptionist who shares a team photo with a caption about a treatment has published advertising. So has a practitioner who posts about their work from a personal account in a way that promotes your services.
Set a short written guide for the team. Cover what can be posted, what can be shared, how comments and reviews are handled, and who approves content before it goes live. A one-page guide with clear approval steps is easier to follow than a warning issued after a post has already gone live.
Influencers and paid creators
If you arrange, pay for or direct a creator to promote your clinic or a treatment, treat their post as yours. A creator's name on the post does not move the responsibility to them. A practice carries the risk for the advertising it runs, including advertising a supplier or creator produced for it.
Brief creators in writing. Approve the content before it goes live, and cut any claim you would not make yourself. A line such as "I had my back fixed in one visit" is a problem whoever wrote it.
Free treatment, a discount or a gift offered in return for a post is an inducement. Its terms and conditions need to be visible close to the offer, so a viewer can read them without searching.
Competitions, urgency and bookings
Giveaways tied to booking, countdown posts and "only three spots left" messages fall under the urgency rules. Section 133 prohibits directly or indirectly encouraging the unnecessary use of regulated health services.
A deadline with a clinical reason behind it, such as a screening window, can be stated along with that reason. If the only reason for the deadline is your diary filling up, leave it out.
Before you post
Check each post, comment and reply against four questions:
- Does it describe a patient's experience of treatment?
- Can every claim be supported by evidence you hold today?
- If there is an offer, can a patient find its terms without searching?
- Does anything promise a result, or create a deadline with no clinical reason?
Anything created by someone else needs one more check: who approved it, and did they check it against these questions?
If a post fails one of these checks, change the wording and keep the point. If you are unsure, get a review before the post goes live.
What a breach costs
The maximum penalty for a breach of section 133 is $60,000 per offence for an individual and $120,000 per offence for a body corporate. Anyone can complain about a post. A complaint can mean a deadline to correct or remove the material, and it can start before any court case.
Frequently Asked Questions
Does content our staff post count as clinic advertising?
Yes, because you are responsible for what your team posts about the clinic, including a receptionist's post about a treatment. The page recommends a short written team guide covering what can be posted, how comments and reviews are handled, and who approves content before it goes live.
Can we reply to a patient who describes treatment in the comments?
Be careful, because your replies count as advertising too, and a reply that says the treatment worked repeats the clinical outcome under your name. The page suggests replies that thank the person, confirm booking or front-desk details, or invite them to call, and it recommends moving any clinical concern to a private channel.
Can we reshare a Google review in a post or ad?
No. The page advises against resharing a review from a third-party site into a post, story or ad, and replies to reviews should leave out the treatment, its outcome and your clinical skill.
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General information only. It is not legal advice and does not replace the current guidelines published by AHPRA and the National Boards. Check the source material or seek advice on your specific situation.