What counts as advertising on your website
The working test is simple. If a page promotes a regulated health service and you control what it says, treat it as advertising. That covers the home page, service pages, landing pages, FAQs, blog posts that recommend your treatments, and the text inside enquiry and booking forms.
It also covers the parts people skip: page titles, meta descriptions, image captions, alt text and pop-up messages. Search results show those fields to millions of people, so they get the same scrutiny as the headline.
Responsibility stays with the practice even when someone else built the site. A web designer, a template vendor or a marketing agency can write the copy, but the clinic that publishes it is the advertiser. Ask your supplier what they check before publishing, and keep a record of who approved each page.
Claims on your pages
Start with the words that do the most damage. "Best", "leading", "number one", "most advanced", "specialist" and "expert" are all claims. If you cannot back one with evidence a reasonable person would accept, it does not belong on the page. Comparative claims are the riskiest, because they imply you have checked every other clinic nearby.
Qualifications need the same care. Calling someone a specialist when they are not registered in an approved specialty is misleading. So is a run of postnominals that suggests more seniority than the practitioner holds. List qualifications the way they are registered, and only where they matter to the service on that page.
Outcome language is the third trap, and hero banners are where it usually appears. "Pain-free in one visit" and "guaranteed results" promise outcomes that vary from patient to patient. A stronger headline describes what the patient receives, such as an assessment and a clear explanation of the options.
Offers and the terms that go with them
An offer is allowed. An offer with its terms left out is not. Section 133 requires that any gift, discount or other inducement used to attract patients states its terms and conditions.
On websites, this usually fails when a "free consultation" banner hides its conditions in a footer link several clicks away, or when a landing page shows a price without saying what it includes or when it ends.
Put the terms on the same page as the offer, close to the call to action. State who the offer is for, what is included and excluded, and whether it expires. If the conditions run long, summarise the key points beside the offer and link to the full terms.
Testimonials and reviews
This rule causes the most confusion, so it is worth being precise. Section 133 prohibits using testimonials, or purported testimonials, in advertising. In AHPRA's guidance, a testimonial is a positive statement that refers to a clinical aspect of the service. That means the reason someone sought care, the diagnosis or treatment provided, the outcome, or the practitioner's skill or experience. Comments about non-clinical matters, such as reception, booking, parking or waiting times, sit outside that definition.
For a website, that means:
- No "what our patients say" block that includes comments about treatment.
- No rotating review slider on your own pages that quotes outcomes.
- No feedback form that asks patients to describe their results for marketing use.
- Care with review widgets. A widget that displays treatment comments on your own pages is material you control, so treat it as your advertising.
Reviews left on platforms you do not control are handled differently. Patients can post what they like, and you are not expected to hunt them down. Copying one onto your site, however, turns it into your advertising. Replies you post on third-party review sites can also be read as using those reviews, so keep any reply non-clinical and check it before it goes up.
A patient praising the front desk or the booking system is a non-clinical comment and can be used, as long as it is quoted accurately.
Before-and-after images
Before-and-after content is allowed, but the bar is high. The two images need to be genuinely comparable: the same lighting, angle and framing, with no retouching or filters and no hand-picked best result. Consent must be obtained and kept on file. The text around the images must not tell the reader they will get the same result.
On websites, the risk often sits in captions and alt text. A caption such as "look at this transformation" makes a promise the images cannot support. If you cannot meet the comparability standard, leave the images out and explain the procedure in plain words instead.
Urgency, scarcity and booking pressure
Section 133 also restricts advertising that encourages the indiscriminate or unnecessary use of regulated health services. On a website, the usual suspects are countdown timers, "only three appointments left this month" banners, loyalty rewards for extra visits, and bulk session packs presented as a bargain.
A deadline with a clinical reason behind it is different. If a screening window or a treatment timeframe is real, state it and explain why it matters to the patient. If the only reason for the deadline is your diary, take it off the page.
Forms and the pages behind them
Forms are where many clinic sites collect the information the rules care about most, so check them as carefully as the headlines.
- Enquiry and booking forms: the headline, button text and any "limited availability" message should be accurate and free of pressure that is not clinical.
- Thank-you pages: a discount on a second visit is an inducement, and it needs its terms. Many clinics add one without thinking about it.
- Confirmation emails: if a confirmation includes an offer or a promotional line, the same rules apply to that wording.
- Story or review submission forms: do not run one to collect material for marketing.
- Before-and-after upload forms: do not collect images for marketing unless you can meet the comparability standard, and consent is documented.
Read every form as a visitor would, and ask whether anything hides a term or pushes a booking.
Check each page before it goes live
Run every page through five questions. If you cannot answer yes to all five, the page is not ready.
- Can every claim on the page be supported by evidence you hold today?
- Is there a patient comment about treatment anywhere on the page, including in images and captions?
- If there is an offer, are its terms visible on the same page without searching?
- Does anything promise or imply a result?
- Is every deadline tied to a clinical reason rather than your calendar?
Repeat the check for page titles, meta descriptions, pop-ups, thank-you pages and confirmation emails. These are the parts most often missed in a review.
Build the site and the copy together
If you are planning a new site, review the build and the copy together. Templates, pop-up settings and form confirmations are where a compliant page can drift into breach after launch. The web design page explains how we approach the build.
Frequently Asked Questions
Does a review widget on our site count as our advertising?
Yes, when it displays treatment comments on your own pages, because material you control counts as your advertising. Reviews left on platforms you do not control are handled differently, but copying one onto your site makes it your advertising.
What must an offer on our website show?
Section 133 requires any discount, gift or other inducement to state its terms and conditions. The page advises showing who the offer is for, what is included and excluded, and whether it expires, on the same page and close to the call to action.
What should we check on every page before it goes live?
The page sets five yes-or-no questions: every claim is backed by evidence you hold today, no treatment comment appears, offer terms are visible on the page, nothing promises or implies a result, and every deadline has a clinical reason. The same check should cover page titles, meta descriptions, pop-ups, thank-you pages and confirmation emails.
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What You Can't Say in Health Ads
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AHPRA & Patient Testimonials
What section 133 says about patient testimonials, where the clinical line falls, purported testimonials, and reviews on platforms your clinic does not control.
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Before and After Photos in Health Advertising
When AHPRA allows before and after photos in health advertising, what makes them misleading, and how to check your clinic's images before you publish.
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How AHPRA's advertising rules apply to clinic social media, including comments, replies, patient reviews, and posts made by staff or influencers.
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Google Healthcare Ad Policies
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AHPRA Compliance Checklist
A practical checklist for clinic owners to test websites, ads, reviews, offers and photos against the AHPRA advertising rules before anything goes live.
Read guideImportant note
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.