What are AHPRA's rules for before-and-after images in health practitioner advertising?
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
CompliGUARD reviews practitioner before-and-after images against AHPRA's advertising rules under the National Law. Before-and-after images are not explicitly prohibited by AHPRA's advertising guidelines, but they almost always breach the prohibition on creating an unrealistic expectation of benefit under s.133(1)(c) of the Health Practitioner Regulation National Law — and should be avoided in practitioner advertising.
The rule: Health Practitioner Regulation National Law, s.133(1)(c) and AHPRA Advertising Guidelines s.3.3
Section 133(1)(c) of the Health Practitioner Regulation National Law prohibits advertising that creates an unrealistic expectation of the benefit of a regulated health service. AHPRA's Guidelines for Advertising a Regulated Health Service (December 2020, s.3.3) specifically address before-and-after images, noting that they can create unrealistic expectations by implying that a specific outcome is typical or achievable for all patients. AHPRA has confirmed that before-and-after images are a frequently cited factor in advertising complaint investigations.
What this means in practice
- Apply a simple test before using any before-and-after image: would a reasonable patient viewing this image expect to achieve a similar result? If yes, the image likely creates an unrealistic expectation.
- Do not pair before-and-after images with testimonial language — the combination is the most common trigger for AHPRA complaint investigation.
- If using comparative images to illustrate an educational point (not a treatment outcome), ensure the context makes clear that the images are illustrative rather than promotional.
- Consider whether the image constitutes a testimonial — if it depicts a patient's individual transformation, it may fall under s.133(1)(c).
- Remove existing before-and-after content from all advertising channels, including posts that are no longer actively promoted but remain publicly visible.
Common mistakes
Using before-and-after images with captions like 'typical results' or 'what's possible'
Framing before-and-after images as representing typical outcomes or potential results compounds the unrealistic expectation — health outcomes are highly individual, and implied typicality is precisely what the prohibition targets.
Remove outcome-implying language entirely. If the image is educational, frame it as illustrating a condition rather than advertising a treatment outcome.
Posting before-and-after content created by a patient without practitioner involvement
Content created and posted by a patient on their own account is not the practitioner's advertising. But if the practitioner reposts, shares, tags, or encourages the content, it becomes part of the practitioner's advertising and the prohibitions apply.
Do not repost, share, or draw attention to patient-generated before-and-after content, even if you did not create it.
Assuming physiotherapy or chiropractic 'posture correction' images are exempt
Images showing a patient's posture before and after treatment are before-and-after images for the purposes of s.133(1)(c), regardless of the clinical terminology used to describe them.
Use anatomical diagrams or stock imagery to illustrate conditions rather than patient-specific outcome images.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Using before-and-after images with captions like 'typical results' or 'what's possible'
✅ COMPLIANT
Remove outcome-implying language entirely. If the image is educational, frame it as illustrating a condition rather than advertising a treatment outcome.
The enforcement context
Before-and-after imagery is one of the most consistently investigated content types in AHPRA advertising complaints. AHPRA's 2024–25 complaint data showed 775 complaints assessed, with visual content — including before-and-after images — cited as a primary or contributing factor in a significant proportion of investigated cases. AHPRA's automated monitoring tools specifically flag before-and-after visual formats on practitioner social media.
Before you publish, check it.
CompliGUARD reviews practitioner advertising content against AHPRA Guidelines s.133(1)(c) for unrealistic benefit claims.
Start free reviewRelated questions
Regulatory references
- Health Practitioner Regulation National Law, s.133(1)(c)
- AHPRA Guidelines for Advertising a Regulated Health Service, December 2020, s.3.3
- AHPRA Advertising Compliance and Enforcement Policy