Can AHPRA-registered practitioners use influencers to promote their health services in Australia?
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
CompliGUARD reviews practitioner influencer content against AHPRA's advertising rules under the National Law. AHPRA-registered practitioners can use influencers to promote their services, but all influencer content is subject to the same advertising prohibitions as direct practitioner advertising — including the ban on testimonials, outcome claims, and inducements — and the practitioner remains responsible for compliance.
The rule: Health Practitioner Regulation National Law, s.133; AHPRA Guidelines for Advertising a Regulated Health Service, December 2020, s.4
AHPRA's Guidelines for Advertising a Regulated Health Service apply to all advertising of regulated health services, regardless of who creates or posts the content. Where a practitioner commissions, pays for, or provides consideration to an influencer to promote their services, that content is advertising under s.133 of the Health Practitioner Regulation National Law — and the practitioner is responsible for its compliance with all four advertising prohibitions. The influencer's status as a non-practitioner does not create an exemption from the practitioner's obligations.
What this means in practice
- Brief influencers explicitly on what they cannot say — no patient outcomes, no 'before and after' framing, no claims of superiority, no language implying guaranteed results.
- Review influencer content before it is posted — retain a timestamped record of the version approved.
- Do not ask influencers to share their personal experience of receiving treatment from you — this constitutes a testimonial under s.133(1)(c) regardless of whether it is framed as a personal story.
- Ensure the commercial relationship is disclosed in the content — ACCC guidelines require disclosure of paid influencer relationships.
- Apply the same pre-publication compliance check to influencer content that you apply to your own direct advertising.
Common mistakes
Using a patient who is also an influencer to share their treatment experience
A patient-influencer who shares their experience of receiving treatment from a practitioner — even if the content is framed as a personal lifestyle post — may constitute a testimonial under s.133(1)(c) if the practitioner commissioned, paid for, or encouraged the content.
Do not ask patients to create content about their treatment experience, regardless of their influencer status. The testimonial prohibition applies to the relationship and the content, not the label applied to the arrangement.
Assuming influencer content is the influencer's responsibility
AHPRA's advertising framework places compliance responsibility on the practitioner whose services are being promoted. An AHPRA advertising complaint arising from influencer content will be directed at the practitioner, not the influencer.
Treat influencer content review as a practitioner compliance obligation. Review all content against AHPRA's four advertising prohibitions before it goes live.
Using influencer content to run promotional offers or discounts
Influencer content that promotes a time-limited discount or special offer on health services may constitute an inducement under s.133(1)(e) — the prohibition applies regardless of whether the offer is communicated directly or through a third party.
Do not use influencer content to communicate promotional offers on health services. Apply the same inducement test to influencer-communicated offers as to direct advertising.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Using a patient who is also an influencer to share their treatment experience
✅ COMPLIANT
Do not ask patients to create content about their treatment experience, regardless of their influencer status. The testimonial prohibition applies to the relationship and the content, not the label applied to the arrangement.
The enforcement context
AHPRA's automated monitoring tools scan social media for advertising by regulated health practitioners, including influencer content associated with practitioner accounts or services. In 2024–25, AHPRA assessed 775 advertising complaints — the monitoring scope includes third-party content where the practitioner is identifiable as the service being promoted.
Before you publish, check it.
CompliGUARD reviews practitioner influencer briefs and drafted content against AHPRA advertising prohibitions before posting.
Start free reviewRelated questions
Regulatory references
- Health Practitioner Regulation National Law, s.133
- AHPRA Guidelines for Advertising a Regulated Health Service, December 2020, s.4 (social media)
- ACCC Influencer Marketing Guidance