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    Can AHPRA-registered practitioners offer discounts or promotions?

    CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.

    CompliGUARD reviews practitioner promotions and discounts against AHPRA's inducement rules under the National Law. Practitioners can offer discounts and promotions but must ensure they do not constitute inducements that encourage a person to seek health services they may not need — this is prohibited under s.133(1)(e) of the Health Practitioner Regulation National Law.

    The rule: Health Practitioner Regulation National Law, s.133(1)(e) and AHPRA Advertising Guidelines s.3.5

    Section 133(1)(e) of the Health Practitioner Regulation National Law prohibits advertising that uses an inducement to encourage a person to use the health service where that inducement may not be in the person's best interests — specifically, where it could encourage them to seek services they do not need. AHPRA's Guidelines s.3.5 provide that gifts, discounts, and competitions can constitute prohibited inducements. The test is not whether a discount exists, but whether the promotion — in context — could encourage a person to seek treatment they may not need.

    What this means in practice

    • Avoid urgency-framed promotions — 'book this week only' or 'limited spots at this price' create pressure to book that may not be driven by clinical need.
    • Avoid promotions that incentivise additional appointments — multi-pack or bundle offers can imply that more treatment is better, regardless of clinical indication.
    • General availability promotions for new patients (introductory pricing) are lower risk than time-limited urgency promotions — but review them case by case.
    • Do not run competitions or prize draws where entry requires booking an appointment or purchasing services.
    • Frame all promotions as making existing services accessible, not as reasons to seek services the patient may not have considered.

    Common mistakes

    Mistake

    "Book this week and get 20% off your first appointment"

    Problem

    A time-limited discount that creates urgency to book may constitute an inducement to seek treatment before assessing clinical need — the pressure element is what AHPRA targets, not the discount itself.

    Fix

    Remove urgency framing. An introductory rate that applies to all new patients without a deadline is lower risk: 'New patient consultation rate: $X.'

    Mistake

    Offering a 'free treatment' as a prize or referral incentive

    Problem

    Competitions or referral programmes where the reward is a free or discounted treatment session constitute an inducement to seek a health service — this is prohibited regardless of the promotional format.

    Fix

    If running a competition or referral programme, ensure the prize is unrelated to clinical services — a product gift, not a treatment session.

    Mistake

    Running bulk-buy treatment packages ('buy 5 sessions, get 1 free')

    Problem

    Bundle pricing that incentivises purchasing more treatment than has been clinically assessed as necessary may constitute an inducement under s.133(1)(e). This is especially high risk for musculoskeletal or allied health services.

    Fix

    Where packages are offered, ensure they are framed as a payment option for a clinically indicated course of treatment — not as a purchasing incentive.

    Compliant vs non-compliant example

    ❌ NON-COMPLIANT

    "Book this week and get 20% off your first appointment"

    ✅ COMPLIANT

    Remove urgency framing. An introductory rate that applies to all new patients without a deadline is lower risk: 'New patient consultation rate: $X.'

    The enforcement context

    Inducement-related advertising complaints are consistently investigated by AHPRA's advertising compliance team. The 104% increase in complaints assessed in 2024–25 reflects broader public awareness of the reporting mechanism — including awareness by competing practitioners. Promotions that appear on social media are especially visible to both AHPRA monitoring tools and competitor complainants.

    Before you publish, check it.

    CompliGUARD reviews practitioner promotional content against AHPRA Guidelines s.133(1)(e) for inducement risk.

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    Related questions

    Regulatory references

    • Health Practitioner Regulation National Law, s.133(1)(e)
    • AHPRA Guidelines for Advertising a Regulated Health Service, December 2020, s.3.5
    • AHPRA Advertising Compliance and Enforcement Policy