What advertising rules apply to massage therapists 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 massage therapist advertising against the Australian Consumer Law and professional association standards. Massage therapists are not registered with AHPRA — advertising is governed by the Australian Consumer Law, the Schedule 3 Code of Conduct for unregistered health practitioners in states and territories that have adopted it, TGA Advertising Code rules where therapeutic goods are promoted, and the advertising standards of any professional association the therapist belongs to (ATMS, AMT, or AAMT).
The rule: Australian Consumer Law / Schedule 3 Code of Conduct / Professional Association Standards, ACL s.18 and s.29; HPRNL Schedule 3; ATMS/AMT/AAMT Member Advertising Standards
Massage therapy is not a nationally registered profession under AHPRA — the title is not protected and s.133 advertising prohibitions do not apply directly. However, massage therapists providing health services are subject to the Schedule 3 Code of Conduct for unregistered health practitioners under the Health Practitioner Regulation National Law, in all states and territories that have adopted it (NSW, QLD, SA, WA, TAS, ACT, NT). Schedule 3 imposes conduct obligations including requirements relevant to advertising, enforced by state and territory health complaints bodies. All massage therapist advertising is also subject to the ACL. Professional associations including the Australian Traditional Medicine Society (ATMS), the Australian Massage Therapy Association (AMTA), and the Association of Massage Therapists (AMT) publish advertising standards that are binding on members as conditions of membership.
What this means in practice
- Understand that Schedule 3 of the Health Practitioner Regulation National Law applies to you as an unregistered health practitioner providing health services in most Australian states and territories.
- Check your professional association's advertising standards — ATMS, AMTA, and AMT all publish advertising conduct requirements for members.
- Apply ACL substantiation requirements to all health claims — every claim about the therapeutic benefits of massage must be accurate and capable of substantiation.
- Do not use patient outcome stories that imply typical or guaranteed results — these can constitute misleading conduct under ACL s.18 even without AHPRA's testimonial prohibition applying.
- Where promoting or selling therapeutic goods (massage oils, topical products listed on the ARTG), apply TGA Advertising Code requirements to those product promotions.
Common mistakes
Making therapeutic outcome claims without substantiation
Claims that massage therapy treats or resolves specific medical conditions — chronic pain, anxiety, fibromyalgia, sports injuries — require peer-reviewed evidence to substantiate under the ACL. Without that evidence, such claims are misleading under s.18 regardless of the practitioner's clinical experience.
Frame massage services as supporting general wellbeing and relaxation, or as complementary to medical care for specific conditions, without implying the massage intervention alone treats or resolves a medical condition.
Ignoring Schedule 3 obligations because massage is not AHPRA-registered
Schedule 3 applies to unregistered health practitioners providing health services — including massage therapists. Conduct complaints can be made to state and territory health complaints bodies and can result in prohibition orders preventing practice.
Familiarise yourself with the Schedule 3 Code of Conduct in your state or territory and apply its conduct standards as a baseline obligation alongside your professional association requirements.
Using 'remedial' or 'clinical' massage claims without substantiation
Describing a massage service as 'remedial' or 'clinical' implies a therapeutic or medical level of intervention. Where the evidence does not support the specific therapeutic claims being made, these descriptors can create misleading impressions under ACL s.29.
Where using 'remedial' or 'clinical' descriptors, ensure the specific therapeutic claims attached to those services are substantiated and not misleading in context.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Making therapeutic outcome claims without substantiation
✅ COMPLIANT
Frame massage services as supporting general wellbeing and relaxation, or as complementary to medical care for specific conditions, without implying the massage intervention alone treats or resolves a medical condition.
The enforcement context
State and territory health complaints bodies have powers to investigate conduct complaints against massage therapists under Schedule 3 and can issue prohibition orders. The ACCC monitors health service advertising under the ACL — including massage therapy advertising making unsubstantiated therapeutic claims. Professional associations including ATMS have formal conduct and complaints processes for members.
Before you publish, check it.
CompliGUARD reviews massage therapist advertising against ACL requirements and Schedule 3 conduct standards.
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Regulatory references
- Health Practitioner Regulation National Law, Schedule 3 — Code of Conduct for Unregistered Health Practitioners
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18 and s.29
- ATMS Code of Conduct — Advertising Standards (applicable to ATMS members)
- AMT Code of Practice (applicable to AMT members)
- ACCC Advertising and Selling Guide, July 2021