What advertising rules apply to naturopaths 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 naturopath advertising against the Australian Consumer Law and TGA Advertising Code. Naturopaths are not registered with AHPRA, meaning AHPRA's s.133 advertising prohibitions do not directly apply — however, naturopath advertising is governed by the Australian Consumer Law's prohibition on misleading conduct, TGA Advertising Code rules where therapeutic goods are promoted, and the advertising standards of their professional association (NHAA or ATMS).
The rule: Australian Consumer Law / Therapeutic Goods Advertising Code 2021, ACL s.18 and s.29; TGAC 2021; NHAA/ATMS Member Advertising Standards
Naturopathy is not a nationally registered profession under the Health Practitioner Regulation National Law — naturopaths are not AHPRA-registered and s.133's specific advertising prohibitions (testimonials, unrealistic expectations, superiority claims, inducements) do not apply as a matter of law. However, naturopath advertising is subject to the Australian Consumer Law, which prohibits misleading or deceptive conduct in trade or commerce and applies to all health service businesses regardless of registration status. Where naturopaths sell, recommend, or promote therapeutic goods (Listed Medicines, herbal products), the TGA Advertising Code 2021 applies to that promotion. Most professional associations for naturopaths — including NHAA and ATMS — have adopted advertising standards that mirror or extend AHPRA's prohibitions as conditions of membership.
What this means in practice
- Apply ACL substantiation standards to all health claims in advertising — every claim must be accurate, capable of substantiation, and not likely to mislead a reasonable consumer.
- Where advertising promotes specific therapeutic goods (supplements, herbal medicines, Listed Medicines), comply with TGA Advertising Code requirements including mandatory statements and permitted claim rules.
- Check your professional association's advertising standards — NHAA and ATMS both publish advertising guidelines that members are required to follow as a condition of membership.
- Avoid patient outcome stories that imply typical or guaranteed results — while the AHPRA testimonial prohibition does not apply directly, using outcome stories in advertising can constitute misleading conduct under ACL s.18.
- For PHI rebate recognition: PHA's framework references ACL advertising compliance as a provider recognition criterion — apply the same substantiation standard regardless of AHPRA registration status.
Common mistakes
Assuming 'not AHPRA-regulated' means advertising is unrestricted
The ACL applies to all businesses — not only AHPRA-registered practitioners. Misleading health claims, unsubstantiated outcome promises, and false comparative claims are all prohibited under ACL s.18 regardless of professional registration status. The ACCC has investigated complementary health practitioners for misleading advertising.
Apply the ACL misleading conduct test to all advertising content: would a reasonable consumer be misled by this claim? If yes, do not use it — regardless of AHPRA registration status.
Using patient outcome testimonials freely because 'naturopaths aren't regulated by AHPRA'
While AHPRA's testimonial prohibition does not apply directly, patient outcome stories used in advertising can constitute misleading conduct under the ACL where they imply typical or guaranteed outcomes. The ACCC applies this standard to all health service advertising.
Treat testimonial-style content with the same caution as an AHPRA-registered practitioner would. Replace outcome stories with educational content about your approach, training, and the conditions you work with.
Promoting herbal or supplement products without TGA mandatory statements
Where a naturopath recommends, sells, or promotes specific Listed Medicines or ARTG-listed products in their advertising, the TGA Advertising Code applies — including mandatory statement requirements for AUST numbers and 'always read the label.'
Identify all therapeutic goods promoted in advertising and apply TGA Advertising Code requirements to each. The naturopath's lack of AHPRA registration does not exempt them from TGA obligations.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Assuming 'not AHPRA-regulated' means advertising is unrestricted
✅ COMPLIANT
Apply the ACL misleading conduct test to all advertising content: would a reasonable consumer be misled by this claim? If yes, do not use it — regardless of AHPRA registration status.
The enforcement context
The ACCC has taken action against complementary health practitioners and businesses for misleading health claims. The TGA has pursued naturopaths and natural health businesses for advertising therapeutic goods in breach of the Advertising Code. From July 2025, PHA's PHI rebate recognition framework adds a commercial consequence to ACL non-compliance — non-compliant advertising risks fund recognition status for rebate-eligible modalities.
Before you publish, check it.
CompliGUARD reviews naturopath advertising against ACL requirements and TGA Advertising Code obligations — the compliance standard referenced in PHA's PHI rebate recognition framework.
Start free reviewRelated questions
Regulatory references
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18 and s.29
- Therapeutic Goods Advertising Code 2021 (Cth)
- ACCC Advertising and Selling Guide, July 2021
- NHAA Advertising Standards (applicable to NHAA members)
- ATMS Code of Conduct — Advertising Standards (applicable to ATMS members)
- Private Healthcare Australia — Natural Therapies Reintroduction Framework (2025)