Can naturopaths use patient testimonials in advertising in Australia?
CompliGUARD reviews this compliance area against TGA · AHPRA · FSANZ · ACCC frameworks for Australian health brands — here's what the regulations say.
It depends on what the testimonial is about. Naturopaths can use client testimonials in service advertising if the testimonial does not include health outcome claims. Testimonials that name or imply a therapeutic good, describe a health condition being treated, or suggest a clinical outcome are prohibited under the TGA Advertising Code 2021, s.18, and restricted under NHAA and AHPRA advertising guidelines.
The rule: TGA Advertising Code 2021 and Australian Consumer Law, TGA Advertising Code 2021 s.18(1); ACL s.18; NHAA Advertising Guidelines
This is one of the most misunderstood areas of health advertising in Australia. The answer turns on a single distinction: is this a testimonial about a therapeutic good, or a testimonial about a health service? For testimonials involving therapeutic goods, the TGA Advertising Code 2021, s.18(1), prohibits advertising for therapeutic goods that contains a testimonial. This applies if your social media post, website, or newsletter advertises — or is likely to influence the use of — a specific supplement, herbal medicine, or ARTG-listed product. The prohibition is broad: a client saying "I started taking the magnesium [practitioner name] recommended and my sleep is completely different" constitutes a testimonial for a therapeutic good, even if the post is primarily about your practice. For testimonials about naturopath services, the Australian Consumer Law s.18 applies. Testimonials must be genuine, not misleading, and not create a false overall impression. A testimonial that implies a guaranteed clinical outcome — "She cured my IBS completely" — may constitute a misleading representation under s.18, even if the client genuinely wrote it. For NHAA members, the association's advertising guidelines are a condition of membership. These include provisions substantially similar to AHPRA's advertising guidelines, which prohibit any testimonial that creates an unrealistic expectation of benefit, implies that the practitioner's services are risk-free, or contains a claim that cannot be substantiated by acceptable evidence.
What this means in practice
- A testimonial that says "I loved working with [practitioner]" is generally low risk — it's a statement of satisfaction, not a health outcome claim.
- A testimonial that says "She sorted my hormones out in 6 weeks" is high risk — it implies a clinical outcome and references a body system, which may constitute a therapeutic representation.
- A testimonial that references a named supplement, herbal product, or ARTG-listed medicine is prohibited under the TGA Advertising Code, regardless of how the rest of the post is framed.
- Star ratings without written testimonials are generally lower risk but should still not be paired with clinical outcome language.
- The practitioner who publishes a testimonial is responsible for its content — not the client who wrote it. "My client wrote it, not me" is not a defence under the TGA Code or the ACL.
- Testimonials in paid social media advertising (boosted posts, Meta ads) carry the same compliance obligations as organic content.
Common mistakes
Reposting client success stories as "social proof"
A screenshot of a client message saying "I finally feel like myself again since seeing you" and posting it to Instagram constitutes publishing a testimonial. If your practice involves therapeutic goods or your profession involves clinical health outcomes, this requires assessment before it goes up.
Treat every client quote as a testimonial requiring review. Check whether it implies a health outcome or references a therapeutic good before reposting.
Using before-and-after imagery alongside testimonials
The combination of before/after images and testimonial language compounds the compliance risk. The TGA and ACCC both assess the overall impression an advertisement creates — a transformation image with a client quote creates an implied therapeutic outcome claim even without explicit wording.
Assess imagery and testimonial content together as a single advertisement. If the combined impression suggests a clinical outcome, do not publish without revision.
Assuming Google reviews are outside the Code
If a third-party review platform (Google, Facebook, Healthengine) displays a testimonial that names a product you recommend or implies clinical outcomes, and you actively direct patients to leave reviews there, the TGA takes the view that you may be responsible for the resulting content. The risk is context-dependent, but it is not zero.
Do not direct clients to leave reviews that reference products or clinical outcomes, and monitor third-party review platforms for content that creates this exposure.
Compliant vs non-compliant example
❌ NON-COMPLIANT
Reposting client success stories as "social proof"
✅ COMPLIANT
Treat every client quote as a testimonial requiring review. Check whether it implies a health outcome or references a therapeutic good before reposting.
The enforcement context
AHPRA assessed 775 advertising complaints in 2024/25 — up 104 per cent over two years. Testimonial-related breaches are among the most commonly cited issues. While AHPRA enforcement applies to registered practitioners (including dietitians), the TGA's testimonial prohibition under s.18 applies to advertising for therapeutic goods by anyone — regardless of registration status. TGA issued 147 infringement notices totalling $2.20M in 2023/24.
Before you publish, check it.
CompliGUARD reviews testimonial content, social posts, and practitioner advertising against TGA · AHPRA · FSANZ · ACCC automatically — flagging testimonial risk at clause level before you post.
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Regulatory references
- Therapeutic Goods Advertising Code 2021, s.18(1) — prohibition on testimonials in therapeutic goods advertising
- Australian Consumer Law (Competition and Consumer Act 2010, Schedule 2), s.18 — prohibition on misleading or deceptive conduct
- AHPRA Advertising Guidelines, December 2020, s.3 — testimonial restrictions for registered health practitioners
- NHAA Advertising Guidelines (current edition) — testimonial and outcomes claim restrictions for members
CompliGUARD provides compliance insights based on TGA, FSANZ, ACCC and AHPRA guidance as current at the time of review. The Therapeutic Goods Advertising Code is currently under formal review by the TGA (2025–26). CompliGUARD assessments reflect the current Code; guidance may be subject to change. This content does not constitute legal advice.