Testimonials, endorsements, and product advertising online: what practitioners can and cannot post (2026)

Most practitioners who breach advertising rules online did not set out to do anything wrong. The practitioner who reposted a patient's five-star Google review, shared an unboxing of a supplement they genuinely love, or published a before-and-after image of a client who consented to it — each was acting in good faith. The problem is that good faith is not the test the regulators apply.

The test is whether the content breaches the applicable framework. And for practitioners operating in Australia, there are up to four frameworks that can apply simultaneously to a single Instagram post — AHPRA's Guidelines, state and territory Codes of Conduct, the TGA Advertising Code, and the Australian Consumer Law. Understanding where each applies is not optional. It is the starting point for managing the risk.

Before posting anything about your services or a product you use or recommend, ask three questions in order.

Question 1: Is the post about a regulated health service or therapeutic good?
If yes, the Health Practitioner Regulation National Law s.133 and the TGA Advertising Code apply. Both may apply simultaneously to the same piece of content.

Question 2: Is the advertising in your control?
Your website, social media accounts, and email list are platforms you control. You are the advertiser for the purposes of everything published on them. Content you control is content you are responsible for.

Question 3: Does it reference a clinical aspect?
A clinical aspect means a symptom, a diagnosis, a treatment, or an outcome. If a comment references any of these, it meets the definition of a testimonial for AHPRA and equivalent Code of Conduct purposes. All three elements present — regulated service, your platform, clinical reference — means a prohibited testimonial.

One important clarification: not all positive comments are testimonials. A comment about your team being friendly, your clinic being easy to book, or your communication being prompt contains no clinical aspect. These are not testimonials under the National Law and are not prohibited.

This is the rule most practitioners do not know exists — and the one with the broadest practical reach.

Section 24(6) of the Therapeutic Goods Advertising Code prohibits health practitioners from endorsing therapeutic goods in advertising. Registered practitioners are captured by s.24(6)(d). Unregistered practitioners who present themselves as qualified to diagnose or treat are captured by s.24(6)(e).

The prohibition is categorical. It applies regardless of whether the product was purchased, gifted, or provided at no cost. It applies to personal social media accounts where a practitioner identifies themselves by their profession. It applies to unboxing videos, product recommendations, and testimonial-style content about supplements, herbal medicines, and any other Listed or Registered Medicine.

A naturopath who posts "as a practitioner, I take this magnesium supplement every day and recommend it to all my clients" is not sharing a personal opinion — they are providing a practitioner endorsement of a therapeutic good. Under s.24(6)(e), that endorsement is prohibited.

The brand whose product is featured also carries a compliance obligation: sponsors are required to take reasonable steps to address non-compliant third-party content associated with their products. A well-intentioned practitioner post can trigger a compliance response from the brand — not because the endorsement is not valued, but because the brand needs to manage its own TGA exposure.

For AHPRA-registered practitioners, the prohibition on using clinical patient testimonials in advertising is absolute under s.4.3 of the AHPRA advertising framework. The prohibition applies regardless of patient consent, anonymisation, or positive framing.

State and territory Codes of Conduct apply an equivalent prohibition to unregistered practitioners providing health services. The framework is described differently across jurisdictions — Schedule 3 in NSW, the National Code of Conduct for Health Care Workers in QLD, TAS, and SA, the General Health Service Providers Code in VIC, and equivalent provisions in WA, ACT, and NT where applicable. The substantive prohibition on clinical testimonials is consistent across these frameworks, but practitioners should confirm the specific instrument that applies in their state or territory.

The following are prohibited testimonials regardless of format: written patient outcome accounts on a practice website, video content featuring a patient describing their treatment experience, parent testimonials about a child's progress, reposted Google or Facebook reviews where the content includes a clinical reference, and case studies describing a specific patient's condition and response to treatment.

The following are not prohibited: comments about booking ease, communication, clinic environment, or staff friendliness — provided no clinical aspect is referenced.

The statutory source is s.133(1)(c) of the Health Practitioner Regulation National Law, which prohibits advertising of a regulated health service that uses testimonials or purported testimonials about the service or business. It applies to all 15 AHPRA-registered professions and to every advertising channel, including websites, social media and Google Business profiles. Penalties reach $60,000 per offence for individuals, and AHPRA uses automated digital monitoring tools to scan practitioner websites and social media.

• Reposting reviews: you may respond to a review on the platform where it was posted, but screenshotting, quoting or reposting it as your own content incorporates it into your advertising.
• Anonymised case studies: a case study describing a patient's experience or outcome is still a testimonial. Replace it with educational content about the condition, the treatment approach and the evidence base.
• Video without narration: footage of a patient doing activities they previously could not perform may still function as a testimonial if the context implies a treatment outcome.
• The reasonable-person test: would a reasonable person viewing the content understand it as a patient endorsing the health service? If yes, do not publish it.
• Brief your team: tell your social media manager that patient stories, outcome case studies and quotes attributed to patients are all prohibited testimonial forms.

Supplement brands face a different testimonial rule under TGA Advertising Code s.24 — see testimonials in supplement advertising.

Clinical patient testimonials used in own advertising (e.g. "I came in with anxiety and I'm so much better")

• AHPRA-registered: ❌ Prohibited — s.4.3. Patient experiences referencing symptoms, diagnoses, or outcomes cannot be used to promote a regulated health service, regardless of consent.
• Non-AHPRA practitioner (state/territory Code of Conduct): ❌ Prohibited — equivalent prohibition applies under NSW Schedule 3, the National Code of Conduct for Health Care Workers (QLD, TAS, SA), and the General Health Service Providers Code (VIC).
• TGA Advertising Code: ❌ Prohibited.
• ACL: ⚠️ Permissible only if genuine and does not imply typical outcomes — prohibited if fake, undisclosed, or misleading in context.

Non-clinical positive comments on practitioner-controlled platforms (e.g. "The team is lovely and easy to book")

• All frameworks: ✅ Permissible — no clinical aspect, no therapeutic claim.

Patient reviews on third-party platforms the practitioner does not control (e.g. Google Reviews)

• AHPRA and state/territory Codes of Conduct: ✅ Not the practitioner's responsibility — the prohibition applies to advertising the practitioner controls. Unsolicited reviews on platforms you do not control are not your advertising.

Practitioner personally endorsing a specific therapeutic product

• All frameworks: ❌ Prohibited — s.24(6)(d)–(e) TGA; AHPRA and state/territory Code of Conduct where clinical authority is implied; ACL where the endorsement implies independent clinical validation that may be false.

Gifted product testimonial (product received in exchange for posting)

• TGA: ❌ Prohibited — s.24(4). Valuable consideration includes products, discounts, and any non-monetary benefit received in exchange for the testimonial.
• ACL: ❌ Must be disclosed and genuine — failure to disclose the commercial arrangement renders the testimonial misleading by omission under s.18 and s.29.

Selectively publishing only positive reviews, suppressing negative ones

• AHPRA: ⚠️ High risk — s.133(1)(a). Selectively edited or published testimonials are explicitly named as high risk under AHPRA guidelines.
• TGA: ⚠️ High risk — s.24(3). Testimonials implying typical outcomes must be consistent with results expected on average by consumers.
• ACL: ❌ Potentially prohibited — selective publication creates a false overall impression of patient outcomes under s.18.

Fake testimonials or reviews not made by genuine clients

• All frameworks: ❌ Prohibited across every applicable framework.

Before-and-after images showing clinical outcomes attributed to treatment

• AHPRA: ⚠️ High risk — s.4.4 and s.4.3. Permissible only if strict conditions regarding lighting, angle, posture, and editing are met.
• TGA: ❌ Where treatment outcome is attributed to a listed or registered product.
• ACL: ❌ Where imagery implies typical outcomes — a representation about efficacy.

The Australian Consumer Law applies to all testimonials and reviews used in advertising, independently of AHPRA and TGA obligations. Under s.18, conduct in trade or commerce that is misleading or deceptive is prohibited. Under s.29, false or misleading representations about the standard or quality of services are prohibited.

Three specific ACL risks apply to practitioner advertising:

Fake reviews — fabricated testimonials breach the ACL regardless of platform or format, and regardless of whether any AHPRA or TGA obligation is also engaged.

Undisclosed commercial arrangements — where a practitioner receives payment, free products, or any other consideration in exchange for a review or recommendation, that relationship must be disclosed. Presenting a paid or gifted endorsement as an organic personal recommendation is misleading by omission.

Selective suppression — publishing only positive reviews while suppressing negative ones creates a false overall impression of outcomes. The ACCC has specifically identified review manipulation as a priority enforcement area.

State Codes of Conduct for unregistered practitioners vary by jurisdiction. NSW refers to Schedule 3; QLD, TAS, and SA use the National Code of Conduct framework; VIC uses the General Health Service Providers Code; WA applies the ACL as the baseline obligation where no equivalent harmonised code exists. This content does not constitute legal advice. For binding interpretations, consult a qualified regulatory professional.

• Publishing without checking the complete advertisement’s overall impression.
• Treating one regulator’s checklist as coverage for every applicable framework.
• Failing to retain evidence showing what was reviewed and approved before publication.

CompliGUARD reviews the complete advertisement against TGA · AHPRA · FSANZ · ACCC requirements, identifies clause-level risks, proposes compliant wording, and retains the result in an audit trail before publication.