The TGA advertising compliance checklist explained — and what Australian health brands use alongside it (2026)

Australian health brands face a compliance problem that didn't exist a decade ago: the volume and speed of digital advertising. A practitioner posting three times a week to Instagram, a supplement brand running split-tested Meta ads, a wellness company sending a weekly email newsletter — each piece of content needs to be checked before it goes live. The consequence of skipping that check has become measurably expensive. In 2023–24, the TGA issued 4,806 removal requests for non-compliant advertising, 147 infringement notices totalling $2.20 million, and 168 warning letters. AHPRA assessed 775 advertising complaints in 2024–25, up 104% in two years.

The question most marketing teams ask is not whether to check their advertising — it is what to check it against, and how.

The TGA publishes an advertising compliance self-assessment checklist specifically for consumer advertising of therapeutic goods. It is available at tga.gov.au and covers the primary requirements under the Therapeutic Goods Advertising Code 2021 (TGAC 2021).

The checklist walks through the major compliance categories:

1. General requirements (TGAC 2021, Part 3) — Does the advertisement include mandatory statements such as "Always read the label and follow the directions for use"? Does it include the AUST L or AUST R number where required? Does it avoid prohibited representations such as claims about serious diseases listed in Schedule 4 of the Code?

2. Claim and evidence requirements (TGAC 2021, s.12–s.18) — Are therapeutic claims consistent with the product's approved indication as listed on the ARTG? Are claims supported by acceptable evidence? Does the advertisement avoid implying effectiveness not established by evidence?

3. Prohibited content (TGAC 2021, Part 5) — Does the advertisement avoid testimonials that breach the Code? Does it avoid comparative advertising that denigrates other products? Does it avoid creating unrealistic expectations of beneficial treatment?

The self-assessment checklist is a binary review — it helps you identify whether specific required elements are present or absent. It is not designed to review the actual wording of marketing copy, and it does not identify whether a specific claim (for example, "supports immune function", "helps you sleep", or "promotes healthy digestion") is an approved indication for the specific product being advertised.

There is also a second TGA tool — the interactive question-and-answer guide "Can I advertise this therapeutic good to the public?" — which helps brands determine whether their product category is permitted for consumer advertising at all. This is the first check, not the last.

The AHPRA self-assessment tool is the equivalent resource for regulated health practitioners — chiropractors, naturopaths, osteopaths, physiotherapists, psychologists, and other registered health professions under the National Law.

It covers the advertising requirements under the Health Practitioner Regulation National Law 2009, s.133, including:

• Prohibition on misleading or deceptive advertising
• Prohibition on creating unreasonable expectations of beneficial treatment
• Prohibition on testimonials (under s.133(1)(c)) for treatment outcomes
• Requirements around use of protected titles and professional designations
• Restrictions on gift, discount, and inducement advertising

The AHPRA self-assessment tool is structured as a checklist that practitioners complete for a specific advertisement. Like the TGA checklist, it assesses whether your advertising meets categorical requirements — but it does not review your actual copy line by line, and it does not flag whether a specific claim crosses into the territory of a testimonial or a misleading health claim.

Naturopaths, in particular, face a dual compliance challenge: their advertising may need to comply with both AHPRA requirements (as a registered health practitioner) and TGA requirements (if they are advertising listed complementary medicines or therapeutic devices to consumers). The official self-assessment tools address each framework separately.

Both TGA and AHPRA self-assessment tools answer the question: "Does my advertisement meet the structural requirements of this Code?" They do not answer the question: "Is the specific language in this copy compliant?"

That gap matters in practice. The most common compliance failures in Australian health advertising are not structural — they are in the language of specific claims. Phrases like "clinically proven", "the most effective", "guaranteed results", "our customers have reported", or "fights infection" each carry specific compliance implications under different frameworks. A checklist cannot flag these because it does not read the copy.

The second gap is multi-framework coverage. A single piece of health marketing content may need to comply with the TGA Advertising Code (if it references a therapeutic good), AHPRA guidelines (if it is published by a registered practitioner), FSANZ Standard 1.2.7 (if it references a food health claim), and the ACCC Advertising and Selling Guide (if it makes comparative or testimonial claims). No single official checklist covers all four frameworks simultaneously.

The third gap is audit trail. Official checklists do not produce a timestamped record of compliance review. For brands with high advertising volume — or for practitioners responding to an AHPRA compliance investigation — a documented pre-publication compliance review process is evidence of due diligence. A completed checklist saved to a shared drive is a start. A timestamped compliance report attached to each piece of content is defensible.

A practical compliance workflow for Australian health brands combines official tools with systematic copy review:

Step 1 — Eligibility check (TGA). Use the TGA's "Can I advertise this therapeutic good to the public?" tool to confirm the product category is eligible for consumer advertising. This is a one-time check per product type, not a per-ad review.

Step 2 — Structural compliance check (TGA or AHPRA). Use the relevant official self-assessment checklist to confirm your advertisement includes all required elements and avoids categorically prohibited content. The TGA checklist applies to therapeutic goods advertising; the AHPRA tool applies to practitioner advertising.

Step 3 — Copy-level compliance review (multi-framework). Review the actual wording of your marketing content against TGA, AHPRA, FSANZ and ACCC requirements. This is where most compliance failures occur and where official checklists stop. For brands publishing frequently, this step is where compliance infrastructure becomes operationally necessary.

Step 4 — Document the review. Record what was checked, what was changed, and when. For a single ad reviewed occasionally, a saved checklist may suffice. For a brand publishing multiple pieces of content weekly, a systematic audit record is the difference between evidence of due diligence and an unsupportable compliance position.

CompliGUARD provides compliance and creative marketing 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 output does not constitute legal advice.

• 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.