TGA releases new guidance on advertising restrictions for prescription medicines: what it means for practitioners and health businesses (2026)

The TGA has released two related guidance documents that should be read together.

The first — Complying with the restrictions on advertising prescription medicines to the public — provides practical examples of the types of advertising and promotional activities likely to be prohibited. It covers websites and social media content, business names and logos, booking systems, product catalogues, price information, and other promotional materials. The guidance provides specific examples to help individuals and businesses understand where the line sits.

The second — Advertising health services that involve therapeutic goods — addresses a specific enforcement concern: the promotion of health services designed to give consumers access to particular prescription medicines. Online and telehealth services that effectively advertise a specific prescription medicine through the vehicle of promoting a health service are within scope of the restriction. The update to this guidance reflects TGA concerns about the way some service providers have attempted to promote prescription-only products indirectly.

Both documents are available on the TGA's website here

Under subsections 42DL(10) and 42DLB(7) of the Therapeutic Goods Act 1989, advertising a prescription medicine to the public is prohibited apart from limited circumstances. The same rules apply to substances in Schedule 3 (pharmacist-only medicines), Schedule 4 (prescription-only medicines), and Schedule 8 (controlled drugs) to the Poisons Standard, unless included in Appendix H. The restriction applies to any person who causes an advertisement to be published — not just the medicine's sponsor or manufacturer.

The guidance identifies common examples of health services that risk unlawfully promoting prescription medicines: cosmetic injectables, peptides, weight loss injections, medical cannabis, IV drip therapies, and erectile dysfunction medicines.

For practitioners and health businesses operating in any of these categories, the updated guidance makes several things explicit:

Indirect references count. The prohibition applies not only to product or brand names (such as Botox or Ozempic) but to substitute terms and class descriptions — "weight loss injections", "wrinkle reduction injections", "plant-based medicine" — where, viewed in context, they refer to a prescription medicine. This applies even if no specific product or substance is named.

Images and designs count. The guidance lists graphics of syringes, applicator pens, vials, capsules, pills, and cannabis leaves as examples of pictorial representations that impliedly refer to a prescription medicine, including in business logos.

Price information for prescription medicines is generally advertising. Listing prices for treatments or services that involve or reference prescription medicines — whether as a total cost or cost per unit — is likely to amount to advertising those medicines. Price lists are permitted only in very limited circumstances under the Code.

Booking systems and product catalogues count. A booking system that lists prescription medicines by name as treatments, or a catalogue that lets consumers browse available medicines for a condition, may amount to advertising those medicines.

Content behind a login or paywall is still advertising to the public. Requiring users to create an account, become a member, or pay a fee does not exempt promotional content from the restrictions.

The update to the health services guidance is the most operationally significant change for telehealth and online service providers. The guidance states that materials promoting a health service — including via telehealth — as a way to obtain specific prescription medicines are likely to amount to unlawful advertising of those medicines. This includes advertising that indicates a health service can supply or facilitate supply of specific medicines, can provide prescriptions for them, or offers consultations where the advertising implies a prescription could or will result.

The guidance gives concrete examples. A pain management clinic that promotes a consultation with a "specialist medicinal cannabis prescriber" is likely unlawfully advertising medicinal cannabis. A wellness centre that promotes hair-loss treatment services while naming finasteride is likely advertising a prescription medicine. A cosmetic clinic that presents cosmetic injectables as a way to "smooth your fine lines and wrinkles" may be unlawfully advertising botulinum toxin. A pharmacy that promotes a UTI service by stating patients can "get the antibiotics you need without visiting a GP" is promoting the supply of prescription medicines.

The guidance also confirms that a questionnaire, checklist, symptom checker, or chatbot that suggests a prescription can be issued for a condition based on automated responses is likely advertising. The vehicle of the promotion — a service booking page, a social media post, a business name, or an automated tool — does not change the analysis.

Beyond the core channels, the guidance identifies several activities that practitioners and businesses may not realise are caught.

Direct marketing to former patients. A cosmetic clinic that emails former patients with information about injectable products available at the clinic — including treatment options, benefits, and prices — is given as a non-compliant example. Because the email is not information shared during the course of treatment, it is not exempt from the advertising restrictions. Mass communications such as emails, text messages, or webinars are unlikely to be exempt.

Linking to third-party content. Linking to external websites, articles, or research papers that promote the use or supply of a specific prescription medicine — or re-sharing social media posts and testimonials — can cause a business's own material to be considered advertising of that medicine, when viewed in context.

Before-and-after photos. Health service providers are not prohibited from using before-and-after photos to advertise a health service. However, where it is expressly or implicitly suggested that the "after" result is due to a prescription medicine, this is likely to amount to advertising that medicine.

Testimonials and endorsements. Using testimonials or endorsements about a prescription medicine is likely to be unlawful advertising of that medicine. Separately, the Advertising Code prohibits testimonials and endorsements about therapeutic goods by certain people, including health practitioners, and the Health Practitioner Regulation National Law prohibits the use of testimonials in advertising a regulated health service.

Influencers and content creators. The guidance confirms that informal, lifestyle-based social media content can still be advertising. Indirect references — "anti-wrinkle", "lip injections", "weight-loss shots" — tags, links, discount codes, and content implying the effect of a prescription medicine are all likely to be caught. Responsibility for compliance may extend to both the clinic and the content creator.

The guidance is equally clear about what practitioners can do. Promoting the type of consultation a service offers, or the medical conditions a service treats, without directly or indirectly referring to therapeutic goods, is unlikely to constitute advertising of those goods. The guidance gives the example: "Call our clinic for a consultation to discuss treatment options for migraine" does not refer to therapeutic goods and is unlikely to breach.

Information given by a health practitioner directly to a patient in the course of treating that patient is also not subject to the prohibition — though this exception requires an established practitioner-patient relationship and does not extend to publicly accessible content or mass communications to prospective patients.

The updated guidance is directly relevant to:

• Registered health practitioners — including nurses, cosmetic doctors, general practitioners, and pharmacists — who advertise services involving prescription medicines on their websites, social media, or booking platforms.
• Telehealth and online health service providers whose platforms or marketing reference specific prescription medicines or their effects.
• Clinics and health businesses in the cosmetic, weight loss, sexual health, medical cannabis, and IV therapy categories — where specific prescription medicines are a core part of the service offering and the marketing.
• Marketing agencies and content creators producing advertising for any of the above.
• Social media influencers who promote health services involving prescription medicines — the prohibition applies to any person who causes an advertisement to be published, not only the business providing the service.

The Therapeutic Goods Advertising Code is currently under formal review by the TGA (2025–26). This content reflects TGA guidance current at the time of review and does not constitute legal advice. Regulatory responsibility rests with the advertiser. For specific advice on compliance obligations for your business or practice, 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.