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AHPRA s.133 + TGA

Advertising Compliance Review

Licet — an educational resource to help you understand AHPRA and TGA advertising standards. Covers IV infusion therapy, cosmetic injectables, skin treatments, and all regulated health services. Eight tools: Compliance Checker, Evidence Checker, Promotions, TGA Schedule, Before/After, Influencer/UGC, Titles, and Scope of Practice.

Regulator
AHPRA & National Boards
Legislation
National Law s.133
Analysis
Regex + AI + Letter
Enforcement letter / specific undertakings
Layer 3

Attach your AHPRA enforcement letter or agreed undertakings. Every check will be cross-referenced against your specific obligations.

Drop file here or browse
PDF, Word (.docx), or plain text — max 10MB
Content to review
0 characters
Review history
0 checks
No checks run yet.
Audit trail
Layer 5
No checks recorded yet.
Product name checker
New

AHPRA flags treatment names that imply benefit — "Immunity", "Weight Loss", "Energy Support". Check any name before using it.

Google review checker
New

Responding to reviews that mention clinical outcomes incorporates them as testimonials in your advertising. Check before responding.

Analysis layers
Layer 1 — Regex pattern scan 40+ patterns drawn from AHPRA s.133, TGA Act, and published AHPRA enforcement guidance.
Layer 2 — Claude AI semantic review Overall impression, paraphrased violations, implied claims.
Layer 3 — Enforcement letter cross-check Cross-references your specific AHPRA obligations and agreed undertakings.
Layer 5 — Audit trail Timestamped log of every check. Exportable as CSV for compliance records.
Layer 7 — Compliant rewrite AI-generated compliant alternative for any flagged content.
Rules applied
Reference sources
AHPRA
Advertising guidelines for registered health practitioners
ahpra.gov.au
Guidelines for advertising regulated health services
ahpra.gov.au
Testimonials and reviews guidance
ahpra.gov.au
Claims about quality of services
ahpra.gov.au
Social media advertising guidance
ahpra.gov.au
AHPRA advertising self-check tool
ahpra.gov.au
Legislation
Health Practitioner Regulation National Law — s.133
legislation.gov.au
Therapeutic Goods Act 1989
legislation.gov.au
TGA
Advertising therapeutic goods — regulatory framework
tga.gov.au
Mandatory requirements for advertising to consumers
tga.gov.au
Platform policies
Google Ads — Healthcare and medicines policy
support.google.com
Meta Ads — Health and wellness policy
facebook.com
AHPRA Compliance Assistant
Ask about rules, flags, or rewrites
Hi — I can answer questions about AHPRA s.133, TGA advertising rules, or explain any flags from your last compliance check. What would you like to know?

Research Evidence Checker

Upload or paste a research article. Claude assesses it against the six AHPRA acceptable evidence factors and tells you whether it can support an advertising claim — and how to frame it if so.

Framework
AHPRA Acceptable Evidence
Factors assessed
Source, Relevance, Inclusion, Level, Quality, Strength
Guidance
AHPRA evidence guidance ↗
Research article or document
Be specific. The more precisely you state the claim, the more accurately it can be assessed.
Drop file here or browse
PDF, Word (.docx), or plain text — max 10MB
AHPRA evidence factors
Full guidance ↗
Automatically unacceptable

AHPRA states these will never constitute acceptable evidence for advertising claims:

Animal studies / in vitro studies (no human subjects)
Before-and-after studies with few or no controls
Self-assessment studies
Anecdotal evidence / single case reports
Uncontrolled audits or outcome studies
Studies not applicable to your target population
Assessment history
0 assessments
No assessments run yet.

Promotion & Inducement Checker

Under s.133(1)(b) of the National Law, gifts, discounts and inducements are only lawful if terms and conditions are stated clearly alongside them. This tool checks whether your promotion is lawful, and if so, whether the T&Cs are complete and compliant.

Your promotion
s.133(1)(b) — Inducement rules

Any gift, discount or other inducement offered to attract a person to use a regulated health service must state the terms and conditions of the offer alongside it.

Always prohibited
Free IV as a prize, competition entry, or bundled add-on without clinical indication. Group deals encouraging non-clinically-indicated use.
Lawful only with full T&Cs
Discounts, packages, memberships, multi-buy offers — must have clear, accessible T&Cs stated in or directly linked from the ad.
T&Cs must be
Plain language · Accurate and honest · Easily accessible (not buried) · Include offer period, eligibility, and limitations.
AHPRA enforcement examples
✕ Cited in your AHPRA letter
"Cosmetic patients receive ONE IV Infusion FREE" — free bundled service, no clinical indication, indiscriminate use.
✕ Cited in your AHPRA letter
"When you come in together, you'll both receive 10% off" — group promotion, no T&Cs, encourages indiscriminate use.
✕ AHPRA general breach
Prize draw where IV sessions are raffle prizes — encouraged use without clinical indication.
✓ Potentially compliant
"10% off your second appointment. Valid until 30 June. Offer applies to returning patients. Full terms at [yourclinic.com.au/terms]. All treatments require prior clinical assessment by our practitioners."

TGA Schedule / ARTG Checker

Some IV ingredients are scheduled substances under the Poisons Standard. Schedule 4 and Schedule 8 substances — including glutathione — cannot be advertised to the public at all, regardless of how the claim is framed. Enter your infusion ingredients to check advertising restrictions.

Infusion ingredients

Add each active ingredient in your IV infusion, IM injection, cosmetic injectable, or skin treatment product. Include all vitamins, minerals, amino acids, and any other therapeutic substances.

Schedule reference
Schedule 4 — Prescription only
Cannot be advertised to the public at all. Includes glutathione (when in IV form). Prescription required. TGA confirmed IV glutathione advertising is prohibited.
Schedule 8 — Controlled drug
Strictly controlled. Cannot be advertised to the public. Requires specialist prescription in most cases.
Schedule 3 — Pharmacist only
Cannot be advertised to the public unless in Appendix H of the Poisons Standard. Advertising without TGA permission is prohibited.
Unscheduled / Schedule 2
Generally advertisable subject to AHPRA and TGA Advertising Code requirements. Claims still need acceptable evidence.
Common IV ingredients
IV Infusion Ingredients
Glutathione (IV)S4 — PROHIBITED
Vitamin C (Ascorbic acid)Unscheduled
Magnesium (IV)Unscheduled
B12 / B-complex vitaminsUnscheduled
NAD+ (IV, high dose)Assess carefully
Alpha Lipoic AcidUnscheduled
PhosphatidylcholineVerify current schedule
Cosmetic Injectables
Botulinum toxin (ALL brands)S4 — PROHIBITED
Hyaluronic acid fillersARTG required
PDO threadsARTG required
Deoxycholic acid (fat dissolving)S4 — verify
Platelet-rich plasma (PRP)Assess — TGA guidance
Skin Treatment Substances
Tretinoin / Retinoic acidS4 — PROHIBITED
Hydroquinone >2%S4 — PROHIBITED
Hydroquinone ≤2%S3 — restricted
Azelaic acid ≤15%Unscheduled
Salicylic acid (cosmetic %)Unscheduled
Laser / energy devicesARTG — check class

Before / After Image Compliance

Before and after images in health advertising can constitute false or misleading advertising or create unreasonable expectations of beneficial treatment. AHPRA sets specific conditions under which they are less likely to be in breach. This tool walks you through every condition.

Image compliance assessment
AHPRA s.133
AHPRA conditions for B/A images

Before/after images are less likely to be misleading if they meet all of these conditions:

Show realistic, typical outcomes — not cherry-picked best results
Not retouched or enhanced beyond the actual result
Accompanied by risk disclosure and typical outcome information
Patient consent obtained and documented
Contextual information (treatment type, number of sessions) provided
Lighting and photography conditions are consistent between images
Do not imply results are typical or guaranteed
Do not use celebrities, influencers, or aspirational imagery
For IV therapy specifically

IV therapy and IM injections rarely produce visible physical outcomes that could be shown in a before/after image — making most before/after use in this context inherently problematic. Any visible skin, hair, or body composition claim in a B/A image compounds the underlying benefit claim breach.

Before/after images are very high risk under AHPRA s.133(a) (false/misleading) and s.133(d) (unreasonable expectation of benefit) across all service types. For cosmetic and skin treatment services, consistent photography standards are critical. If in doubt, do not use them.

Influencer & UGC Classifier

Tagging a clinic in a post can make it your advertising under the National Law. This tool classifies whether content constitutes advertising, whether you're responsible for it, and whether it contains a prohibited testimonial or clinical claim.

Content to classify
When you're responsible

You are the advertiser — and therefore responsible — if you have control over the content. AHPRA's definition of control is broad:

✕ You authored or approved the post
✕ The influencer tagged your business at your request or arrangement
✕ You paid for or gifted treatment in exchange for a post
✕ You reposted, shared, or linked to the content
✕ You responded to a Google review incorporating clinical outcome language
✓ Organic post on a platform you don't control where you have no arrangement with the poster
Clinical aspect test

A testimonial exists when content references a clinical aspect of care. AHPRA defines clinical aspects as:

Symptoms experienced or improved
Diagnosis or condition mentioned
Treatment outcome or benefit
How they felt before or after treatment
✓ Customer service or communication style (OK)
✓ Clinic environment, comfort, or ambience (OK)
✓ Booking process or staff friendliness (OK)

Title & Qualification Checker

Using the wrong title in advertising can constitute a criminal offence under the National Law's protected title provisions, or be misleading under s.133(a). This tool checks whether a practitioner's title and qualification claims are compliant for their registration type.

Practitioner details
Title protection rules
Protected titles — criminal offence to misuse
Doctor, Nurse, Midwife, Physiotherapist, Pharmacist, Psychologist, Chiropractor, Osteopath, Optometrist, Dentist, Paramedic and others. Registration in that profession is required.
"Surgeon" — 2024 amendment
Only practitioners with specialist registration in surgery, obstetrics/gynaecology, or ophthalmology may use "surgeon". GPs with cosmetic training cannot use "cosmetic surgeon".
"Specialist" / "specialises in"
Implies AHPRA recognised specialist registration. If you don't hold it, this language is misleading. Use "substantial experience in" or "working primarily in" instead.
Acceptable descriptors
"Substantial experience in", "working primarily in", "interest in", "additional training in" — factual, non-specialist language that doesn't imply AHPRA registration.
Aesthetic medicine examples
✕ "Cosmetic Surgeon" (if not specialist registered) — banned under 2024 National Law amendment. GPs cannot use this title.
✕ "IV Specialist" / "Injection Specialist" — implies specialist registration that doesn't exist as an AHPRA category
✕ "Anti-aging Expert" / "Skin Specialist" — same issue, implies AHPRA specialist registration
✕ "Aesthetic Surgeon" or "Cosmetic Physician" without specialist registration — misleading as to qualifications
✓ "Registered Nurse — cosmetic injectable treatments" — accurate, factual, no specialist implication
✓ "GP with substantial experience in cosmetic injectable procedures" — accurate, specific, non-specialist framing
✓ "Aesthetic Injector — Registered Nurse" — describes the role accurately without implying specialist registration

Scope of Practice Checker

Who is legally permitted to perform which procedures — and how those procedures can be advertised. This tool checks whether a practitioner's registration type permits them to perform a given treatment, and whether advertising that treatment is compliant with their scope.

Procedure details
Key scope rules
Anti-wrinkle injections (botulinum toxin)
S4 — requires a prescription. Only medical practitioners can prescribe. RNs and NPs can administer under a valid prescription. Beauty therapists and unregistered practitioners CANNOT legally administer.
Dermal fillers
Regulation varies by state. In most states, medical practitioners are required. NSW and QLD have specific requirements. RNs may administer in some contexts with appropriate oversight.
Laser and IPL treatments
Class 3B and 4 lasers require operator training and in some states medical oversight. Beauty therapists may operate lower-class devices. Check your state's radiation safety legislation.
IV infusions
Intravenous procedures are invasive and must be performed by a registered health practitioner (RN, NP, or medical practitioner). Oversight requirements vary by state and clinical context.
Prescription requirements
Any S4 or S8 substance (botulinum toxin, tretinoin, hydroquinone >2%) requires a valid prescription from an authorised prescriber — typically a medical practitioner.
Advertising scope obligations

Advertising must accurately represent who performs the treatment and their qualifications. Key rules:

Cannot advertise a procedure a practitioner is not legally permitted to perform
Cannot imply medical supervision when none exists
Cannot use "medically supervised" if the supervision does not meet the required standard
Must accurately describe who performs the treatment (title, registration)
✓ Stating "administered by registered nurses under doctor supervision" — accurate and appropriate
✓ Stating clinical assessment is required before treatment — appropriate and encouraged