FFP Guides

AHPRA advertising

AHPRA before and after photo rules for allied health

The National Law has no clause written for before and after photos specifically. Section 133(1)(c) still catches most of them: a photo pair implying a clinical outcome (straighter posture, a healed injury, better mobility) is a purported testimonial. The narrow safe use is an anatomical or educational image with no named patient and no outcome claim attached to it.

Last checked 25 Sep 2026 against the sources listed at the end of this page.

"A person must not advertise a regulated health service ... in a way that ... (c) uses testimonials or purported testimonials about the service or business." (National Law, section 133(1)(c)). Ahpra's Testimonial tool defines a testimonial as "a recommendation or positive statement about the clinical aspects of a regulated health service," which the tool applies to the clinical aspects shown, not only to written words.

Source

Allowed

  • A generic anatomical diagram or stock illustration explaining a condition or a treatment technique, with no real patient and no claimed outcome attached.
  • A photo of equipment, the clinic space, or a practitioner performing a technique on a model, with nothing shown or implied about that person's own clinical result.
  • Progress photos kept in a patient's own clinical file for treatment planning. The rule governs advertising, not clinical record keeping, so nothing stops a clinic photographing a patient for their own notes with consent.
  • A patient's own before and after post on their personal social media, shared entirely on their own initiative and never touched, reposted or promoted by the clinic.
  • General practitioner education content, for example a photo series showing correct versus incorrect lifting posture, where no individual patient's condition or outcome is depicted.

Not allowed

  • A side by side of a patient's posture, gait, swelling, scar or range of motion before treatment and after it, used to promote the service, even with the face blurred or the name withheld.
  • A goniometer reading, a measurement overlay, or a caption claiming a specific improvement (added degrees of movement, reduced swelling, pain gone) attached to a photo pair.
  • Marketing a weight loss, posture correction or rehabilitation program with client transformation photos, a format common in the fitness industry that Ahpra treats the same way as any other outcome testimonial when the provider is a regulated practitioner.
  • Any of the above published with a disclaimer such as results may vary. A disclaimer does not exempt a testimonial from section 133(1)(c); the ban is on using the testimonial at all, not on using it without a warning.
  • Editing, cropping or angle matched before and after images to make the change look larger or smaller than it was, which risks a second breach under section 133(1)(a) for being false, misleading or deceptive on top of the testimonial problem.

What a compliant clinic website does

A compliant allied health site keeps clinical photography out of its marketing pages entirely. Where a visual is useful, it uses a labelled anatomical diagram or a photo of the practitioner demonstrating a technique on a colleague or model, captioned to describe the technique rather than an outcome. Any patient case material stays inside the clinical record, shared with that patient's own consent for their own file, not published on the website or social channels.

Penalty: Advertising in breach of section 133 is a criminal offence, with a maximum penalty of $60,000 per offence for an individual practitioner and $120,000 per offence for a body corporate such as a clinic company.

This is general information, not legal advice. Check the current guideline before you publish.

Why there is no specific before and after clause to point to

Ahpra does publish detailed, numbered rules for before and after images, but only inside the Guidelines for advertising higher risk non-surgical cosmetic procedures, a document written for injectables, thread lifts and similar cosmetic medical work. That guideline requires a prominent warning that results are patient specific and bans edited or filtered images outright. Physiotherapy, podiatry, exercise physiology and most other allied health services are not higher risk cosmetic procedures, so that specific document does not apply to them directly.

That gap does not create a loophole. Every regulated health service, allied health included, is still bound by the general advertising rules in section 133(1) of the National Law: nothing false, misleading or deceptive, and no testimonials or purported testimonials. A before and after pair almost always trips the testimonial ban on its own, because showing a clinical change over time is, by definition, a positive statement about a clinical outcome, whether or not a single word of text accompanies it.

The test to apply to any image, not just photos with captions

Ahpra's testimonial guidance defines a testimonial by its content, not its format: a recommendation or positive statement about the clinical aspects of a service. A photo pair makes that statement visually. Blurring a face, cropping out the name, or leaving off a caption does not change what the image communicates, which is that this treatment produced this result for this person. The same reasoning applies to video, a slow pan across a before and after pair in a Reel, or a side by side graphic built in a design tool.

Where a disclaimer does and does not help

A results may vary line is required for higher risk cosmetic procedure images under the cosmetic specific guideline, but it is there to reduce a different risk, that viewers assume the same result for themselves, not to excuse the testimonial. For allied health advertising governed by the general section 133 rules, no disclaimer removes a testimonial once it is published; the safest position is not publishing clinical before and after material at all, and reserving it for the patient's own consented clinical record.

Sources

  1. Section 133(1)(c) of the National Law prohibits advertising a regulated health service in a way that uses testimonials or purported testimonials about the service or business. Ahpra and the National Boards, checked 25 Sep 2026.
  2. A testimonial is a recommendation or positive statement about the clinical aspects of a regulated health service used in advertising. Ahpra, checked 25 Sep 2026.
  3. Under the Guidelines for advertising higher risk non-surgical cosmetic procedures, images used to show outcomes must not be edited, retouched or filtered, and must carry a prominent warning that the outcomes shown are patient specific and do not necessarily reflect other patients' results. Ahpra, checked 25 Sep 2026.
  4. Section 133(1)(a) of the National Law separately prohibits advertising that is false, misleading or deceptive, or likely to be misleading or deceptive. Ahpra and the National Boards, checked 25 Sep 2026.
  5. The maximum penalty for an advertising offence under the National Law is $60,000 per offence for an individual and $120,000 per offence for a body corporate. Ahpra and the National Boards, checked 25 Sep 2026.