FFP Guides

AHPRA advertising

AHPRA rules for discounts, vouchers and free offers

Section 133(1)(b) of the National Law does not ban discounts, gift vouchers or free offers. It bans advertising one without also stating the terms and conditions. Ahpra's guidelines give a specific example of a breach: offering a free second consultation while raising the price of the first one to cover it, which is a discount in name only.

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 ... (b) offers a gift, discount or other inducement to attract a person to use the service or the business, unless the advertisement also states the terms and conditions of the offer." (National Law, section 133(1)(b), Ahpra Guidelines for advertising a regulated health service, section 4.2). Section 4.2 gives as an example of a breach an advertiser who "makes an offer of 'make one consultation appointment, get one free', but raises the price of the first consultation to largely cover the cost of the second (free) appointment."

Source

Allowed

  • A discount, gift voucher or free offer advertised together with its terms and conditions in the same place: what it covers, how long it runs, who is eligible, and what happens after it ends.
  • A free initial assessment, provided the advertisement also states what it includes, how long it runs for, and that the practitioner's clinical judgement, not the offer, decides what treatment follows.
  • A gift voucher for a fixed dollar amount or a fixed number of sessions, sold at its stated price, with its expiry and any conditions on use printed on the voucher or the page selling it.
  • A loyalty or referral discount (for example, ten percent off a client's next block of sessions) advertised with the same term and condition disclosure as any other discount.
  • A genuinely reduced price during a stated period, where the underlying full price has not been raised beforehand to make the discount look larger than it is.

Not allowed

  • Any gift, discount, voucher or free offer advertised with no terms and conditions stated at all, even where the offer itself is genuine.
  • A free second consultation, session or add on where the first, paid item's price has been increased to cover the cost of the free one, the exact example Ahpra's guidelines give of a breach.
  • A free initial assessment advertised in a way that implies, or is likely to be read as implying, that treatment is guaranteed to follow, which risks a second breach under section 133(1)(d) for creating an unreasonable expectation of benefit, and under 133(1)(e) for encouraging use of a service that is not needed.
  • Terms and conditions that exist only in a separate document a patient has to ask for, rather than being stated in or clearly linked from the advertisement itself.
  • A gift voucher offer with no stated expiry, refund or transfer terms, since silence on these points leaves the terms and conditions requirement in section 133(1)(b) unmet.

What a compliant clinic website does

A compliant clinic offer page states the discount or free item in the headline, then a short terms line directly underneath it: what is included, the offer's start and end dates, and any eligibility limit (new patients only, one per person). A free initial assessment page adds a line making clear that further treatment is recommended only if clinically appropriate, not because the assessment was free.

Penalty: Advertising in breach of section 133(1)(b) is a criminal offence, carrying the same maximum penalty as any other advertising breach under the National Law: $60,000 per offence for an individual and $120,000 per offence for a body corporate.

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

The rule is about disclosure, not about banning discounts

Allied health clinics routinely run new patient discounts, gift vouchers and free initial assessments, and none of that is prohibited by the National Law. Section 133(1)(b) is a disclosure rule: an advertisement can offer a gift, a discount or another inducement to attract a patient, but only if it also states the terms and conditions of that offer in the advertisement itself. An offer with no terms stated anywhere is a breach even if the offer is completely genuine, because the rule is about what the advertisement says, not just what actually happens when a patient calls.

Why the free consultation example matters

Ahpra's own illustration of a breach under this clause is a clinic that advertises make one consultation appointment, get one free, while quietly raising the price of the first consultation to cover most of the cost of the second. The terms and conditions might even be stated, and the offer would still be a problem, because it is not really a discount at all: the patient pays close to the combined price either way. The lesson for a physio or allied health clinic running a free initial assessment or a two for one package is to check the maths runs the other direction, that the free or discounted item is a genuine reduction against the clinic's ordinary pricing, not a relabelling of it.

Free initial assessments carry an extra risk

A free initial assessment is common in allied health marketing, and section 133(1)(b) is satisfied as long as the terms are stated: what the assessment covers, how long the offer runs, and any eligibility limit. The extra care needed is around two other clauses in the same section. Wording that implies treatment will definitely follow the assessment risks creating an unreasonable expectation of benefit, and wording that pushes people toward booking who may not need the service at all risks encouraging indiscriminate or unnecessary use. Neither risk is about the free price tag itself; both come from how the offer is worded around it, so a free assessment ad is safest when it states plainly that any recommended treatment depends on what the assessment finds.

Sources

  1. Section 133(1)(b) of the National Law prohibits advertising a regulated health service in a way that offers a gift, discount or other inducement to attract a person to use the service or business unless the advertisement also states the terms and conditions of the offer. Ahpra and the National Boards, checked 25 Sep 2026.
  2. Ahpra's guidelines give as an example of a breach an advertiser offering make one consultation appointment, get one free, while raising the price of the first consultation to largely cover the cost of the free second appointment. Ahpra and the National Boards, checked 25 Sep 2026.
  3. Section 133(1)(d) of the National Law prohibits advertising that creates an unreasonable expectation of beneficial treatment, and section 133(1)(e) prohibits advertising that directly or indirectly encourages the indiscriminate or unnecessary use of regulated health services. Ahpra and the National Boards, 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.