AHPRA Advertising Rules for Dental Practices: What You Can and Cannot Say
The AHPRA advertising rules ban five things, not one. The testimonial rule is narrower than you have been told, and the penalty most agencies quote is out of date.
What a dental practice may say in its ads
Table of Contents10 sections
Most dental marketing agencies in Australia have a page about the AHPRA advertising rules, and plenty of them say the maximum penalty is $30,000 for an individual and $60,000 for a company.
The short version: the AHPRA advertising rules ban five things, and testimonials are only the third of them. A testimonial means praise for the clinical side of care, so a comment about reception or parking doesn't count.
Breaking the rules can cost up to $60,000 per offence for an individual and $120,000 for a body corporate, in every state and territory.
The $30,000 and $60,000 figures were Western Australia's. The rest of the country moved on in 2022, when the National Law was amended and the maximum fine per advertising offence rose from $5,000 to $60,000 for an individual and from $10,000 to $120,000 for a body corporate.
| Maximum penalty per advertising offence | Individual | Body corporate |
|---|---|---|
| Every state and territory, WA included since July 2024 | $60,000 | $120,000 |
| Western Australia until July 2024, still quoted on agency pages | $30,000 | $60,000 |
| The rest of the country before the 2022 amendment | $5,000 | $10,000 |
WA kept its own lower numbers until July 2024, and since then the higher ones apply there too. AHPRA says so on its Advertising and the law page.
So the figure on those agency pages is now wrong in every state. It's an easy mistake if you copy another agency's blog instead of reading the regulator, and it says a lot about how this topic usually gets written. What follows is our version, with the sources attached so you can check each claim yourself.
Key Takeaways
- Section 133 lists five prohibitions. Most articles stop at testimonials, but the other four catch more practices.
- A testimonial is about clinical aspects: symptoms, diagnosis, treatment or outcome. AHPRA says in writing that comments on customer service or communication style don't count.
- The penalty is $60,000 and $120,000 everywhere, Western Australia included since July 2024. The $30,000 and $60,000 figures on many agency sites were only ever WA's, and WA has since moved to the national figures.
- AHPRA publishes no banned-words list. Section 4.1 targets any claim of a superior service, whatever words carry it, which makes it broader and harder to game.
- Title tags, meta descriptions, alt text and your Business Profile description are all advertising of a regulated health service, and they're where non-compliant wording usually survives.
What the AHPRA Advertising Rules Prohibit
Ask a dentist what AHPRA bans and you'll usually hear one word: testimonials. That's one of five prohibitions, and the other four catch more practices than the testimonial rule does.
Section 133 of the Health Practitioner Regulation National Law says you must not advertise a regulated health service, or a business that provides one, in a way that:
- is false, misleading or deceptive, or is likely to be misleading or deceptive
- offers a gift, discount or other inducement to attract someone to the service, unless the advertisement also states the terms and conditions of that offer
- uses testimonials or purported testimonials about the service or business
- creates an unreasonable expectation of beneficial treatment
- directly or indirectly encourages the indiscriminate or unnecessary use of regulated health services
Limb 2 is the one people misread. It allows discounts, as long as the ad states the terms and conditions.
A practice advertising a "$99 new patient check-up and clean" is fine if the page says what's included, what isn't and when the offer ends. Run the same words with no conditions and it's an offence. Practices lose sight of this all the time, and they usually err on the cautious side, assuming they can't run offers at all.
Limb 1 is the broadest and does most of the work in practice. It also overlaps with Australian Consumer Law, which applies whatever AHPRA decides. If you want your own site checked against it, our marketing audit includes a health advertising screen for dental and clinic sites.
The Testimonial Rule Is Narrower Than You Have Been Told
Here's AHPRA's own definition, from its summary of the advertising requirements:
Advertising must not use testimonials or purported testimonials, that is, recommendations or positive statements about the clinical aspects of a regulated health service. 'Clinical aspects' refers to statements about symptoms, diagnosis, treatment, outcome.
A little further down the same page is the sentence almost nobody quotes:
Not all reviews or positive comments made about a regulated health service are considered testimonials. For example, comments about customer service or communication style that do not include a reference to clinical aspects are not considered testimonials for the purposes of the National Law.
So the question for any comment is whether the praise is about clinical care. General praise is fine.
"The reception team called me back within an hour and parking was easy" is about service. "Dr Chen fixed my chipped front tooth and it looks better than the original" is about treatment and outcome.
You can use the first one in material you control. You can't use the second, however genuine and unprompted it was, and even if it's already public on Google.
The other half of the rule is about where it applies. AHPRA again:
Advertisers are responsible for removing testimonials from the advertising they control, including social media platforms advertising their regulated health service (e.g. clinic Facebook page).
Your website, Facebook page, Instagram, ads and printed material are all yours. What patients write on Google, on a forum or on a review site you don't run is outside your control, and AHPRA doesn't expect you to police it.
We've covered that side in its own article: Google reviews and AHPRA explains what you can and can't do with reviews you didn't write.
The Trap Sitting Inside Your Website Copy
This is the part where a legal topic turns into a marketing one.
Limb 4 bans creating "an unreasonable expectation of beneficial treatment", and limb 1 bans anything misleading. Between them they rule out a lot of wording that's normal on service websites, including wording your SEO instincts push you toward.
Secondhand summaries usually go wrong here, so it's worth being exact. AHPRA publishes no banned-words list, and its guidelines never use the word "best" or "superlative".
What section 4.1 of the advertising guidelines says is that advertising may be false, misleading or deceptive if it "makes claims about providing a superior regulated health service", or if it "misleads, either directly or by implication through the use of emphasis, comparison, contrast or omission".
That covers far more ground than a list of words would. "Bondi's best dentist" claims superiority. So does "the most advanced practice in the area", and so does a layout that puts your five-star average beside a competitor's three stars.
Here are the common patterns, with a version you can use instead:
| Instead of | Say something like | Rule it engages |
|---|---|---|
| "Dr Chen fixed my chipped front tooth" on your site | "The reception team called me back within an hour" | Testimonials, s.133(1)(c) |
| "Bondi's best dentist" | "We hold two hours every weekday for same-day emergencies" | Superior service, s.4.1 |
| "Pain-free dentistry" | Your sedation options and a slower first visit for anxious patients | Minimising risk, s.4.4 |
| "Specialises in implants" | "Working primarily in implant dentistry" | Specialist wording, s.4.1.4 |
| "Straight teeth in six months" | An estimated treatment time, given at the consultation | Unreasonable expectation, s.133(1)(d) |
| A $99 check-up and clean, no terms | The same offer with what's included, what costs extra and an end date | Inducement without terms, s.133(1)(b) |
| Your five stars beside a rival's three | Your own rating, with no comparison | Comparative claims, s.4.1.3 |
People do search for those phrases, which is why they end up in title tags. You can still rank for the search without making the claim.
A page called "Finding a dentist in Bondi Junction" that explains how to compare practices, what to ask about after-hours care and what happens at a first appointment answers the same search. It says nothing about how good you are, and it's a more useful page anyway.
A few other patterns turn up again and again in dental website copy.
Guarantees About Outcomes
"Straight teeth in six months" sets an expectation you can't promise every patient. Compare "Most Invisalign cases at this practice run between X and Y months, and we give you your estimated range at the consultation", which tells the reader more and promises less.
Pain-Free, Safe, Risk-Free
Section 4.4 names these directly. It lists advertising that:
minimises the complexity of risk associated with a treatment (i.e. using words or phrases such as 'safe', 'effective', 'risk-free', 'pain-free') without acknowledging possible adverse reactions or mixed/inconclusive evidence for the treatment
Read the end of that sentence closely. You can use the words, provided you also acknowledge the risks and the state of the evidence.
Specialist, Specialises In, Specialty
AHPRA is blunt about this one. Section 4.1.4 of the guidelines says advertising that uses "'specialist', 'specialises in', 'specialty', or 'specialised'" may be false, misleading or deceptive, while "words such as 'substantial experience in' or 'working primarily in' are less likely to be misleading".
Are you on the specialist register for that field? If not, change the wording. It's one of the most common problems on general practice websites, usually sitting in a services menu nobody has reread in three years.
Comparative Claims About Other Practices
Section 4.1.3 covers these, and it's worth reading in full before you try one. Comparisons of outcomes, practitioner skill or prices all need to be "clear, accurate and supported by acceptable evidence where relevant". Complete information is hard to fit into a headline, which is where most comparative claims come unstuck.
Before and After Galleries
AHPRA allows these with conditions, and its tone is gentler than most summaries suggest.
Section 4.4.1 says "care should be taken", then lists what makes such images "less likely to be misleading":
- images "as similar as possible in content, camera angle, background, framing and exposure"
- consistent posture, clothing and make-up
- consistent lighting and contrast
- an explanation if anything has been altered
- the treatment being "the only visible change to the person being photographed"
Most galleries fail on lighting first.
Prices Without Conditions
This is limb 2 again. It's easy to fix and very often broken.
Who Carries the Liability Under the AHPRA Advertising Rules
The National Law applies to the advertiser. Section 3.2 of AHPRA's guidelines defines that as whoever authorises the content, and says advertisers "need to check any content produced by others on their behalf", naming marketing agencies as one of those others.
So when an agency writes non-compliant copy for you, the problem lands on you. Before you sign with any provider, ask how they handle compliance.
"We'll check with your lawyer" is a real answer. "AHPRA is pretty relaxed about it these days" is a reason to walk away.
There's a second risk that gets less attention. AHPRA's requirements sit alongside the Australian Consumer Law, which the ACCC enforces whatever a professional board thinks, so one misleading claim can get you into trouble with two regulators at once.
What Compliant Marketing Looks Like
The rules take one kind of persuasion off the table and leave you plenty of others.
You can talk about the treatments you provide, your qualifications and registration, how long you've been open, your equipment, your fees and payment options with the conditions attached, your hours, your languages, your accessibility, how you look after anxious patients, what happens at a first visit and how you handle emergencies. Everything on that list is factual, checkable and specific.
Specific is the important word there. Dental copy reaches for superlatives when the practice hasn't written down what actually makes it different. "Award-winning care" is what ends up on the page when nobody has thought to write "we hold two hours a day for same-day emergencies and publish our wait time on the homepage".
Handled well, the rules push you toward better copy. Specific claims convert better than superlatives, and they're the only kind a search engine or an AI assistant can check against anything else.
Where the AHPRA Advertising Rules Intersect With Your Rankings
For search, this has three practical consequences.
Your Title Tags and Headings Are Advertising
A <title> reading "Best Dentist Melbourne" advertises a regulated health service. So do meta descriptions, image alt text, Google Business Profile descriptions and Google Ads headlines (the Google Business Profile guide covers the rest of that profile). A compliance review that only reads the visible page misses all of them.
When we audit a practice's site, titles and headings are where we find the most non-compliant wording. Whoever built the site usually wrote them, and nobody has looked at them since.
Review Content on Your Own Pages Carries the Risk With It
A Google reviews widget on your homepage pulls patient comments about clinical care onto a page you control, and that's what makes them your responsibility. Read the companion piece on reviews before you install one.
You Cannot Mark Up Your Own Reviews for Star Ratings
This is a separate rule that hits the same page. Google's review snippet documentation was last updated 8 September 2026. It says a business that controls the reviews about itself can't get star ratings on its pages.
That holds whether the reviews sit:
"either directly in their structured data or through an embedded third-party widget (for example, Google Business reviews or Facebook reviews widget)" So if someone offers you review schema for stars on your own site, walk away. Google has ruled it out in writing.
Common Questions
Can we use patient reviews on our website at all?
Yes, as long as they don't mention clinical aspects, meaning symptoms, diagnosis, treatment or outcome. Comments about service, communication or how the visit felt aren't testimonials under the National Law. Comments about the work you did are testimonials, and they can't appear in material you control.
What about reviews on Google that mention treatment?
You don't have to do anything about them. AHPRA says advertisers aren't responsible for removing unsolicited testimonials on platforms they don't control, and the boards don't expect you to monitor forums outside your control. The risk starts when you copy one of those reviews onto your website, your social pages or an ad.
Can we advertise a new patient discount or a $99 check-up and clean?
Yes, provided the ad states the terms and conditions of the offer: what's included, what isn't, and when it ends. That's limb 2 of section 133. Limb 5 adds one more limit, which is that the offer mustn't be set up in a way that encourages unnecessary treatment.
Are before and after photos banned?
No, and AHPRA doesn't say they are. Section 4.4.1 of the advertising guidelines says "care should be taken", and lists when such images are "less likely to be misleading": consistent content, camera angle, background, framing, exposure, posture, clothing, make-up, lighting and contrast, a note of any alteration, and the treatment being the only visible change.
Can we describe ourselves as specialists?
Only if you're on the specialist register for that field. Section 4.1.4 of AHPRA's advertising guidelines warns that "specialist", "specialises in", "specialty" and "specialised" may be false, misleading or deceptive, and suggests "substantial experience in" or "working primarily in" as lower-risk wording.
What is the actual maximum penalty under the AHPRA advertising rules?
$60,000 per offence for an individual and $120,000 for a body corporate. The increase came with the 2022 amendments to the National Law. Since July 2024 it has applied in Western Australia as well, which had kept lower figures of $30,000 and $60,000 until then.
Does AHPRA enforce this?
Yes. It publishes the advertising cases heard by courts and tribunals, and it has run compliance campaigns aimed at particular professions. In May 2024 the Dental Board put out a public statement urging dentists to comply with the advertising rules, which suggests the regulator is still watching dental advertising closely.
Our agency writes our copy. Who is liable?
You are. Section 3.2 of AHPRA's advertising guidelines makes whoever authorises the content the advertiser, and says advertisers need to check content others produce for them, including a marketing agency. Having an agency write the words doesn't move the responsibility off your practice.
Is it against AHPRA rules to say we are the best dentist in our suburb?
AHPRA has no banned-words list and never uses the word "best". But section 4.1 of the advertising guidelines says advertising may be false, misleading or deceptive if it "makes claims about providing a superior regulated health service". Calling yourself the best in your suburb is a claim of superiority, so you'd need evidence to back it up.
Can we put "pain-free dentistry" or "painless treatment" on our website?
Both promise an outcome you can't guarantee for every patient, which is where limbs 1 and 4 of section 133 apply. A safer version describes what you actually do: the sedation options you offer, your anaesthetic technique, and how you look after anxious patients. That gives people the reassurance they're looking for without promising a result.
Does AHPRA apply to our Google Ads and our Instagram, or only to our website?
All of them. The rules cover every place you advertise a regulated health service, including Google Ads headlines, Google Business Profile descriptions, Instagram and Facebook posts, printed material, signage and the text inside images. What matters is that it's advertising, whatever the medium.
Are our page titles and meta descriptions covered by the advertising rules?
Yes. A <title> reading "Best Dentist Melbourne" advertises a regulated health service in exactly the way section 4.1 describes, and so do meta descriptions, headings and image alt text. This is where non-compliant wording survives longest, because it's usually written once during a site build and never reviewed.
Who is responsible if a patient posts a testimonial on our Facebook page?
You are. A practice Facebook page is advertising you control, so a comment about clinical care posted there is yours to remove. If the same patient leaves the same comment as a Google review, it's outside your control and you can leave it alone.
How often do the AHPRA advertising guidelines change?
AHPRA revises them from time to time. The penalties changed with the 2022 amendments and again in Western Australia in July 2024, and AHPRA says the guidelines themselves will be updated to reflect the new penalties at their next review. Treat any summary, this one included, as a starting point and check the current text on ahpra.gov.au.
Before You Brief Anyone on the AHPRA Advertising Rules
Read your own site the way AHPRA would. Start with the title tags and headings, because that's where superlatives tend to survive.
Then check every offer for stated conditions, and every review on a page you control for clinical content. Would your before-and-after photos hold up if someone asked about the lighting?
Last, look at the penalty figure in whatever guide you've been relying on. Does it still say $30,000? Then whoever wrote it hasn't checked the regulator since mid-2024.
If you'd like a second opinion, our fixed-price audit covers advertising compliance along with the technical and search work. How we approach marketing for practices is on the marketing for dentists page.
This article describes publicly available regulatory requirements and is not legal advice. AHPRA's guidelines are the authoritative source and are revised periodically. Verify against ahpra.gov.au and dentalboard.gov.au before relying on anything here.
Sources
- AHPRA: Advertising and the law (penalty amounts, 2022 amendment, WA from July 2024)
- AHPRA: Summary of the advertising requirements (testimonial definition, scope of advertiser responsibility)
- AHPRA: Guidelines for advertising a regulated health service (sections 4.1, 4.1.3, 4.1.4, 4.4 and 4.4.1)
- Dental Board of Australia: Advertising a regulated health service
- AHPRA: Dental Board urges compliance with advertising rules, 6 May 2024
- Google: Review snippet structured data, last updated 8 September 2026
