{"id":2108,"date":"2026-07-30T07:02:38","date_gmt":"2026-07-30T07:02:38","guid":{"rendered":"https:\/\/mersa.biz\/blog\/?p=2108"},"modified":"2026-07-30T07:19:48","modified_gmt":"2026-07-30T07:19:48","slug":"ahpra-advertising-rules-dental-practices","status":"publish","type":"post","link":"https:\/\/mersa.biz\/blog\/healthcare-compliance\/ahpra-advertising-rules-dental-practices\/","title":{"rendered":"AHPRA advertising rules for dental practices: what you can and cannot say"},"content":{"rendered":"\n

Most dental marketing agencies in Australia have a page about the AHPRA advertising rules.
Go and read a few.
A striking number of them quote the maximum penalty as $30,000 for an individual and $60,000 for a company.<\/p>\n\n\n\n

That figure was correct in Western Australia.
It has not been correct anywhere else in Australia since 2022.<\/p>\n\n\n\n

When the National Law was amended that year, the maximum financial penalty per advertising offence went from $5,000 to $60,000<\/strong> for an individual, and from $10,000 to $120,000<\/strong> for a body corporate.
Western Australia did not adopt the increase, so the old $30,000 and $60,000 numbers still apply there and nowhere else.
AHPRA publishes both figures on its own Advertising and the law<\/a> page.<\/p>\n\n\n\n

Doubling a number is a small mistake.
Copying a number off another agency’s blog without checking the regulator is a bigger one, and it tells you something about how this topic usually gets written about.<\/p>\n\n\n\n

So here is the version of the AHPRA advertising rules with the sources attached.<\/p>\n\n\n\n

\"The\n\t\t\t\n\t\t\t\t\n\t\t\t<\/svg>\n\t\t<\/button>
Section 133 prohibits five things. Almost every article about AHPRA covers the third.<\/figcaption><\/figure>\n\n\n\n

What the AHPRA Advertising Rules Prohibit<\/h2>\n\n\n\n

Almost every conversation about AHPRA collapses into one word: testimonials.
That is one of five prohibitions, and the other four catch more practices than the testimonial rule does.<\/p>\n\n\n\n

Section 133 of the Health Practitioner Regulation National Law says a person must not advertise a regulated health service, or a business providing one, in a way that:<\/p>\n\n\n\n

    \n
  1. is false, misleading or deceptive, or is likely to be misleading or deceptive<\/li>\n\n
  2. 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<\/li>\n\n
  3. uses testimonials or purported testimonials about the service or business<\/li>\n\n
  4. creates an unreasonable expectation of beneficial treatment<\/li>\n\n
  5. directly or indirectly encourages the indiscriminate or unnecessary use of regulated health services<\/li>\n<\/ol>\n\n\n\n

    Read limb 2 again.
    It does not ban discounts.
    It bans discounts advertised without their terms and conditions.
    A practice running “$99 new patient check-up and clean” is fine if the page says what is included, what is excluded, and when the offer ends.
    The same words with no conditions attached are an offence.
    That distinction gets lost constantly, usually in the direction of practices believing they cannot run offers at all.<\/p>\n\n\n\n

    Limb 1 is the broadest and the one that does the most work in practice.
    It is also the one that overlaps with Australian Consumer Law, which applies to you regardless of what AHPRA does.<\/p>\n\n\n\n

    The testimonial rule is narrower than you have been told<\/h2>\n\n\n\n

    AHPRA’s own definition, from its summary of the advertising requirements<\/a>:<\/p>\n\n\n\n

    \n

    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.<\/p>\n<\/blockquote>\n\n\n\n

    And then, in the same document, the sentence almost nobody quotes:<\/p>\n\n\n\n

    \n

    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.<\/p>\n<\/blockquote>\n\n\n\n

    So the test is not “is it praise”.
    The test is whether the praise is about clinical care.<\/p>\n\n\n\n

    “The reception team called me back within an hour and parking was easy” is a comment about service.
    “Dr Chen fixed my chipped front tooth and it looks better than the original” is about treatment and outcome.
    The first can appear in material you control.
    The second cannot, no matter how genuine it is, no matter that the patient offered it unprompted, and no matter that it is sitting publicly on Google already.<\/p>\n\n\n\n

    The other half of the rule is about scope.
    AHPRA:<\/p>\n\n\n\n

    \n

    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).<\/p>\n<\/blockquote>\n\n\n\n

    Your website, your Facebook page, your Instagram, your ads, your printed material.
    Those are yours.
    What patients write on Google, on a forum, or on a review site you do not run is not your responsibility to police.
    That distinction is worth its own article, and it has one:     Google reviews and AHPRA<\/a> covers what you may and may not do with reviews you did not write.<\/p>\n\n\n\n

    \"Table\n\t\t\t\n\t\t\t\t\n\t\t\t<\/svg>\n\t\t<\/button>
    Six patterns AHPRA’s guidelines describe, and a version of each that survives. AHPRA publishes no banned-words list.<\/figcaption><\/figure>\n\n\n\n

    The trap sitting inside your website copy<\/h2>\n\n\n\n

    Here is where this stops being a legal topic and starts being a marketing one.<\/p>\n\n\n\n

    Limb 4 prohibits creating “an unreasonable expectation of beneficial treatment”.
    Limb 1 prohibits anything misleading.
    Together they rule out a large amount of language that is otherwise standard on service websites, and much of it is language an SEO instinct pushes you toward.<\/p>\n\n\n\n

    Worth being precise here, because this is where secondhand summaries go wrong.
    AHPRA does not publish a banned-words list.
    It never uses the word “best” and never uses the word “superlative”.
    What the     advertising guidelines<\/a> say, at section 4.1, 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”.<\/p>\n\n\n\n

    That is broader than a word ban and harder to game.
    “Bondi’s best dentist” is a claim of superiority.
    So is “the most advanced practice in the area”, and so is a layout that puts your five-star average next to a competitor’s three-star one.
    The search demand behind those phrases is real.
    Asserting them about yourself is not available to you.<\/p>\n\n\n\n

    There is a workable version.
    You can rank for a query without asserting the query.
    A page titled “Finding a dentist in Bondi Junction” that explains how to compare practices, what to ask about after-hours care, and what a first appointment involves targets the same intent without making a claim about yourself at all.
    It also happens to be a better page.<\/p>\n\n\n\n

    Some other patterns that surface repeatedly in dental website copy:<\/p>\n\n\n\n

    Guarantees about outcomes.<\/strong> “Straight teeth in six months” sets an expectation you cannot promise for every patient.
    “Most Invisalign cases at this practice run between X and Y months, and we give you your estimated range at the consultation” says more and promises less.<\/p>\n\n\n\n

    Pain-free, safe, risk-free.<\/strong> These are named directly.
    Section 4.4 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”.
    Note the qualifier at the end.
    The words are not forbidden outright; using them while staying silent about risk is the problem.<\/p>\n\n\n\n

    Specialist, specialises in, specialty.<\/strong> AHPRA’s FAQ is direct about this one: advertising using “‘specialist’, ‘specialises in’, ‘specialty’, or ‘specialised'” may be considered false, misleading or deceptive, while “words such as ‘substantial experience in’ or ‘working primarily in’ are less likely to be misleading”.
    If you are not on the specialist register for that field, change the phrasing.
    This turns up on general practice websites constantly, usually in a services menu nobody has reread in three years.<\/p>\n\n\n\n

    Comparative claims about other practices.<\/strong> Section 4.1.3 covers this and is worth reading in full if you are tempted.
    Comparisons of outcomes, of practitioner competency, or of prices all need to be “clear, accurate and supported by acceptable evidence where relevant”, and complete information is hard to fit into a headline.<\/p>\n\n\n\n

    Before and after galleries.<\/strong> These are conditional rather than banned, and the regulator’s register is softer than most summaries suggest.
    Section 4.4.1 says “care should be taken”, and 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, and the referenced treatment being “the only visible change to the person being photographed”.
    Most galleries fail on lighting before they fail on anything else.<\/p>\n\n\n\n

    Prices without conditions.<\/strong> Limb 2, as above.
    Easy to fix, frequently broken.<\/p>\n\n\n\n

    Who Carries the Liability Under the AHPRA Advertising Rules<\/h2>\n\n\n\n

    The National Law applies to the advertiser.
    That is the practice and the practitioner, not the agency.<\/p>\n\n\n\n

    An agency that writes non-compliant copy for you has caused you a problem it does not carry.
    Ask any provider pitching you how they handle this before you sign anything, and treat “we’ll check with your lawyer” as a real answer and “AHPRA is pretty relaxed about it these days” as a reason to walk.<\/p>\n\n\n\n

    There is a second, quieter exposure.
    AHPRA’s advertising requirements sit alongside the     Australian Consumer Law<\/a>, and the ACCC does not care what your professional board thinks.
    A misleading claim can be a problem in two places at once.<\/p>\n\n\n\n

    \"Two\n\t\t\t\n\t\t\t\t\n\t\t\t<\/svg>\n\t\t<\/button>
    Section 133 in full, beside what it leaves untouched.<\/figcaption><\/figure>\n\n\n\n

    What compliant marketing looks like<\/h2>\n\n\n\n

    The rules remove one category of persuasion.
    They do not remove persuasion.<\/p>\n\n\n\n

    What you may say is broad: what treatments you provide, your qualifications and registration, how long the practice has operated, your equipment, your fees and payment options with conditions attached, your hours, your languages, your accessibility, your approach to anxious patients, what happens at a first visit, how emergencies are handled.
    Factual, verifiable, specific.<\/p>\n\n\n\n

    That last word is the one worth sitting with.
    The reason so much dental website copy reaches for superlatives is that the practice has not done the work of writing down what makes it different in concrete terms.
    “Award-winning care” is what you write when you have not written “we hold two hours a day for same-day emergencies and publish our wait time on the homepage”.<\/p>\n\n\n\n

    Compliance pressure, applied properly, tends to produce better copy than it removes.
    Specific beats superlative on conversion anyway, and it is the only kind of claim a search engine or an AI assistant can verify against anything.<\/p>\n\n\n\n

    \"A\n\t\t\t\n\t\t\t\t\n\t\t\t<\/svg>\n\t\t<\/button>
    Eight surfaces that are all advertising a regulated health service. The example wording is invented.<\/figcaption><\/figure>\n\n\n\n

    Where the AHPRA Advertising Rules Intersect With Your Rankings<\/h2>\n\n\n\n

    Three practical consequences.<\/p>\n\n\n\n

    Your title tags and headings are advertising.<\/strong> A <title><\/code> containing “Best Dentist Melbourne” is advertising a regulated health service.
    So is a meta description, an image alt attribute, a Google Business Profile description, and the text of a Google Ads headline.
    Compliance reviews that stop at the visible body copy miss all of it.
    When we run an     audit<\/a>, the title and heading layer is where non-compliant language turns up most often, because it is usually written by whoever set up the site and never reviewed again.<\/p>\n\n\n\n

    Review content on your own pages carries the risk with it.<\/strong> Embedding a Google reviews widget on your homepage pulls patient text about clinical care into material you control.
    The widget makes it yours.
    Worth reading the     companion piece on reviews<\/a> before you install one.<\/p>\n\n\n\n

    You cannot mark up your own reviews for star ratings anyway.<\/strong> Separate issue, same page.
    Google’s     review snippet documentation<\/a>, updated 24 July 2026, states that when the entity being reviewed controls the reviews about itself, those pages are ineligible for the star review feature, “including through an embedded third-party widget (for example, Google Business reviews or Facebook reviews widget)”.
    Any agency selling you review schema for stars on your own site is selling you something Google has ruled out in writing.<\/p>\n\n\n\n

    Questions practices ask<\/h2>\n\n\n\n

    Can we use patient reviews on our website at all?<\/strong><\/p>\n\n\n\n

    Only if they contain no reference to clinical aspects, meaning symptoms, diagnosis, treatment or outcome.
    Comments about service, communication or the experience of the visit are not testimonials under the National Law.
    Comments about the work you did are, and those cannot appear in material you control.<\/p>\n\n\n\n

    What about reviews on Google that mention treatment?<\/strong><\/p>\n\n\n\n

    Not your responsibility.
    AHPRA states that advertisers are not responsible for removing unsolicited testimonials on platforms they do not control, and that boards do not expect you to monitor forums you do not control.
    Leave them alone.
    The risk starts when you reproduce them somewhere you do control.<\/p>\n\n\n\n

    Can we offer a discount for new patients?<\/strong><\/p>\n\n\n\n

    Yes, with the terms and conditions of the offer stated in the advertisement.
    That is limb 2 of section 133 in full.
    What you cannot do is structure an offer so that it encourages unnecessary treatment, which is limb 5.<\/p>\n\n\n\n

    Are before and after photos banned?<\/strong><\/p>\n\n\n\n

    No, and AHPRA does not say they are.
    Section 4.4.1 of the advertising guidelines says “care should be taken”, and describes the conditions under which such images are “less likely to be misleading”: consistent content, camera angle, background, framing, exposure, posture, clothing, make-up, lighting and contrast, disclosure of any alteration, and the treatment being the only visible change.
    Anyone telling you before-and-afters are prohibited is overstating the AHPRA advertising rules.<\/p>\n\n\n\n

    Can we describe ourselves as specialists?<\/strong><\/p>\n\n\n\n

    Only if you are registered as one in that field.
    AHPRA’s FAQ 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 alternatives.<\/p>\n\n\n\n

    What is the actual maximum penalty under the AHPRA advertising rules?<\/strong><\/p>\n\n\n\n

    $60,000 per offence for an individual and $120,000 for a body corporate, everywhere except Western Australia, where it remains $30,000 and $60,000.
    The increase came in with the 2022 amendments to the National Law.<\/p>\n\n\n\n

    Does AHPRA enforce this?<\/strong><\/p>\n\n\n\n

    It publishes advertising cases heard by courts and tribunals, and it has run compliance campaigns directed at specific professions.
    The Dental Board issued a public statement in May 2024 urging compliance with advertising rules, which is not the behaviour of a regulator that has stopped looking.<\/p>\n\n\n\n

    Our agency writes our copy.
    Are they liable?<\/strong><\/p>\n\n\n\n

    No. You are.
    The National Law binds the advertiser.<\/p>\n\n\n\n

    Is it against AHPRA rules to say we are the best dentist in our suburb?<\/strong><\/p>\n\n\n\n

    AHPRA publishes no banned-words list and never uses the word “best”.
    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”.
    A claim to be the best in a suburb is a claim of superiority, and you would have to be able to substantiate it.
    In practice nobody can.<\/p>\n\n\n\n

    Can we put “pain-free dentistry” or “painless treatment” on our website?<\/strong><\/p>\n\n\n\n

    Both assert an outcome you cannot guarantee for every patient, which is where limbs 1 and 4 of section 133 bite.
    The lower-risk version describes what you actually do \u2014 the sedation options you offer, the anaesthetic technique, what happens if a patient is anxious \u2014 rather than promising the result.<\/p>\n\n\n\n

    Does AHPRA apply to our Google Ads and our Instagram, or only to our website?<\/strong><\/p>\n\n\n\n

    Every surface where you advertise a regulated health service.
    That includes Google Ads headlines, Google Business Profile descriptions, Instagram and Facebook posts, printed material, signage and the text inside images.
    The rules attach to the advertising, not to the medium.<\/p>\n\n\n\n

    Are our page titles and meta descriptions covered by the advertising rules?<\/strong><\/p>\n\n\n\n

    Yes.
    A <title><\/code> reading “Best Dentist Melbourne” advertises a regulated health service in exactly the way section 4.1 describes, as does a meta description, a heading and an image alt attribute.
    This is where non-compliant language most often survives, because it is usually written once during a site build and never reviewed again.<\/p>\n\n\n\n

    Can we advertise a free consultation or a $99 check-up and clean?<\/strong><\/p>\n\n\n\n

    Yes, provided the advertisement states the terms and conditions of the offer \u2014 what is included, what is excluded, and when it ends.
    That is limb 2 of section 133 in full.
    The separate constraint is limb 5: the offer must not be structured so that it encourages unnecessary treatment.<\/p>\n\n\n\n

    Who is responsible if a patient posts a testimonial on our Facebook page?<\/strong><\/p>\n\n\n\n

    Your practice Facebook page is advertising you control, so a comment about clinical care sitting on it is your responsibility to remove.
    A review the same patient leaves on Google is not, because you do not control that platform.<\/p>\n\n\n\n

    How often do the AHPRA advertising guidelines change?<\/strong><\/p>\n\n\n\n

    They are revised periodically, and the penalty figures moved as recently as the 2022 amendments to the National Law.
    Treat any summary \u2014 including this one \u2014 as a starting point and check the current text on ahpra.gov.au before relying on it.<\/p>\n\n\n\n

    \"Bar\n\t\t\t\n\t\t\t\t\n\t\t\t<\/svg>\n\t\t<\/button>
    The maximum penalty per offence since the 2022 amendments. The $30,000 and $60,000 figures quoted across agency sites are correct in Western Australia and nowhere else.<\/figcaption><\/figure>\n\n\n\n

    Before You Brief Anyone on the AHPRA Advertising Rules<\/h2>\n\n\n\n

    Read your own site as if you were AHPRA.
    Start with the title tags and headings rather than the body copy, because that is where the superlatives usually survive.
    Check every offer for stated conditions.
    Check every review that appears on a page you control for clinical content.
    Check whether your before-and-after images would survive a question about lighting.<\/p>\n\n\n\n

    Then check the penalty figure on your marketing provider’s website.
    If it says $30,000 and they are not in Perth, you have learned something useful about how carefully they read primary sources.<\/p>\n\n\n\n

    We publish a fixed-price audit<\/a> that covers the advertising-compliance layer alongside the technical and search work, and a longer explanation of how we approach search for Australian practices on the SEO for dentists<\/a> page.<\/p>\n\n\n\n

    \n\n\n\n

    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<\/a> and dentalboard.gov.au<\/a> before relying on anything here.<\/em><\/p>\n\n\n\n

    Sources<\/strong><\/p>\n\n\n\n