Are These 3 Before & Afters Illegal? AHPRA vs TGA Compliance Breakdown

Hi Facecoachers,

The regulatory landscape in 2026 is, frankly, a bit of a minefield. Between the TGA’s absolute ban on advertising Schedule 4 (S4) medicines and AHPRA’s strict new standards for cosmetic procedures, it’s easy to feel like you’re walking on eggshells every time you want to post a result on Instagram.

We all want to showcase our work. It’s how patients find us and how we build trust. But the rules have changed significantly over the last two years. What was "grey area" in 2024 is now a clear "red light" in 2026.

Today, I want to take a look at three specific uploaded images and call them as they are. We’re going to break down the exact red flags in each one, and why “guarantees” are still the fastest way to get yourself an AHPRA notification.

Case Study 1: Lip Filler

The Verdict: Illegal (TGA + AHPRA problem)

This one is a direct hit.

The first issue is obvious: it’s lip filler. That means we are in Schedule 4 territory, which immediately creates a TGA advertising issue if this is being promoted to the public.

But the overlay language makes it worse.

If the image includes claims like “Results Guaranteed!” and “Pain-Free”, that is a direct compliance breach. You cannot guarantee a medical result. Full stop. And “pain-free” is the kind of absolute claim regulators really dislike because it is misleading, not clinically defensible, and sets up the wrong patient expectation from the start.

This is interesting because even some clinicians who know the TGA injectable rules still miss the advertising language problem. They think the image is the breach. Often, the copy is what turns a bad post into an indefensible one.

There is another major issue here as well. The patient appears to be under 18, or at the very least presents that way in the advertising. Under current AHPRA guidance on cosmetic procedures advertising, you cannot use images of people who are, or appear to be, under 18 to advertise cosmetic procedures. That is a non-negotiable rule designed to protect minors.

So before we even get to “Results Guaranteed!” and “Pain-Free”, the youthful appearance alone would be enough to trigger serious scrutiny.

What’s wrong here:

• Appears to feature a person under 18 = major AHPRA advertising concern

• “Results Guaranteed!” = not acceptable in medical advertising

• “Pain-Free” = misleading and forbidden as an absolute claim

• Lip filler outcome = likely public advertising of an S4 treatment by implication

  
  

We suggest treating the word guarantee as radioactive in cosmetic medicine advertising. If it’s in your artwork, caption, reel cover, or testimonial tile, take it out. And if the patient could reasonably be read as a minor, don’t use the image at all.

Case Study 2: Laser

The Verdict: Still a major red flag

Some practitioners relax when they move from injectables to devices. Fair enough. Laser is not the same regulatory bucket as filler.

But if this image uses “Results Guaranteed!”, that is still a massive problem.

Even where the treatment is device-based rather than medicine-based, guarantees are exactly the sort of wording that can trigger scrutiny. AHPRA expects advertising to be accurate, balanced, and not misleading. A guarantee does the opposite. It suggests certainty of outcome in a setting where results vary by indication, skin type, treatment plan, healing response, compliance, and operator skill.

So yes, the fact that it is a laser image may reduce the TGA injectable issue. It does not rescue the ad from bad advertising language.

There is also a second major red flag here. The person shown appears under 18, or at minimum young enough to raise the issue immediately. Under current AHPRA guidelines, you cannot use images of people who are, or appear to be, under 18 to advertise cosmetic procedures. That is one of the clearest rules in the space.

So again, even before the “Results Guaranteed!” language is assessed, the youthful appearance alone would trigger a massive investigation.

What’s wrong here:

• Appears to feature a person under 18 = major AHPRA advertising concern

• “Results Guaranteed!” = misleading claim

• Device-based treatment or not, a guarantee is still a compliance red flag

• If the image also lacks balanced risk or variability language, the problem gets worse

  
  

We suggest clinicians stop thinking in silos here. Don’t ask only, “Is this injectables or laser?” Also ask, “Would this wording survive an AHPRA complaint?” And just as importantly, “Could this patient reasonably be interpreted as under 18?”

Case Study 3: Facial Rejuvenation

The Verdict: Compliant

This is the only compliant image in the set.

Why? Because this appears to be a Laser treatment. That means we are dealing with a device, not an S4 medicine, so it does not carry the same direct TGA injectable advertising problem as the first image.

Just as importantly, this creative does what the first two do not. It includes the kind of AHPRA risk and variability disclaimers we want to see, such as “Multiple sessions may be required” and “Results are individual”. That matters. It tells the patient that outcomes vary and that treatment may not be a one-and-done event.

This is interesting because it gives us a useful contrast across the set. The first two images fall over because of absolute promotional claims like “Results Guaranteed” and “Pain-Free”, and because both appear to feature patients who are under 18 or could reasonably be read that way. This third image is stronger because it avoids those shortcuts, includes the qualifying information that supports more balanced advertising, and clearly shows an adult patient.

A quick note on cropping. Yes, this image is cropped tightly. But the disclaimers are still present and legible, which is why it meets the standard. That said, practitioners need to be careful. If you crop too hard, you can easily bury or cut off the disclaimer text, and then you have a compliance problem very quickly. We discuss this exact issue in the Monash course because small presentation choices can create big regulatory headaches.

Why this one works:

• Laser treatment = device-based, not an S4 medicine

• Includes AHPRA-style risk and variability disclaimers

• States that multiple sessions may be required

• Makes clear that results are individual

• Clearly features an adult patient

• Avoids the absolute claims used in the first two ads

  
  

Watch-out point:

• Tight cropping is fine only if the disclaimer remains clear and legible

• If you crop too hard and hide the qualifying text, that becomes a compliance risk

  
  

We suggest using this third example as the benchmark. It is not flashy, but it is a much

safer way to present treatment outcomes.

Why the Crackdown?

It’s about patient safety and informed consent. The regulators want to ensure that patients aren't being "sold" a result based on cherry-picked, edited photos that don't represent the reality of medical procedures.

The TGA’s stance on S4 drugs is absolute because these medicines carry risks that require a consultation with a medical professional: not a choice made because of a flashy Instagram post.

AHPRA’s focus is on ethics. They want to prevent the "glamourisation" of medical procedures. This is why we are now seeing bans on influencer testimonials and the requirement for adult-only tags on social media ads for cosmetic procedures.

Navigating the Compliance Minefield

If you're feeling overwhelmed, you're not alone. The rules are complex, and the penalties for non-compliance are significant: ranging from heavy fines to conditions being placed on your registration.

This is exactly why we developed the Patient Suitability, Governance, Compliance and Ethics of Non-Surgical Cosmetic Medicine course at Monash University.

This isn't just another clinical course. It’s a 12-week, fully online intensive designed to help you build a practice that is safe, ethical, and fully compliant with the latest Australian laws.

We cover:

• Advertising Legislation: How to promote your services without triggering a TGA or AHPRA audit.

• AHPRA & NMBA Guidelines: Staying within your scope and meeting the latest standards.

• Poisons Legislation: Understanding the legalities of Schedule 4 and Schedule 8 medicines.

• Ethical Frameworks: How to manage patient expectations and identify high-risk patients (like those with Body Dysmorphic Disorder).

The course involves 144 notional hours of learning, providing you with a Monash University certification that signals to your patients: and the regulators: that you take professional responsibility seriously.

Final Thoughts

We suggest doing an "audit" of your own social media and website today. Look at your B&As through the eyes of a regulator.

• Does this show the effect of a prescription medicine?

• Have you used words like guaranteed, pain-free, safe, or natural?

• Is the disclaimer actually visible, legible, and complete?

If there is one takeaway from these three examples, it’s this: guarantees are the fastest way to get an AHPRA notification. They are easy for a complainant to spot, hard to defend, and completely unnecessary if your practice is already good.

If you aren't 100% sure, it's time to invest in your governance knowledge. The prestige of a Monash certification is a great asset, but the peace of mind knowing your practice is compliant is priceless.

Check out the course details here: Monash University - Patient Suitability and Governance.

Stay safe out there, Facecoachers.

Mike ClagueDirector