New Zealand Just Changed the Rules on Advertising Cosmetic Procedures: What Australian Injectors Can Learn
Hi Facecoachers,
New Zealand has just tightened its approach to therapeutic and health advertising.
The updated Therapeutic and Health Advertising Code took full effect on 1 July 2026.
This matters to Australian injectors because the direction of travel is clear: regulators are looking more closely at social media, testimonials, influencer arrangements, before-and-after images and the claims made around cosmetic procedures.
There is also an important difference between the two countries.
New Zealand continues to permit direct-to-consumer advertising of approved prescription medicines, including botulinum toxin. Australia does not permit direct-to-consumer advertising of prescription-only medicines under the Therapeutic Goods Act 1989.
So, what is legal in Auckland may be an AHPRA or TGA breach in Sydney.
What changed in New Zealand?
The new New Zealand Code applies to all media. That includes:
Websites and online booking pages
Instagram, Facebook, TikTok and YouTube
Influencer and creator content
Email and SMS marketing
Brand-controlled comments and reviews
User-generated content appearing on a clinic’s channels
Traditional print, radio and television advertising
The ASA announcement confirming the Code took effect explains the main changes.
The important point is that advertising is no longer just the post your clinic creates. It can also include what happens underneath that post.
If a patient comments, “This completely fixed my face,” and the clinic leaves the comment visible, reacts positively to it or uses it in marketing, that may create a compliance problem.
Advertisers are expected to actively moderate their own social channels and remove non-compliant user-generated content.
The evidence must exist before you publish
The new Code makes the expectation clear: claims must be supported by sound, relevant and robust evidence before publication.
Not after somebody complains.
This applies to claims about:
Safety
Effectiveness
Duration of results
Patient suitability
Comparative performance
Clinical outcomes
The use of scientific studies or data
We suggest keeping an evidence file for every clinical or therapeutic claim used in your marketing.
If you cannot produce the relevant study, product information or data that supports the wording, do not publish the claim.
“Guaranteed,” “risk-free,” “permanent,” “best,” “miracle” and “no downtime” are obvious warning signs. But more subtle wording can also create problems if the overall impression is misleading.
The same principle is highly relevant to Australian cosmetic medicine advertising under the AHPRA advertising guidelines.
Testimonials and endorsements are a major risk area
Under the New Zealand framework, testimonials must be genuine and typical. They must not make therapeutic or health claims. Any payment or benefit must also be disclosed.
That includes a gifted treatment.
However, the Medical Council of New Zealand takes an even stronger position for doctors. Its statement on cosmetic procedures says doctors must not glamourise cosmetic procedures, overstate results or foster unrealistic expectations.
Testimonials are strictly prohibited on any platform a doctor controls.
New Zealand advertising must also not imply that a product, treatment or service has been recommended or endorsed by a registered health professional.
For Australian practitioners, the practical answer is straightforward:
Stop using patient testimonials as cosmetic treatment marketing.
In Australia, the use of testimonials and reviews in cosmetic advertising is restricted under AHPRA expectations. A patient saying they are “thrilled” with a treatment may seem harmless, but once that comment is displayed, promoted or incorporated into your marketing, it can become advertising content.
This is interesting because many clinics treat social media comments as outside their responsibility. The new New Zealand approach makes the opposite expectation clear.
Before-and-after images need discipline
Before-and-after images are not automatically safe simply because they are real.
In New Zealand, images must be unaltered and realistic. They should be taken using consistent:
Lighting
Camera angle
Distance
Background
Exposure
Facial expression and positioning
That means no filters, no skin smoothing and no selective cropping that exaggerates the treatment area.
There should also be no suggestion that the result is guaranteed or typical for every patient.
For Australian clinics, we suggest treating every image as a clinical record first and a marketing asset second.
Consent for photography is separate from consent for treatment. Your image consent should be specific to marketing use, explain where the image may appear and allow the patient to withdraw consent where practicable.
Avoid images of anyone who may appear under 18. Avoid tightly cropped treatment-area images. Do not use images that create an unrealistic body image or imply that a procedure will produce a particular result for every patient.
New Zealand versus Australia
Issue | Australia | New Zealand |
Direct-to-consumer advertising of prescription medicines | Prohibited for prescription-only medicines, including botulinum toxin | Permitted for approved prescription medicines, subject to the Medicines Act, Medicines Regulations and advertising rules |
Testimonials | Restricted under AHPRA advertising requirements; practitioners remain responsible for advertising content | Therapeutic testimonials are restricted, and doctor-controlled testimonials are strictly prohibited by the Medical Council |
Before-and-after images | Must be realistic, unaltered, appropriately consented and compliant with AHPRA advertising expectations | Must be unaltered, realistic and consistent in technique; must not imply guaranteed outcomes |
Main regulator/framework | TGA, AHPRA, Medical Board of Australia, Nursing and Midwifery Board of Australia and relevant state legislation | Medicines Act 1981, Medicines Regulations 1984, ASA Therapeutic and Health Advertising Code and Medical Council of New Zealand |
Dermal fillers are classified as medical devices in New Zealand. That does not mean they can be promoted without controls. False or misleading claims, inappropriate urgency, unrealistic outcomes, professional endorsements and therapeutic testimonials remain prohibited or heavily restricted.
The governing New Zealand framework includes the Medicines Act 1981, Medicines Regulations 1984 and the ASA Code.
The Therapeutic Products Act 2023 was repealed in 2024. The Medicines Amendment Act 2025 is also relevant to prescribers.
The planned Medical Products Bill, expected to be introduced to Parliament in 2026, is intended to continue permitting direct-to-consumer advertising of approved prescription medicines. The government has stated that it found no compelling evidence of significant public health harm to justify a complete ban.
However, the Bill is expected to provide a clearer definition of advertising and give the government power to restrict specific practices, such as advertising targeting children.
New Zealand advertisers can also use the voluntary Therapeutic Advertising Pre-vetting Service, or TAPS. It is not a substitute for legal responsibility, but advertisers are strongly encouraged to use it.
What Australian injectors should do now
Here is the practical checklist I would suggest for Australian clinics.
1. Audit your social media channels
Review posts, comments, tagged content and patient replies.
Ask:
Are patients making therapeutic claims?
Are staff liking or reinforcing those comments?
Are old posts still visible?
Are influencers describing gifted treatment?
Are your hashtags referring to prescription-only products?
Under the New Zealand Code, brand-controlled user-generated content must be moderated. The same risk exists in Australia under AHPRA advertising expectations.
2. Remove testimonials from treatment marketing
Do not ask patients to provide reviews describing their clinical results.
Do not repost comments saying a treatment was “life changing,” “pain-free,” “permanent” or “the best decision ever.”
If an influencer receives a free or discounted treatment, the benefit must be disclosed clearly. It should not be hidden in a hashtag list or written in a way that consumers are unlikely to understand.
3. Standardise your photography
Use the same lighting, angle, distance and background.
Do not use filters or retouching.
Do not crop tightly to isolate a treatment area. Do not present a single dramatic result as though it is guaranteed.
4. Ask what the patient has seen online
During consultation, ask:
“What have you seen online about this treatment?”
This gives you an opportunity to correct unrealistic expectations before treatment.
The Medical Council of New Zealand specifically expects doctors to address pre-conceived expectations formed by advertising and social media. That matches the broader Australian focus on patient suitability, informed consent and professional responsibility.
5. Keep your evidence ready
Before publishing a claim, keep the supporting evidence on file.
If the claim relates to a prescription medicine or medical device, check that it is consistent with the approved use and the relevant product information.
In Australia, always consider the TGA position before mentioning a prescription-only product in consumer-facing content.
Build advertising compliance into your clinical governance
Advertising is not separate from patient safety.
The wording used in an Instagram post can influence who books, what they expect and whether they understand the risks. That makes advertising part of clinical governance.
This is one reason I developed the Patient Suitability, Governance, Compliance and Ethics of Non-Surgical Cosmetic Medicine course with Monash University.
It is a 12-week, fully online intensive course involving 144 notional hours, with Monash University certification. It is designed for AHPRA-registered doctors and nurses who are offering, or planning to offer, non-surgical cosmetic procedures.
The course covers:
Advertising legislation
AHPRA and NMBA guidelines
Body dysmorphia assessment
Poisons legislation
Patient consent
Medical ethics in aesthetics
National governance frameworks
Clinical assessment of patient suitability for lasers, botulinum toxins and soft tissue fillers
The next intake begins 1 February 2027.
If you are looking for cosmetic injector compliance training or a cosmetic medicine course in Australia, you can find the course details here.
Use the code FIRST50STUDENTS where relevant.
The key lesson from New Zealand is simple: your advertising is part of your professional responsibility.
Keep the claims evidence-based. Remove the hype. Moderate your channels. Protect vulnerable patients. And make sure the expectations created online can be responsibly addressed in the consultation room.
Regards,
Mike Clague
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