AHPRA & TGA · Images
Before-and-after photo rules for cosmetic clinics
You can use them. They just have to clear two regulators at once.
AHPRA governs the image. The TGA governs any reference to a prescription-only substance. A before-and-after that satisfies one but not the other is still a breach. This is general information, not legal advice. Last reviewed 14 June 2026.
The AHPRA conditions for higher-risk procedures
For higher-risk non-surgical procedures, the image rules are specific and checkable. Both images must be of genuine, actual patients of that practitioner who had that procedure. Each of these has to be true:
- ▸Genuine actual patients of that practitioner, who had that procedure. Not stock, not someone else’s work.
- ▸No editing. No filters, retouching, grey-scaling or enhancement of any kind.
- ▸A prominent warning that the outcomes shown are only relevant for that patient.
- ▸The “after” must not be the most prominent or first image. Lead with the “before”, or a composite.
- ▸State how long after the procedure the “after” was taken.
- ▸Never use images of anyone under 18.
Even outside the higher-risk category, AHPRA’s general guideline only treats a before-and-after as low-risk when the two images match. Same content, angle, background, framing and exposure. Same posture, clothing and make-up. Same lighting and contrast. Any alteration spelled out, and the treatment the only visible change. Miss one and the gallery can mislead.
The unreasonable-expectation rule
Images, not just words, can create an unreasonable expectation of benefit, which breaches section 133. If a photo exaggerates the outcome or downplays recovery, it crosses the line even when no words do. One person’s result doesn’t predict anyone else’s, and the guideline applies that directly to before-and-after images.
The TGA layer for injectables
The TGA doesn’t prohibit before-and-after photos for your health service. But if the after is the result of a prescription-only injectable, the photo must not reference that substance, directly or indirectly. A caption, hashtag or tag that points to the medicine turns a compliant image into an unlawful ad for the product. So injectable galleries have to clear AHPRA’s image rules and the TGA’s naming ban together.
Common questions
Can cosmetic clinics use before-and-after photos at all?
Yes, but they have to satisfy two regulators at once. AHPRA governs the image itself, and for higher-risk procedures the conditions are strict. The TGA governs any reference to a prescription-only substance. A photo that clears one but not the other is still a breach.
What makes a before-and-after image compliant under AHPRA?
For higher-risk procedures: genuine actual patients of that practitioner who had that procedure, no filters or retouching or enhancement, a prominent warning that outcomes are only relevant for that patient, the after image not the most prominent or first one, a note of how long after the procedure it was taken, and never images of anyone under 18.
Why can’t the “after” image be the first thing people see?
Leading with the after can create an unrealistic expectation of the result, which is its own breach. AHPRA wants the most prominent or first image to be the before, or a composite, so the comparison is honest rather than aspirational.
Does the TGA affect my before-and-after photos too?
Yes, for injectables. The photos must not reference, directly or indirectly, the prescription-only substance used. So even a compliant AHPRA image becomes a breach if it’s captioned or tagged in a way that points to the prescription medicine.
The full two-regulator rulebook is here.
Before-and-after photos are one piece. The complete AHPRA and TGA picture, including injectables, testimonials and the September 2025 rules, is in the pillar guide.
Read the 2026 rulebookSources