Start with the broader framework: Healthcare Advertising & AHPRA: A Practical Guide for Australian Practices.
Of everything a derm, plastics, cosmetic or dental practice puts on its website, before and after photos are the asset most likely to cause a problem. They are also the asset practices are most reluctant to give up, because they work. A good gallery is persuasive in a way words never are, which is exactly why AHPRA scrutinises it so closely.
It is worth walking through this the way you would with a colleague who has just asked, half-hoping for a yes, whether they can put their gallery back up. The honest answer is: sometimes, under strict conditions, and only if you are prepared to do it properly. This is one of the areas where a well-meaning practice can breach the rules without ever intending to mislead anyone.
This article is general information about advertising compliance, not legal advice. AHPRA's guidelines are the authority and the details change over time, so check the current AHPRA and Medical Board guidance for your profession before you publish any images. This piece builds on our longer AHPRA advertising rules guide, which is the place to start for the full picture.
Why before and after photos are treated as high-risk
Start with the reason, because it makes everything else make sense. A before and after image is a claim about outcome. It says, in effect, "this is what this treatment does." And a claim about outcome is precisely the kind of advertising AHPRA watches most carefully, because it is so easy to create an unrealistic expectation in a patient who is worried, hopeful, and comparing themselves to the person in the photo.
Under Section 133 of the Health Practitioner Regulation National Law, advertising must not be false, misleading or deceptive, and must not create an unreasonable expectation of beneficial treatment. A before and after gallery sits right on top of both of those. One patient's result tells you very little about what the next patient will get, yet the format quietly implies otherwise. That gap between what the image shows and what a new patient can realistically expect is where the compliance risk lives.
This is not a fringe concern. AHPRA has singled out cosmetic advertising as a priority enforcement area, and before and after imagery is named repeatedly in its guidance as a place practices get into trouble. If you work in cosmetic, dermatology, plastics or dental, treat your gallery as one of your highest-risk pages, not a routine bit of marketing.
What AHPRA actually requires
First, work out which rulebook applies to you. Read the higher-risk non-surgical cosmetic advertising guidelines and, where relevant, the Medical Board cosmetic surgery advertising guidelines. Every practice using before and after images is bound by the general advertising guidelines: the images must be genuine, and the comparison must not be manufactured. If you advertise higher risk cosmetic procedures, a second, stricter layer applies on top. The cosmetic guidelines add conditions around consent, warnings, timing, image order and age that the general rules do not impose. Most of the detail below comes from that stricter layer, so a dermatology practice doing general skin work is held to less than a cosmetic injectables clinic. Check which one you are before assuming the whole list binds you.
If you are going to use before and after images, the requirements are specific. AHPRA's advertising guidance and its cosmetic guidelines set out what a compliant image looks like. Here is the plain-English version.
The images must be genuine. They must be of actual patients who had that procedure performed by the practitioner advertising it. No stock photos, no manufacturer-supplied examples presented as your own work, no borrowed results.
The before and after must be standardised. This is the one practices underestimate most. AHPRA expects the two images to be as similar as possible in content, lighting (including any use of flash), camera angle, background, framing and exposure, posture, clothing and makeup. The point is that the comparison should be genuine: the after image should look better because of the treatment, not because someone changed the lighting, softened the pose, added makeup, or shot from a more flattering angle.
No editing, filters or retouching. Images used to advertise cosmetic procedures must not be edited or enhanced, so no filters, retouching, grey-scaling or similar techniques, because these can mislead about the real result, whether by enhancing the outcome or minimising something like bruising. The correct way to achieve consistency is to capture the images consistently, not to fix them in software afterwards.
A prominent variability warning. Images intended to show outcomes must carry a prominent warning that the result shown is relevant only to that patient and does not necessarily reflect what other patients will experience. A small "results may vary" in a footer is not the standard; the warning is meant to be clear and visible alongside the image.
Specify the timeframe. The after image should state how long after the procedure it was taken. "Six weeks post-treatment" is meaningful information; an undated after shot implies a permanence or immediacy that may not be real.
Do not lead with the after image. AHPRA's cosmetic guidance flags that the most prominent or first image a viewer sees should be the before image, or a combined before-and-after composite, not the after on its own. Leading with the glamorous after shot is treated as more likely to create an unrealistic expectation.
Specific, informed consent. For higher risk cosmetic procedures you need "fully informed consent from patients, separate from the consent to the higher risk cosmetic procedure": written, for that exact advertising use, obtained through a genuine process. A clinical photography consent buried in an intake form is not the same as consent to publish someone's face on your homepage. Consent must also remain revocable: if a patient withdraws it, you are expected to remove their images promptly, so you need a way to find them.
As a matter of basic practice, we would not seek advertising consent from a patient whose capacity to give it might be impaired, or who is otherwise vulnerable, though note that is our own line rather than something we can point to in the guidelines.
No images of anyone under 18. This one is absolute in the cosmetic guidelines. Not with parental consent, not with the face cropped: images of people under 18 must not be used in advertising higher risk cosmetic procedures.
The 2023 and 2025 context you need to know
Two waves of reform tightened all of this, and where your obligations sit depends partly on what you do.
In 2023, the Medical Board of Australia's guidelines for medical practitioners who perform cosmetic surgery and procedures came into effect, raising the bar on consent, cooling-off periods and how outcomes may be portrayed. Information provided to patients must not glamorise surgery, minimise its complexity, overstate results, or imply outcomes that are not realistic, and before and after imagery is one of the main ways practices accidentally do exactly that.
Then from 2 September 2025, AHPRA's new guidelines for non-surgical cosmetic procedures extended similar safeguards across all registered health practitioners, so the tighter expectations no longer apply only to surgeons. If your work involves injectables, energy-based devices, or other non-surgical cosmetic treatments, you are now inside the higher-risk advertising regime. We cover that shift in detail in our guide to AHPRA's 2025 cosmetic advertising changes.
The practical takeaway: guidance from a few years ago is not a safe reference point. Work from the current version for your profession.
What makes a before and after non-compliant
Most breaches we see are not deliberate. They are ordinary galleries that quietly fail one or more of the conditions above. These are the traps that come up again and again.
| The trap | Why it breaches | The fix |
|---|---|---|
| After image is better lit, better posed, or has makeup the before doesn't | Misleading, because the improvement isn't only the treatment | Standardise capture so both images match |
| Any filter, retouch or smoothing on either image | Prohibited editing that flatters the result | Use only raw, unaltered images |
| Best-ever result shown with no context | Implies a typical outcome that isn't typical | Show representative results and warn that results vary |
| No timeframe on the after image | Implies immediacy or permanence that may be false | State how long after treatment the photo was taken |
| Leading with the after shot | More likely to create unrealistic expectation | Lead with the before, or a combined composite |
| No visible variability warning | Fails the required disclosure | Add a prominent "individual results" warning |
| Generic clinical consent, not advertising consent | Consent doesn't cover this use | Obtain specific written consent for advertising |
| No mention of risk, recovery or downtime near the image | Presents benefit without balancing information | Accompany images with realistic risk and recovery information |
Notice how many of these are about what surrounds the image, not the image itself. A single striking result, presented as if it were what everyone gets, with no risks, no recovery information and no timeframe, is misleading even when the photo is completely real. Cherry-picking your best case is one of the easiest ways to breach without ever touching an editing tool.
A safe decision framework
When a practice asks us whether to run a gallery, we do not start with the photos. We start with four questions, in order.
1. Do we actually need before and after images to make our case? Often the honest answer is no. Qualifications, a clear explanation of the procedure, realistic outcome ranges, and factual education do most of the persuasive work without going near the risk. If images are a nice-to-have rather than essential, the safest gallery is no gallery.
2. Can we meet every condition, every time? Standardised capture, no editing, specific consent, timeframes, variability warnings, accompanying risk and recovery information, and leading with the before image. This is an all-or-nothing standard. If you cannot commit to all of it as a repeatable process, you should not publish images at all, because a partial effort is what gets audited.
3. Is this a fair representation, not a highlight reel? If you would only ever show your single best result, that is a signal the format is misleading. Compliant imagery represents what patients realistically achieve, not the outlier.
4. Do we have a system to keep it compliant over time? Consent can be withdrawn, guidelines change, and staff move on. You need a way to remove an image quickly if a patient revokes consent, and a habit of re-checking the current AHPRA and Medical Board guidance before anything new goes up.
If you cannot answer all four cleanly, the conservative choice, and the one we usually recommend, is to leave before and after photos off the public site and compete on substance instead. It is a genuinely defensible position, and it removes an entire category of risk in one decision.
The bottom line
Before and after photographs can carry substantial advertising risk. Check the current rules for the procedure, the full presentation of the images and the consent process before publication. A genuine photograph can still mislead when its surrounding claims imply more than the evidence supports.
The mindset that keeps you safe is the same one that runs through everything we write about AHPRA: describe what you do factually, respect how differently patients respond, and never let the marketing imply more than the medicine can deliver. If you are confident you can meet every condition and keep meeting it, a carefully built gallery can be compliant. If you are not, there is no shame in the safer path.
This is exactly the kind of judgement we build into a site from the start, rather than fixing after a complaint. If you would rather not carry the risk of interpreting all of this yourself, our AHPRA-compliant content service helps prepare and review your pages, including how proposed images are presented. Your practice remains responsible for clinical accuracy, consent and final approval; seek legal advice where needed.
