Compliance

Healthcare Marketing Compliance

AHPRA testimonials: what you can and can't use

Section 133 prohibits clinical testimonials in healthcare advertising. Here's what AHPRA considers a testimonial, what falls outside the rule, and how to build trust without breaching it.

Under section 133 of the Health Practitioner Regulation National Law, testimonials about clinical aspects of care are prohibited in advertising for a regulated health service in Australia. That covers the obvious things (patient quotes, video testimonials, before-and-after stories) and it catches a lot of things clinics don't realise count, like screenshotted 5-star reviews on Instagram or a "What our patients say" widget on a clinic homepage.

The rule sounds blunt. In practice there's nuance, and the nuance is where most clinics get tripped up. This page covers what counts as a testimonial under AHPRA, what doesn't, and the workarounds that respect the rule rather than try to dodge it.

What AHPRA considers a testimonial

AHPRA defines a testimonial broadly. It's any statement that recommends a regulated health service, refers to a person's experience of the service, or expresses an opinion on the clinical care provided. The format doesn't matter (text, photo, video, audio), and neither does the source (a patient, a family member, a celebrity, an influencer).

If the statement is published in or shared as part of your advertising, and it touches clinical care, it's caught. That includes:

  • Patient quotes on your website ("Dr Smith fixed my back!")
  • Video testimonials on YouTube, Instagram, or TikTok
  • Screenshotted Google Reviews shared on your own channels
  • Case studies that identify a patient or quote their experience
  • Influencer or paid endorsement content praising the service or practitioner
  • "Real patient story" content used as marketing collateral

What isn't a testimonial

Three things sit outside the rule, and each one matters:

Unsolicited reviews on independent platforms. A Google Review, Healthengine review, or RateMDs review left by a patient on the platform itself, with no editorial involvement from the clinic, is generally not considered a testimonial under section 133. The reasoning is that you didn't publish it; the platform did. Once you start embedding it on your own website or featuring it in your ads, that protection disappears.

Comments on the non-clinical aspects of your practice. A patient saying "the reception team was lovely" or "parking was easy" is not commenting on clinical care. Those statements aren't testimonials. In practice the line gets blurry fast, because patients tend to drift between non-clinical and clinical observations within the same review.

Educational case studies that don't identify a patient or quote them. A de-identified clinical explainer ("a 35-year-old patient presenting with X, treated with Y, here's the typical clinical reasoning") can be used. The moment it becomes a marketing story with a named patient and a quote, it's a testimonial.

Worth knowing

AHPRA's own published guidance confirms that reviews on independent third-party review websites are not testimonials within the meaning of section 133, on the basis that they aren't published by the practitioner or business. This is the legal foundation for why Google Reviews are tolerated and why screenshotting them onto your own marketing isn't.

What you can actually use in your marketing

The rule rules out a tactic, not a category. Healthcare clinics still build trust through marketing every day. The patterns that work without breaching section 133:

  • Star ratings as factual information. Displaying an aggregate Google rating (e.g. "4.9 stars on Google") with a link to the platform is generally acceptable. You're stating a verifiable fact, not publishing a clinical testimonial.
  • Practitioner credentials, experience, and approach. Detailed bios, areas of focus, training, qualifications, and a description of how the practitioner works build credibility without quoting a single patient.
  • Educational content. Explainers of conditions, treatments, what to expect at a first consultation. This converts at least as well as testimonials for most healthcare verticals because it answers the questions patients actually have.
  • Practice information and signals. Years operating, number of practitioners, professional memberships, hospital affiliations, awards from peer bodies (where the award itself is appropriate and not promotional in nature).
  • Process transparency. Photos of the clinic, written information about what an appointment looks like, fees and payment options, telehealth availability. These are highly trust-building and entirely compliant.

The Google Reviews question, properly answered

This is the single most common testimonial question we get from clients. The honest answer is: Google Reviews on Google itself are fine. Soliciting them in a blanket, non-incentivised way is fine. Featuring them on your own website, your own ads, or your own social posts is where you trip section 133.

That includes the well-meaning patterns like a "Reviews" tab that pulls in Google ratings via an embed, a slideshow of 5-star quotes in the website footer, a sitelink in Google Ads pointing to "Read our reviews", or a screenshot of a particularly nice review reposted on Instagram with a heart emoji.

The compliant pattern is: keep your reviews on Google. Display the aggregate star rating as a factual statement. Link out to the Google profile. Don't reproduce the content of the reviews inside your own marketing assets.

Where we sit on this

Our team has built marketing for 100+ Australian healthcare clients across a decade, without a single AHPRA notification attributable to our work. The testimonial rule is one of the easiest to comply with once you stop trying to find a creative workaround. Build the campaign around what you can say, not around the patient quote you wish you could publish.

For the broader picture, see the AHPRA advertising guidelines page or the What is AHPRA? explainer. If you'd like a compliance-aware review of your existing marketing, get in touch.

Common Questions

AHPRA testimonials,
answered.

The questions practice owners, marketers, and patients most often ask about testimonials and reviews under AHPRA.

Yes, in most cases. AHPRA's position is that reviews on independent third-party platforms (Google, Healthengine, true industry directories) are generally outside the scope of the testimonial rule, provided the practitioner didn't solicit them improperly and doesn't feature them in their own advertising.

Where it goes wrong is when a clinic embeds those reviews on its website, screenshots a 5-star quote and posts it on Instagram, or runs a Google Ads sitelink to "Read our reviews." At that point the clinic is publishing the testimonial as part of its own marketing, and section 133 applies.

Soliciting reviews from current patients in a way that targets clinical experiences can be problematic. A neutral, blanket request ("If you've valued our service, we'd appreciate a review on Google") is generally accepted. Selectively asking patients who you know had a good outcome, offering incentives, or providing a draft quote is not.

The cleanest pattern is automation that asks every patient the same way, with no incentive attached, and lets them write whatever they want.

If the video says anything about the clinical service, the practitioner, or the outcome the patient experienced, it's a testimonial under section 133, and it's not permitted on advertising material you control. That includes your website, your YouTube channel when it's promoting your practice, your social pages, and any paid ads.

A patient describing their experience of the practice (administration, parking, reception, fees) without referencing the clinical service can sometimes work, but the line is fine and rarely worth the risk.

De-identified, educational case studies that explain a clinical condition and how it might be approached are usually fine, because they aren't testimonials in the section 133 sense. The moment they identify a specific patient or quote them praising the practitioner, they cross the line.

Most clinic case studies as written by marketers are testimonials in disguise. If you're not sure, strip the patient's voice out and present the case as an educational explainer. That's what we do for clients.

Yes, but carefully. Don't confirm whether the reviewer is a patient (that's a confidentiality breach in its own right). Don't argue clinical detail in public. A short, professional reply inviting the person to contact the practice directly is almost always the right move.

If the review is defamatory or breaches Google's policies, you can flag it for removal through Google's process. Don't expect a fast result.

Section 133 advertising offences can attract civil penalties (recently up to around $60,000 per offence for a corporation), and breaches are increasingly published on the AHPRA website by name. The bigger risk for most clinics is a notification that triggers an investigation into broader conduct, which is administratively painful even when it ends in no action.

For most healthcare businesses, the reputational cost of being named in an AHPRA breach notice outweighs the actual financial penalty.

Still have questions? We're here to help.

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