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.
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.