Before/after photos on UK and AU beauty clinic websites: what you can legally show

Nothing converts a prospective cosmetic patient faster than a well-lit before/after. Nothing sinks a clinic’s marketing faster than a complaint to the advertising regulator. The line between the two is clearer than most clinics think — just rarely followed.

UK — ASA, CAP, and MHRA

In the UK, the Advertising Standards Authority (ASA) and the Committee of Advertising Practice (CAP) govern what you can show. For prescription-only medicines (Botulinum toxin, fillers classified as medical devices in certain formats), specific rules apply under MHRA regulations. The headline rules:

• You may not advertise prescription-only medicines (POMs) to the public. This includes naming ‘Botox’ or any POM by brand.
• Before/after photos for treatments involving POMs must not act as advertising for the POM itself — frame them around the treatment outcome, not the substance.
• Every image needs written, signed, specific consent from the subject — and the consent must cover the medium (your website, social media, print).
• Images must be representative and not misleadingly enhanced. No heavy retouching, filters, or cherry-picked lighting.
• Results disclaimers — ‘individual results vary’ — are expected whenever outcomes are shown.

Australia — TGA, AHPRA, and state rules

Australia went stricter in 2023. The Therapeutic Goods Administration (TGA) and AHPRA jointly regulate cosmetic-procedure marketing, and the rules now meaningfully constrain before/after content:

• You cannot use patient testimonials or images that reference specific therapeutic goods (which includes most injectables).
• Before/after photos must not be the primary advertising mechanism — they must support educational content, not replace it.
• Images must be raw, unedited, and clearly labelled with time-elapsed and treatment type.
• Consent requirements are stricter than the UK — fresh consent for every new use.
• Social-media reposts count. If you share a patient photo on Instagram, the same rules apply.

Practical compliance for your website

Rather than wrestle with edge cases, use this pattern and you’ll be on the right side of both jurisdictions for non-POM treatments like laser, skincare, and surgical dermatology:

• Build a dedicated /gallery page rather than scattering images across treatment pages.
• Each image has: a date, treatment type, number of sessions, time between before/after.
• Disclaimers on every image: ‘Individual results vary’ plus any clinical caveats.
• Written consent stored — ideally digitally signed, dated, and specific to use.
• No POM names (UK) or therapeutic-good references (AU) in image captions.
• Clear labelling where a photo has been lightly adjusted (colour correction, crop) and no transformation beyond that.

“The cost of a compliant gallery is two hours of paperwork. The cost of an ASA or AHPRA complaint is your marketing budget for a year.”

When in doubt, ask

This post is starting-point guidance, not legal advice. The rules evolve — especially in Australia — and specific treatment types have additional constraints (breast augmentation, for instance, has bespoke AHPRA rules). If you’re unsure, the ASA (UK) and AHPRA (AU) both offer pre-publication review for marketing content; use them.

What we ship by default on beauty clinic sites

Every beauty-vertical site we build includes a compliance-aware before/after gallery template: per-image consent capture, time-elapsed and treatment-type metadata fields, automatic disclaimer rendering, and (for AU clinics) the labelling structure required by AHPRA’s 2023 rules. You don’t need to remember the rules — the template enforces them.

From £119/mo on the Business tier. If you’re running a Wix or WordPress gallery today and you’re not sure whether it’s compliant, send us the link and we’ll review it before any commitment. No charge for the review — we’d rather you fix it whether you become a client or not.