Ahpra's advertising guidelines apply to every psychologist who promotes a service, including websites, directory listings and social media. Section 133 of the National Law bans five things: false or misleading claims, inducements without stated terms, testimonials, unreasonable expectations of benefit, and encouraging unnecessary treatment. Breaches carry penalties of up to $5,000 per offence for an individual.
These are not soft guidance. They sit in legislation, they are enforced by prosecution, and the most commonly broken one, the testimonial ban, is usually broken by a reviews widget somebody installed on the practice website years ago and forgot about. Here is what the Guidelines for advertising a regulated health service actually say, plus the psychology-specific traps generic allied health articles miss.
What counts as advertising for a psychologist?
Broader than most clinicians assume. Ahpra's definition covers "all forms of verbal, printed or electronic public communication that promotes a regulated health service provider to attract a person to the provider", with examples including websites, social media, business cards, office signs, letterheads, directory listings and patient recall notices.
Three exclusions matter day to day. Material given to a client in a consultation explaining their condition, where they can ask questions, is not advertising, so psychoeducation handouts are fine provided they do not slide into promoting your services. Neither is treatment or cost information discussed in a consultation: quoting your fee on the phone is not advertising, publishing it on your website is. Nor are comments a client makes on an account you do not own or control.
Anything an agency, VA or associate publishes for you is still yours: Ahpra defines the advertiser as whoever "publish[es] or authorise[s] content or direct[s] someone to publish or draft content (including a third party, staff member or marketing agency)". Outsourcing the work does not outsource the liability.
Can psychologists use testimonials or Google reviews?
No, not in advertising, and this is where most practices are quietly non-compliant. Section 133(1)(c) prohibits advertising that "uses testimonials or purported testimonials about the service or business", a purported testimonial being anything that merely looks like one. But the rule is narrower than the folklore. Ahpra says plainly that "not all reviews or positive comments made about a regulated health service are considered testimonials". A comment is only a testimonial when it touches a clinical aspect, which Ahpra defines as one of three things:
- Symptom: the specific symptom, or the reason the person sought treatment.
- Diagnosis or treatment: the specific diagnosis, or the treatment provided.
- Outcome: the specific outcome, or the practitioner's skills or experience, directly or by comparison.
So "the reception team was lovely and I never waited more than five minutes" is customer service feedback, not a testimonial. "She helped me beat my panic attacks in six sessions" hits all three triggers and cannot appear in your advertising.
Who is responsible when the review sits on someone else's platform?
Responsibility follows control:
- Your own website republishing reviews, and your business social media page with a reviews function: you are responsible. Where a platform does not let you edit or delete reviews, Ahpra says compliance "may be achieved by disabling the reviews/testimonials functions".
- A third party booking site or review platform where you cannot control the reviews function: the platform owner is responsible for the reviews, and you remain responsible for the profile content you do control.
- A directory or discussion forum not advertising a health service: advertisers "are not responsible for removing (or trying to have removed) testimonials published on platforms they do not control".
One caution practices miss: thanking a client publicly for a clinical compliment may itself count as using a testimonial to advertise. The audit is short. Turn off the Recommendations tab on your Facebook page, remove any embedded reviews widget, delete the "what our clients say" section, and leave the Google reviews alone, because they are not yours to police.
Why psychologists cannot say they "specialise in" anything
This trap is unique to psychology. The National Law protects specialist titles and, separately, endorsements. The Psychology Board states directly that "area of practice endorsement is different from specialist registration", and points practitioners to its explanation of "why there is no specialist registration in psychology". Psychology has approved areas of practice for endorsement, including clinical psychology, counselling psychology, clinical neuropsychology and educational and developmental psychology, but no recognised specialties at all.
Ahpra's position is unambiguous. Where a practitioner does not hold specialist registration, the National Boards consider that "any advertising using words or titles related to specialty is likely to mislead the public", expressly "includ[ing] advertising that uses the words, or variations of the words or phrases 'specialist', 'specialises in', 'specialty', or 'specialised'".
Because no psychologist holds specialist registration, no psychologist can safely use those words. Ahpra gives the alternative in the same paragraph: "substantial experience in" or "working primarily in" are "less likely to be misleading".
In practice that means rewriting three common lines:
- "Specialising in adolescent anxiety" becomes "substantial experience working with adolescent anxiety".
- "Trauma specialist" becomes "works primarily with trauma presentations".
- "Our specialty is couples therapy" becomes "our practice works primarily with couples".
One related rule travels with this: you may only use a title relating to an endorsement if you hold it, in your business name as well as your advertising, so "Clinical Psychology Services" as a trading name is a claim you must be able to back. Qualifications themselves are fine when stated accurately, a masters degree or "10 years' experience working at clinic XY", because the line falls between describing what you have done and implying a registration category you do not hold.
What claims can you make about therapy working?
Only claims you can substantiate. Advertising is false, misleading or deceptive when it "makes statements about the effectiveness of the treatment that are not supported by acceptable evidence", or makes "unqualified claims about the effectiveness of treatment by listing health conditions that a treatment or service can 'assist with' or 'treat'". That second limb catches the "conditions we treat" list on most practice websites.
Acceptable evidence, in Ahpra's framing, is "empirical data from formal research or systematic studies in the form of peer-reviewed publications". Anecdotal observations from practice and self assessment studies generally will not qualify, and the bar sits deliberately higher than the evidence you weigh in clinical decision making, because an advertisement gives nobody the chance to ask a question.
Advertising must also not create an unreasonable expectation of beneficial treatment. Ahpra flags exaggerated recovery times and words such as "safe", "effective", "risk-free" or "pain-free" used without acknowledging possible adverse reactions or mixed evidence. Client stories are called out directly, "as the outcomes experienced by one person do not necessarily reflect the outcomes that other people may experience", which catches a de-identified composite case study as readily as a named one.
What about discounts, first-session offers and social media?
Discounts and gifts are allowed, but only when "the advertisement also states the terms and conditions of the offer", in plain language. Ahpra's breach examples include price information that is "unclear, inexact or vague" and offers omitting restrictions such as expiry dates or eligibility. Where the terms will not fit alongside the offer, link to them, and do not make the public "exhaustively search for or contact the advertiser" to find them. Our guide to psychologist fees in Australia covers presenting fees clearly.
The fifth prohibition, encouraging indiscriminate or unnecessary use of services, governs urgency marketing. Ahpra names the phrases: "don't delay", "act now before it's too late", "don't miss out", "time is running out", "for a limited time only", where they are tied to unsubstantiated claims that someone's health will suffer without the service. It also captures encouraging regular appointments with no clinical indication, worth weighing before advertising a block of sessions, and your cancellation policy is the better place to set frequency expectations.
On social media, Ahpra's guidance is that the National Law, your Board's code of conduct and the advertising guidelines "apply, just as when you interact in person". It also states practitioners "will not be investigated purely for holding or expressing their views on social media", while drawing a firm line at discrimination and racism.
Confidentiality is the risk that eclipses the advertising rules here. A clinical vignette posted to Instagram can identify someone through details you did not think were identifying, and consent does not fully cure it. Our guide to when a psychologist can break confidentiality sets out the boundaries.
What happens if you breach the advertising rules?
Section 133 sets a maximum penalty of $5,000 per offence for an individual and $10,000 for a body corporate. Title breaches are far worse: up to $60,000, three years' imprisonment, or both for an individual, and $120,000 for a body corporate (Western Australia applies lower maximums of $30,000 and $60,000).
For registered practitioners, prosecution is only one tool. Ahpra can investigate your conduct, impose conditions restricting your ability to advertise, or take disciplinary action through a panel or tribunal. Enforcement is risk based, and Ahpra confirms it "will only take regulatory action where there is a risk to the public".
Two things Ahpra will not do: give you legal advice, and pre-approve your advertising. If a claim is borderline, the guidelines direct you to "seek appropriate independent advice from their legal adviser or indemnity insurer", and your insurer will usually answer at no cost.
An annual audit is a half hour job when your public facing material and client records sit in one system rather than across a website builder, a booking widget and three social accounts. PractaLuma is AI-native practice management software for Australian mental-health practices, and consolidating practice operations is part of what makes that audit tractable. If you are setting up now, our guide to starting a private psychology practice covers registration, insurance and software in sequence, alongside PractaLuma plans.
Frequently asked questions
Can I ask clients for a Google review? Asking is not itself prohibited, and Ahpra does not stop clients posting reviews. The prohibition bites when you use a clinical review in advertising. Google reviews sit on a platform you do not control, so you are not responsible for them, but do not republish them on your site and be careful about replying to clinically specific ones.
Are testimonials from other health professionals allowed? No. Section 133(1)(c) covers testimonials about the service or business without limiting who wrote them, so a referring GP's endorsement of your clinical work is caught the same way a client's is.
Can I write "clinical psychologist" if I hold a masters in clinical psychology? Only if you hold the clinical psychology area of practice endorsement on your registration. Claiming a title relating to an endorsement you do not hold is a title offence, not merely an advertising breach, and it carries the higher penalties.
