Optometry Advertising Rules Australia 2025 — AHPRA, TGA & ACL Compliance Guide
Australian optometrists operate under a dual regulatory framework: as AHPRA-registered health practitioners subject to the National Law s.133 advertising restrictions, and as retailers of therapeutic goods (contact lenses, certain ophthalmic products) subject to the TGA Advertising Code 2021. This guide covers every major compliance obligation for optometry practices in Australia.
Contents
Regulatory Overview
Optometrists are registered under the Optometry Board of Australia (an AHPRA national board). All advertising by or on behalf of a registered optometrist must comply with:
- Health Practitioner Regulation National Law 2009 s.133 — prohibits false/misleading claims, prohibited testimonials, unreasonable outcome expectations, and encouragement of unnecessary treatment
- AHPRA Advertising Guidelines (2020, updated 2023) — detailed guidance on testimonials, before/after photos, and social media
- Optometry Board of Australia Guidelines — profession-specific guidance on scope of practice advertising
- Therapeutic Goods Advertising Code 2021 — applies to therapeutic medical devices including contact lenses
- Australian Consumer Law (ACL) — prohibits misleading conduct, false representations, and unfair pricing practices
Key distinction: Optical dispensers are not AHPRA-registered and are not subject to the National Law s.133 testimonial ban — but they are still bound by ACL and TGA rules for any therapeutic products they supply.
Testimonial Ban & Patient Reviews
Under National Law s.133(1)(c), registered optometrists must not use testimonials or endorsements about professional services. This is one of the most commonly misunderstood rules in optometry marketing.
What is prohibited
- Quoting patient reviews in your own advertising or website
- Re-sharing Google, Facebook, or Healthengine reviews on your clinic channels
- Video testimonials from patients about your clinical care
- Screenshots of positive reviews used in social media posts
- "What our patients say" sections on clinic websites
Third-party review platforms
Google Reviews and similar platforms are not controlled by the practice, so their existence alone is not a breach. However:
- You must not solicit testimonials about clinical services from patients
- You must not re-share clinical testimonials on your own channels
- Responding to reviews is generally acceptable but responses must not amplify clinical claims
2023 AHPRA update: AHPRA clarified that practices cannot provide incentives (e.g. discounts, competition entries) in exchange for patient reviews about clinical services.
TGA Rules for Contact Lenses & Ophthalmic Products
Contact lenses are classified as Class IIa therapeutic medical devices under the Therapeutic Goods Act 1989 and must be listed on the Australian Register of Therapeutic Goods (ARTG). Advertising of these products is regulated by the TGA Advertising Code 2021.
Contact lens advertising — key rules
✅ Permitted
- Advertising ARTG-listed contact lens brands by name
- Promoting comfort, wearability, and convenience features
- Comparing prices between equivalent listed products
- Advertising availability of daily, fortnightly, monthly lens options
- Promoting dry-eye compatible lenses (without unsubstantiated medical claims)
❌ Prohibited
- Claims of disease treatment (e.g. "treats keratoconus")
- Comparing therapeutic performance without clinical evidence
- Claiming superiority over other ARTG-listed devices without evidence
- Using testimonials about therapeutic outcomes for lenses
- Advertising prescription contact lenses in a way that bypasses practitioner involvement
Ophthalmic drops and supplements
Eye drops and ophthalmic supplements may be scheduled medicines or listed therapeutic goods. The advertising rules depend on classification:
Cosmetic contact lenses: Coloured or decorative contact lenses are Class IIa medical devices. Advertising them as "fashion accessories" without noting they require professional fitting and are therapeutic goods is a TGA compliance risk.
Outcome Claims & Visual Acuity Advertising
National Law s.133(1)(d) prohibits creating an unreasonable expectation of beneficial treatment. Visual outcome claims require particular care.
Visual acuity claims
Myopia control advertising
Myopia control is a growing area of optometry marketing. Claims must be:
- Supported by current clinical evidence (e.g. peer-reviewed studies for Ortho-K, multifocal lenses, atropine)
- Qualified with individual variation statements
- Not presented as guaranteed outcomes
- Not suggesting that delay in treatment will cause identifiable harm (could constitute encouraging unnecessary treatment)
Before/after imagery
AHPRA's 2023 guidelines restrict before/after comparisons. For optometry, this means visual comparisons showing simulated vision with vs. without correction must:
- Not imply specific outcomes for individual patients
- Clearly label that images are illustrative/simulated
- Not use actual patient eye images without careful compliance review
Pricing, Bulk Billing & ACL Obligations
Optometry practices routinely advertise pricing for eye examinations, contact lenses, and spectacles. All pricing claims must comply with ACL.
Medicare bulk billing
Key ACL pricing rules for optometry
- "Free eye test with purchase" — must honour the offer for all eligible purchases; conditions must be clearly disclosed upfront
- "From $X frames" — must be a genuine available starting price, not a price only available for severely limited stock
- Private health insurance claims — must not overstate rebate amounts; actual rebates vary by fund and level of cover
- Package deals — total cost must be clearly shown; must not use drip pricing that adds lens costs after advertising frame price only
- Sale pricing — "Was $X, Now $Y" requires the "was" price to have been a genuine price charged for a reasonable period
Title & Qualification Restrictions
Only AHPRA-registered optometrists may use the protected title "optometrist" in advertising. Using protected titles without valid registration is a criminal offence under the National Law.
Title usage rules
- Staff who are not optometrists cannot be described as "our optometrists" even informally
- Optical dispensers must not be described using language that implies optometry registration
- "Therapeutic optometrist" — valid if the practitioner holds therapeutic endorsement from the Optometry Board; must not be used otherwise
- "Behavioural optometrist" — acceptable as a descriptor of practice area, not a protected title, but claims about behavioural optometry effectiveness must be evidence-based
Visiting practitioners: If your practice hosts visiting ophthalmologists or orthoptists, advertising must clearly distinguish their role and qualifications from in-house optometrists.
Penalties
Violations can attract penalties from multiple regulators simultaneously.
Optometry Advertising Compliance Checklist
- No patient testimonials about clinical services used in any advertising channel
- No re-sharing of patient reviews on practice social media
- All contact lens brands advertised are ARTG-listed
- No therapeutic claims for contact lenses beyond approved indications
- Cosmetic lenses advertised as medical devices requiring professional fitting
- Visual acuity outcome claims qualified with individual variation statements
- No guarantee of specific visual outcomes
- Before/after imagery labelled as illustrative or simulated
- Bulk billing claims clearly state eligible patient categories
- "From $X" pricing represents a genuine available price
- Package pricing shows total cost upfront (no drip pricing)
- "Free eye test" conditions clearly disclosed
- Superlative claims ("best", "award-winning") substantiated
- Only AHPRA-registered optometrists described as "optometrists"
- Influencer and third-party promotions reviewed for AHPRA compliance
- Social media comments monitoring process in place
Check Your Optometry Practice Ads for AHPRA & TGA Violations
Paste your eye care ad, contact lens promotion, or practice website — ClearAd flags AHPRA testimonial bans, TGA therapeutic device claims, and ACL pricing issues with specific fix suggestions.
Check My Optometry Ad Free
Social Media Compliance
AHPRA's advertising rules apply to all channels operated by or on behalf of an optometry practice — Instagram, Facebook, TikTok, YouTube, LinkedIn, and practice websites alike.
Common social media compliance issues
TikTok / Reels: Short-form video content is increasingly scrutinised by AHPRA. "Eye transformation" videos showing dramatic clinical outcomes are a known area of concern.