Guide

How Australian clinics can follow up enquiries within Ahpra and TGA advertising rules

By Frenz Adrian Sarabia, founder of G-SYNQ · Updated 28 September 2026

Reply to every enquiry straight away, but make the automatic reply about booking a consultation, not about a product. In Australia that means no names, nicknames or prices of prescription-only cosmetic injectables in your automated messages, forms or public booking pages, no testimonials, and nothing that promises a result. Your clinic approves every word, and consent to email is recorded before any marketing goes out.

I wrote a general guide on following up treatment enquiries for clinics anywhere. Most of it holds in Australia. But a few things are different enough that I'd set up an Australian clinic's follow-up differently, and I'd rather spell them out than let you find out from a regulator. I'm not a lawyer and this isn't legal advice. Everything below links to the regulator's own page, and your clinic should check its own situation with its adviser.

Why does an Australian clinic need a different first reply?

Because two sets of rules meet in the same message.

The first is Ahpra's. Its summary of the advertising requirements says they apply to any person or business advertising a regulated health service, not only to practitioners. It says advertising must not be false, misleading or deceptive, must not use testimonials, and that any offer has to state its terms and conditions where they're easy to find. It also says advertisers are responsible for content other people produce for them. That includes me. If I write your follow-up emails, your clinic is still the advertiser.

The second is the TGA's, and this is the one that changes the wording. In March 2024 the TGA published an update on referring to cosmetic injectables in advertising. It says express references to products or ingredients have never been permitted, and that it no longer permits terms such as "wrinkle reducing injections" where a reasonable consumer would understand the content is promoting a prescription medicine. It also says advertising prescription medicines through testimonials, claims, before and after photos or price lists has never been compliant.

So in my general clinic guide, the first reply confirms which treatment someone asked about. For an Australian clinic offering cosmetic injectables, I'd change that line.

What can the automatic first reply say?

The TGA's frequently asked questions on advertising cosmetic injection services (last updated 21 July 2026) say clinics should focus their advertising on the types of consultations available, instead of referring to the prescription-only medicines used in treatment. That's a good rule for the automatic reply too. Something like this, as an illustration only:

Hi Chloe, thanks for getting in touch with [clinic]. The best first step is a consultation with one of our practitioners, who can talk through your questions and whether any treatment is right for you. You can pick a time here: [booking link]. If you'd rather we call you, just reply to this email.

The same FAQ says that giving the information needed to answer a direct question is unlikely to be advertising, although it depends on what's said. But an automatic reply isn't an answer to one person's question. It's the same message sent to everyone who enquires, so I write it as if it were advertising, and leave treatment-specific answers to your practitioner in the consultation.

What should your enquiry form and booking page avoid?

This is the part clinics most often get wrong without meaning to. The TGA's FAQ says a publicly available booking system that draws people in on the basis of specific therapeutic goods is likely to be an advertisement for them, and gives two examples that would be unlawful where prescription-only medicines are involved: a form where the consumer picks from a list of treatments involving prescription-only medicines, and price information for a prescription-only medicine.

So on a public enquiry form or booking page, I'd offer consultation types, not a menu of injectables, and no price per unit or per area. The TGA's example is about publicly available booking systems, so I treat anything a member of the public can see or use as public.

If you use Facebook or Instagram lead forms, there's a second reason to keep questions general. Meta's list of questions prohibited on instant forms includes health information such as medical conditions and treatments, and Meta says a form that breaks this won't run. Ask what kind of consultation they want and when suits them. Leave medical questions for the practitioner.

What changed for cosmetic procedures in September 2025?

Ahpra's new guidelines for non-surgical cosmetic procedures took effect on 2 September 2025. For advertising higher risk non-surgical cosmetic procedures, the announcement says advertisements must only use real images without misleading editing, must carry a warning that results may vary when they use images, must not glamorise procedures, and must not target people under 18. It also strengthens the ban on testimonials from social media influencers, and sets a seven-day cooling-off period for under-18s between the first consultation and any procedure.

For the follow-up side, that means three practical things:

• No before-and-after images in automated nurture emails unless your clinic has confirmed they meet the guidelines, including the results warning.
• No patient or influencer quotes anywhere in the sequence.
• The automation books consultations, never procedures. Whether and when a procedure happens is your practitioner's decision, and the cooling-off rules depend on it.

What about consent and privacy?

For emails, the ACMA's guide to avoiding sending spam says you need consent before sending marketing messages, that it's up to you to prove it, and that inferred consent is not as reliable as express consent. Each message must identify your business with correct contact details, and the unsubscribe has to be honoured within 5 working days. So I add a consent checkbox to the enquiry form, record who ticked it and when, name the clinic in every message, and make one unsubscribe stop everything.

For health details, the OAIC's guide to health privacy says health information is sensitive information under the Privacy Act, with stricter requirements for handling it. That's one more reason the enquiry form and the automated emails stay away from medical questions. The less clinical information sits in a marketing system, the better.

Who approves the wording?

Your clinic, always, and before anything goes live. I draft the replies, reminders and rebooking messages, and you approve every word. If your clinic has a compliance adviser, they should see the sequence too. That's not me being cautious for the sake of it: Ahpra's summary says the advertiser is responsible for what others write for them.

What results can you expect?

I'll be straight with you. G-SYNQ has worked with one Australian client before, a B2B training business, and no results from that work are published, so I don't quote any. I haven't run an Australian clinic yet. The closest thing on our Work page is a brow studio in the Philippines, where Messenger campaigns brought 2,028 conversations at ₱10.40 each. Those are conversations, not booked appointments, and it's a different market with different rules. What I can offer an Australian clinic is the system and the care with the rules described above, not a number.

A checklist for your clinic

If your enquiries arrive faster than you can answer them, the reply speed matters as much as the wording. I've written about that in how fast to reply to a new enquiry. And the way I work with Australian businesses in general is on the Australia page.