Discounts, gift vouchers and 'free' offers: the AHPRA rules
By Daniel Welsh, Founder, Routiq · Last updated 10 July 2026
Offers aren't banned. The National Law says an advertised gift, discount or other inducement must state its terms and conditions clearly — and separately, offers must not push people toward care they don't need, and 'free' must be genuinely free.
The exception is prescription-medicine treatments: for injectables, offers are effectively off the table regardless of how good your fine print is.
The terms-and-conditions rule
Advertising an inducement without clearly stating its terms is itself an offence under section 133 — the breach isn't the discount, it's the missing fine print. Plain-language T&Cs in the ad: what's included, who's eligible, when it expires, what it costs after. 'T&Cs apply' with nothing behind it doesn't meet the standard; unreadable six-point footnotes don't either.
'Free' has a legal meaning
The public reads 'free' as absolutely free. If a 'free assessment' is recouped through a health-fund claim, a Medicare billing, or a padded treatment plan afterwards, it isn't free — it's misleading advertising. Either make it genuinely free or call it what it is: 'initial consultation $X, deducted from treatment'.
When an offer becomes 'encouraging unnecessary use'
The National Law prohibits advertising that encourages indiscriminate or unnecessary use of health services. That's where prize draws and giveaways attached to treatment sit ('win a free treatment package'), along with countdown urgency on clinical care ('flash sale ends midnight') and screening funnels built to convert everyone. The test regulators apply: would this push someone to use a health service regardless of clinical need?
Injectables: offers are basically off the table
Discounts, gift vouchers, loyalty points and packages attached to prescription-only medicines are a TGA problem regardless of your T&Cs — you'd be using an inducement to promote a Schedule 4 medicine. The September 2025 cosmetic guidelines also explicitly banned free or discounted procedures for influencers. If you sell vouchers, sell them for consultations or non-regulated services (skincare products, non-clinical facials) — not for S4 treatments. Background: why clinics can't advertise Botox.
Risky vs calmer
Risky
“🎉 EOFY FLASH SALE — 30% off all injectables today only! Gift vouchers available, treat your bestie 💉”
Calmer
“Planning ahead? We have consultation appointments available this month — full details and booking terms on our website.”
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Ask Abby →Common questions
Can I offer a new-patient discount?
Yes — with clear terms and conditions in the ad, honest 'free'/price claims, and framing that doesn't pressure people into unnecessary care.
Can I sell gift vouchers for filler or anti-wrinkle treatments?
High-risk — a voucher is an inducement attached to a prescription-only medicine, which raises TGA issues no matter the fine print. Vouchers for consultations or non-regulated services are the safer product.
Can I run a competition or giveaway?
Prizes that encourage people to use a regulated health service regardless of need sit inside the prohibition — and for cosmetic procedures they're a known enforcement target. Keep giveaways away from treatment.
Where do the terms and conditions have to appear?
Clearly, in the advertising itself — plain language covering eligibility, inclusions, expiry and any conditions. A bare 'T&Cs apply' isn't enough.
General information, not legal advice
This page explains published AHPRA and TGA advertising guidance in plain English to help you review your own marketing. It is not legal advice, does not certify compliance, and is not endorsed by AHPRA or the TGA. Confirm anything material with your own lawyer or regulatory advisor.
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