In the United Kingdom, no. Botox and its other brand names are prescription-only medicines, and a prescription-only medicine cannot be advertised to the public. The rule that catches most clinics is that indirect references count too, so writing anti-wrinkle injections or wrinkle-relaxing treatment in a services list breaches CAP rule 12.12 just as naming the brand would. New Zealand's rewritten advertising code separately prohibits patient testimonials in direct-to-consumer advertising of prescription medicines, and botulinum toxin is one. In Australia the treatment is permitted to be advertised but carries extra duties as a higher-risk cosmetic procedure.
Key points
Botox and brand names such as Vistabel and Dysport are prescription-only medicines in the UK and cannot be advertised to the public.
Indirect references are equally caught. CAP guidance names wrinkle-relaxing treatments and hashtags such as brotox and beautox as breaches.
New Zealand's Therapeutic and Health Advertising Code rule 2(f) prohibits patient testimonials in direct-to-consumer advertising of prescription medicines, which includes botulinum toxin.
In Australia, cosmetic injectables are named as higher-risk non-surgical cosmetic procedures under guidelines effective 2 September 2025.
Australian advertising naming an individual performing a higher-risk procedure must include their registration number.
Dubai prohibits staff describing themselves as Aesthetician, Cosmetologist, Cosmetic Specialist or Anti-Aging Specialist unless that matches their DHA licence.
Advertising a Dubai clinic's services without prior DHA approval is a listed violation carrying an AED 2,000 fine, doubled on repeat within a year.
Why can't Botox be advertised in the UK?
Because it is a prescription-only medicine, and the rule against advertising prescription-only medicines to the public is old, settled and strictly applied.
The ASA and CAP position is explicit: Botox and its other brand names, such as Vistabel and Dysport, are prescription-only medicines, which means they cannot be advertised to the public. CAP rule 12.12 is the operative provision.
What catches clinics is the reach of the prohibition. It is not a ban on using the trade name, which would be easy to work around. Indirect references are caught on the same footing. CAP guidance specifically warns against wrinkle-relaxing treatments as a phrase, and against hashtags such as brotox and beautox.
That makes a services list a compliance question rather than a copywriting one. Anti-wrinkle injections, the phrase most aesthetic clinics use precisely because it avoids the trade name, is an indirect reference to a prescription-only medicine.
What can a UK clinic say instead?
The distinction the rules draw is between advertising the medicine and advertising the consultation.
You may promote a consultation. You may describe your practitioners, their qualifications and their registration. You may talk about the conditions you treat in general terms without naming or gesturing at the prescription product that treats them.
What you may not do is put the treatment itself in front of the public, whether by brand name, by generic description, or by a phrase that plainly means the same thing. The prohibition covers posts on social media, leaflets and any other public-facing material, not only paid advertising.
This is one of the few areas where the compliant version is genuinely harder to write. Most clinics solve it by advertising the assessment rather than the injection.
What does New Zealand's new code change?
It closes the testimonial route, which for aesthetic clinics is usually the most valuable content they have.
The ASA Therapeutic and Health Advertising Code, published December 2025 and applying to new advertising from 1 April 2026 and to all advertising from 1 July 2026, states at rule 2(f) that testimonials by patients or consumers are not permitted in the direct-to-consumer advertising of prescription medicines.
Botulinum toxin is a prescription medicine in New Zealand. So a patient testimonial about an injectable treatment sits inside that prohibition rather than outside it.
The code's guidance also names user-generated content that could cause issues, including customer comments on platforms the advertiser controls. That reaches further than a quote on a website.
How does Australia treat the same treatment?
Differently, and more permissively on the advertising question itself, but with a set of duties attached that most clinics have not implemented.
AHPRA's guidelines for advertising higher-risk non-surgical cosmetic procedures, effective 2 September 2025, name cosmetic injectables among the higher-risk procedures. Advertising them is permitted. Advertising them carelessly is not.
Two requirements bite hardest. Where the advertising references a specific individual as performing the procedure, it must include that practitioner's registration details, including their registration number. And the rules on before-and-after images are prescriptive in a way that ordinary photo galleries are not built for.
There is also a criminal provision aimed at the clinic rather than the practitioner. Section 115 of the National Law makes it an offence to knowingly or recklessly use a specialist title in relation to another person who is not registered in that specialty, carrying a maximum of $60,000 or three years imprisonment for an individual and $120,000 for a body corporate.
Why is a before-and-after gallery a problem?
Because the rules govern which image appears first, and a photo gallery does not reliably let you control that.
For higher-risk cosmetic procedures, AHPRA requires that before-and-after images be genuine patients of that practitioner, and that they are presented so the most prominent or first image seen is either a composite of both images or the before image. They must not be edited, filtered, retouched or grey-scaled, and must match in lighting, camera angle, background, framing and exposure.
A Google Business Profile gallery orders images by its own logic. If the after image surfaces first, the requirement is not met, and the clinic has no setting that fixes it.
The workable answer is usually to publish before-and-after material where you control the layout, on a page of your own, and keep the profile gallery to premises, team and equipment photographs that raise none of these questions.
Which rules apply to which half of a dermatology clinic?
Both halves, differently, and the line between them is drawn by purpose rather than by procedure.
AHPRA defines non-surgical cosmetic procedures as those undertaken to revise or change appearance with the dominant purpose of achieving what the person perceives to be a more desirable appearance. Clinically justified work sits outside that definition. So the same clinic runs medical dermatology under one set of expectations and cosmetic work under another.
There is an unresolved edge worth knowing about. The guidelines for performing these procedures name CO2 laser resurfacing, laser hair removal, dermabrasion and chemical peels. The higher-risk advertising guidelines list dental veneers, cosmetic injectables, injection lipolysis, thread lifts, sclerotherapy and platelet rich plasma procedures, and do not name laser, peels or dermabrasion at all.
A clinic offering laser and peels therefore sits in a boundary the two documents describe differently. The prudent reading is to treat the advertising duties as applying, since the cost of over-complying is a registration number and a tidier gallery.
Market
Position on advertising injectables
United Kingdom
Prohibited. Prescription-only medicine, and indirect references such as anti-wrinkle injections are equally caught under CAP 12.12
New Zealand
Permitted, but patient testimonials are prohibited in direct-to-consumer advertising of prescription medicines
Australia
Permitted as a higher-risk procedure, with registration numbers required where an individual is named and prescriptive before-and-after rules
Dubai
Permitted only after DHA approval of the advertising, and only where a licensed consultant or specialist supervises the procedures
What are the rules in Dubai?
Approval first, then wording, and the wording rules target the exact vocabulary aesthetic clinics use.
The DHA standards for medical advertisement content require that staff and healthcare professionals refrain from using names or specialty titles different from their DHA licence. The examples given include Cosmetic Specialist, Aesthetic Specialist, Aesthetician, Cosmetologist and Anti-Aging Specialist. Those are the standard self-descriptions across the sector.
The DHA standards for non-surgical cosmetic procedures separately require a facility to have at least one full-time or part-time DHA licensed consultant or specialist plastic surgeon or dermatologist to supervise non-surgical cosmetic procedures.
And advertising the facility's services without first obtaining DHA approval is itself a listed violation under Executive Council Resolution No. 49 of 2024, carrying a fine of AED 2,000, doubled where the violation is repeated within a year.
Do review rules differ for cosmetic clinics?
Yes, and in Australia the position hardened in a way most clinics have not registered.
For practices advertising higher-risk cosmetic procedures, AHPRA now states that a testimonial is used in advertising where a practitioner interacts with a review on a third-party website, including liking or otherwise responding to it, and that practitioners must take steps to ensure they do not interact with testimonials, meaning positive reviews.
The December 2020 guidelines had only advised practitioners to take care when engaging with reviews. The instruction is new, and it inverts the standard advice to reply to everything.
In the United States a different rule applies to a related practice. The Federal Trade Commission's rule on consumer reviews requires an officer or manager writing a review about their own business to disclose the relationship clearly, and makes it a violation to solicit reviews from immediate relatives, employees or agents in circumstances the rule sets out.
Related questions
Can a UK clinic advertise Botox on its website?
No. Botox and brand names such as Vistabel and Dysport are prescription-only medicines and cannot be advertised to the public under CAP rule 12.12. The prohibition covers websites, social media posts and leaflets, not only paid advertising.
Is anti-wrinkle injections an acceptable alternative phrase?
No. CAP treats indirect references the same as naming the product, and specifically warns against phrases such as wrinkle-relaxing treatments and hashtags like brotox. The phrase means the prescription medicine, which is what the rule addresses.
What can a UK clinic promote instead?
The consultation rather than the medicine. You may advertise an assessment, describe your practitioners and their registration, and discuss conditions in general terms, provided you do not put the prescription treatment itself in front of the public.
Can we use patient testimonials for injectable treatments in New Zealand?
Not from 2026. Rule 2(f) of the ASA Therapeutic and Health Advertising Code prohibits patient testimonials in direct-to-consumer advertising of prescription medicines, and botulinum toxin is a prescription medicine. The code applies to new advertising from 1 April 2026 and to all advertising from 1 July 2026.
Do we have to publish a registration number in Australian cosmetic advertising?
Where the advertising names a specific individual as performing a higher-risk cosmetic procedure, yes. AHPRA requires the advertising to include the practitioner's registration details including their registration number.
Can we put before-and-after photos on our Google Business Profile?
It is difficult to do compliantly in Australia. The rules require the most prominent or first image seen to be a composite or the before image, and a profile gallery orders images on its own terms. Publishing them on a page you control is the safer route.
Why do laser and chemical peels sit in a grey area?
Because AHPRA's two cosmetic guidelines use different scope lists. The performing guidelines name CO2 laser resurfacing, laser hair removal, dermabrasion and chemical peels. The higher-risk advertising guidelines do not name them. Treating the advertising duties as applying is the cautious reading.