Five limbs, thirteen requirements, and why everyone says seven

Search for the rules on advertising a health service in Australia and you will find, again and again, that there are seven of them. Agency blogs say seven. Compliance checklists say seven. We said seven ourselves, on this website, until we sat down and counted.

There are not seven. There is no source at Ahpra, and none at any of the National Boards, that enumerates seven advertising rules. The number appears to have started in a marketing blog and been copied from there.

Here is what the primary sources actually say.

The Act says five

Section 133 of the Health Practitioner Regulation National Law creates the offence. It has five limbs, lettered (a) to (e).

(1) A person must not advertise a regulated health service, or a business that provides a regulated health service, in a way that—

(a) is false, misleading or deceptive or is likely to be misleading or deceptive; or
(b) offers a gift, discount or other inducement to attract a person to use the service or the business, unless the advertisement also states the terms and conditions of the offer; or
(c) uses testimonials or purported testimonials about the service or business; or
(d) creates an unreasonable expectation of beneficial treatment; or
(e) directly or indirectly encourages the indiscriminate or unnecessary use of regulated health services.

Health Practitioner Regulation National Law (Queensland), s133(1), authorised consolidation current as at 10 April 2026.

Five. And the detail inside them matters more than the count.

The guidelines have four sections

The Guidelines for advertising a regulated health service, issued 14 December 2020 and still current, run to four numbered sections. The substance sits in section 4, which runs 4.1 to 4.5 and mirrors the five statutory limbs one for one.

These guidelines are not a brochure. Section 133(3) provides that a court may have regard to a guideline approved by a National Board about the advertising of regulated health services. That is what gives them weight — and it is also why the penalty figure printed inside them matters.

Ahpra’s own summary lists thirteen

Ahpra publishes a separate page, Summary of the advertising requirements. It is the closest thing to a practical checklist the regulator offers. It has thirteen items.

Items 12 and 13 appear on almost no agency checklist anywhere. They are the two most commonly lost when thirteen items are compressed into seven.

So where did seven come from?

The earliest source we can find is an agency article, Healthcare Marketing and AHPRA: 5 limbs You Can’t Afford To Break, published 13 October 2025. It is a competent piece. It quotes section 133 correctly and gets the penalties right. But its seven is an editorial choice, not a legal one, and it has since been repeated as though it were the regulator’s own framing.

How to state it correctly

For a legally accurate formulation: five statutory prohibitions under section 133 of the National Law. For a practical checklist: Ahpra’s own thirteen.

Do not use seven. And treat anyone who does with some care — it tells you their compliance work was copied rather than read.