Advertising rules for aesthetic clinics in Ireland and the UK

An injector in Dublin and a clinic manager in Manchester ask the same question most weeks: can we post this? Several rulebooks answer at once, and on the basics they agree. This guide maps them into a routine your team can follow. It is general information, not legal advice. For other markets, see our guide to advertising rules in aesthetics.

1. Who regulates what

In Ireland, the Health Products Regulatory Authority (HPRA) enforces the law on advertising medicines, the Advertising Standards Authority for Ireland (ASAI) applies its Code to ads, websites and social posts, and doctors also answer to the Medical Council. In the UK, the MHRA enforces medicines advertising law, the ASA applies the CAP Code, and doctors, nurses and dentists follow their own regulators. Data protection sits across all of it: the Data Protection Commission in Ireland, the ICO in the UK.

2. Prescription-only medicines

Botulinum toxin is a prescription-only medicine in both countries, and prescription-only medicines cannot be advertised to the public. The HPRA says the ban covers all media and all promotional activity, including clinics whose services may lead to a prescription, and it names semaglutide and tirzepatide alongside botulinum toxin. In the UK, the ASA treats almost any public mention of Botox or another toxin brand as a breach, including hashtags, spellings such as “Beautox” and indirect phrases such as “wrinkle-relaxing treatment”.

What you can promote: the clinic, the team’s qualifications, treatments that are not prescription-only, and a consultation for lines and wrinkles, where a prescriber decides what is suitable. UK guidance accepts a factual price list naming the medicine, away from the homepage and without product claims.

3. Promises, before-and-after photos, testimonials and influencers

Every claim needs evidence. The ASAI Code asks for health and beauty claims to be substantiated and for photographs not to create unrealistic expectations, and it treats “cure” and “rejuvenation” as generally unacceptable. In the UK, keep signed and dated proof that before-and-after photos are genuine and unretouched; a disclaimer does not fix a misleading image. For toxin treatments, before-and-after photos are out altogether, because they work as a claim for the medicine.

Testimonials must be genuine, used with permission and free of any reference to a prescription-only medicine. Health professionals, celebrities and influencers cannot endorse one. Any post that is paid, gifted or commercially connected needs a clear label, such as #ad, at the start.

4. Offers, prices and urgency

Clear prices are fine; offers are where clinics get caught. A promotion on a prescription-only medicine is still advertising, so “20% off this week” attached to toxin breaks the rules. For other treatments, the ASA has ruled against cosmetic ads that pushed people to book within a short window. In the UK, ads for cosmetic interventions must not be directed at under-18s or run where they make up more than 25% of the audience. Example: swap “Book by Friday” for “Book a consultation and take the time you need to decide”.

5. Client photos, consent and data

A photo of a face after a treatment says something about that person’s health, and data concerning health is a special category under the GDPR. For marketing, plan on explicit consent, confirmed in words: separate from consent to treatment, specific to each use, whether website, Instagram or paid ads, recorded with the date and what the client was told, and as easy to withdraw as it was to give. The Medical Council’s guide tells doctors not to publish images of individual patients on public platforms where they could be identified. Sort consent before a shoot, as we do for photography and video for clinics in Dublin.

6. Before you publish

• Does the post, caption, hashtag or image name or hint at a prescription-only medicine?
• Is the call to action a consultation rather than a medicine?
• Can every claim be backed with evidence, and is there any promise, even an implied one?
• Is there an offer, deadline or prize that rushes the decision?
• Is there written, specific consent on file for every client image, and is any editing documented?
• Is any influencer or partner content labelled as advertising?

If any answer is “I’m not sure”, the piece goes back for review before it goes live.

Sources: HPRA, promoting medicines to the public on social media; ASAI Code, Section 11: Health & Beauty; ASAI, social media influencer guidance; Medical Council, Guide to Professional Conduct and Ethics (2024); ASA/CAP, botulinum toxin products; CAP Bitesize, rules for advertising Botox; ASA/CAP, before and after photos; ASA/CAP, cosmetic surgery; ASA, rules on cosmetic intervention ads and under-18s; MHRA Blue Guide, Appendix 6; Data Protection Commission, special category data; ICO, consent. Checked in November 2026.

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