Marketing for Aesthetics Clinics and Med Spas.
Sell the consultation, not the syringe.

The UK advertising code's rule 12.12 says prescription-only medicines or prescription-only medical treatments may not be advertised to the public. CAP, which writes the code, says in a January 2020 FAQ that the rule covers every prescription-only botulinum toxin brand, Botox, Vistabel, Azzalure, Bocouture and Dysport included, and does not apply to dermal fillers. CAP's guidance gives "a consultation for the treatment of lines and wrinkles" as a claim likely to be acceptable, with the product name kept out of the initial ad.

The wording follows your real treatment list. CAP's FAQ says "anti-wrinkle injections" might be acceptable as a collective term for a clinic offering both toxin and fillers, provided nothing implies the injections mean Botox alone. For a toxin-only clinic the FAQ advises against the phrase, and says "relaxing" is likely to be understood as an implied reference to Botox even for clinics that also sell fillers.

Filler ads can name the treatment, because rule 12.12 does not cover fillers, though the rest of the Code still applies. Toxin ads sell a consultation for lines and wrinkles. Our paid media and lead generation work is built on that consultation as the conversion: the booking form, the reply and the reminder all point at it.

CAP's guidance says any reference to Botox on a clinic's social media pages, hashtags included, is likely to be seen as an implied ad for a prescription-only medicine, and its FAQ says the rule applies to all marketing material, a clinic's own website included, with narrow exceptions.

One ASA ruling of 18 December 2024 concerned a paid Facebook ad for a beauty clinic. The image text read "cosmetic injections, dermal filler, lip filler" with a from-price for three areas. The ASA understood the promotion applied only to the "anti-wrinkle" treatments, so the ad indirectly advertised a POM, namely Botox, and must not appear again in its current form. CAP's FAQ adds that a price promotion for Botox such as "20% off" or "buy two areas get one free" is likely to breach the Code.

A from-price for a number of areas is the format that ruling caught. Price-led offers go on treatments the rule does not cover, where your own professional regulator allows them. The feed runs on filler and skin results, the team and what a consultation involves. A rebooking message that promotes treatment is marketing material too, so your email reminders, and any texts your clinic sends, invite the patient to a review appointment and leave the product out.

Clinic websites get a narrow exception: they may give information about a prescription-only medicine, but only as a possible treatment option following a consultation. CAP's guidance says there should be no reference to one in a sponsored ad, on the homepage, in logos, testimonials or hover text, nor in homepage small print, and its FAQ says it shouldn't be easy to stumble upon toxin information.

The homepage promotes a wrinkle treatment consultation, and the page a click deeper emphasises the consultation and the range of options it can lead to. CAP's guidance for that page includes keeping toxin references incidental, balanced and factual and within the product's licensed treatment areas. We plan a UK clinic's SEO and AI visibility around that structure.

In toxin marketing, CAP's guidance says the ASA is likely to read before and after images as an efficacy claim, which is not permitted. A clinic offering both toxin and fillers can show images of someone who received a non-prescription-only treatment, clearly labelled, with signed and dated proof that they are genuine and representative. Presenting a toxin result as filler is unlikely to be acceptable. Build galleries by treatment, with consent and proof on file first.

Rule 12.25 says marketing for cosmetic interventions must not be directed at under-18s through the selection of media or context. The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 makes it an offence to administer toxin, or a filler injected for cosmetic purposes, to anyone under 18 in England, with defences that include one where the person took reasonable steps to establish the patient's age and reasonably believed they were 18 or over. Paid social runs on adult-only audiences, and the booking form asks for a date of birth before anything else.

For practitioners outside the doctors' and dentists' registers, the NHS tells patients they can check whether other professionals offering cosmetic procedures are on a voluntary register accredited by the Professional Standards Authority, naming the JCCP and Save Face. The JCCP says its register is formally accredited by that authority; Part A covers doctors, dentists, nurses, specific allied health professionals and pharmacists.

The same NHS page tells patients to always book a consultation with the person who will do the procedure and not to pay until they have had one. Toxin can only be prescribed after a consultation, and the person giving the injection need not be the prescriber. Patients are also told to avoid treatment vouchers sold on group discount sites, among other things.

A clinic whose only presence is an Instagram grid, or whose offer arrives as a voucher, matches the profile patients are warned about. The site names the prescriber and the treating practitioner, shows each register entry beside the person, and offers a consultation to book. That consultation is also what we count: consultations booked, consultations attended, and the share that become treatments by treatment type, with no-shows and rebookings beside them. Your own last twelve months is the baseline.

A CQC inspection summary for one English clinic, published in August 2022, records that its anti-ageing injections and dermal fillers were not within CQC's scope of registration, while surgical thread lifts and Botox to treat medical conditions such as excessive sweating did need it. That is one clinic and sets no general rule, but any "CQC registered" line on your site should name the activity the registration covers.

Section 180 of the Health and Care Act 2022 gives the Secretary of State power to require personal and premises licences for specified cosmetic procedures in England, and the government's response says licences would be issued by local authorities. The government's consultation page, last updated 7 August 2025, carries its response to the 2023 consultation. That consultation had proposed an amber tier including botulinum toxin injections and semi-permanent dermal fillers injected into the face. The response says further work is required to determine where specific procedures will sit, and that proposals, starting with the highest-risk procedures, would be consulted on early next year, which on a page dated August 2025 means early 2026; as of October 2026 the page shows no later update.

A consultation page describes proposals, not the law in force, so check whether licensing regulations have been made and are in force before any ad or page says "licensed", and claim a licence only once you hold one.

In Great Britain, the DMCC Act bans fake reviews and reviews that hide that they were paid for or incentivised, and the Competition and Markets Authority tells businesses not to offer inducements (money or gifts) to customers to write positive reviews. In the US, the FTC says paying for five-star reviews violates its rule even with a disclosure, and warns that failing to disclose incentives could be a violation of the FTC Act.

A patient's photo or story is quoted on the site only with written consent for that use, and a UK testimonial should not mention toxin at all, because CAP's guidance lists testimonials among the places a POM should not be referenced. Practitioners are endorsers too: CAP's guidance says using health professionals or celebrities to endorse a prescription-only medicine breaches rule 12.18, so no clinician or celebrity fronts a toxin ad. In the US, the FTC says an endorsement should make obvious any material connection, and a creator given a free or discounted treatment discloses it in the post.

When a review is unhappy, the FTC says its reviews rule does not prohibit contacting the reviewer to resolve the issue. The public reply stays short and confirms nothing about the person's treatment.

The FDA, on a page current as of July 2023, says fillers are approved for adults 22 or older for specific uses, and that filler injection should be considered a medical procedure, not a cosmetic treatment. It adds that injecting filler into the glabella (between the eyebrows), nose, area around the eyes, forehead or neck is not an approved use. Treatment pages read as medical pages, and one built around an unapproved area goes to your medical director first.

The FDA warned on 16 April 2024, with an update on 1 May 2024, that counterfeit Botox had been found in multiple states. Federal law requires providers who administer prescription drugs to buy only from authorised sources. A "genuine product" line runs on a med spa site only when you can show where you buy.

In Texas, the medical board treats nonsurgical cosmetic procedures, including cosmetic injection, as the practice of medicine that can be properly delegated and supervised, effective 9 January 2025. The physician's written order must include, among other things, the identity of the delegating physician. California's Business and Professions Code, section 2400, says corporations have no professional rights, privileges or powers in its medicine chapter, so med spa ownership there is a question for a California healthcare attorney. Your medical director signs off what we promote, and the site states accurately who supervises.

We take on aesthetics clinics and med spas in the UK and the US, work across both countries' time zones, and quote in GBP or USD.