Can You Advertise Botox on a UK Clinic Website?

In May 2023 the ASA ruled on six Instagram Stories for an aesthetic clinic. None of them used the word "Botox". The clinic called the treatment "anti-wrinkle injections", and the ASA understood it did so "to avoid using the term Botox". Read with the rest of the Stories, the ASA held that the softer phrase had "the same effect as promoting a POM", a prescription-only medicine.

Checked against the regulators' published guidance on 1 October 2026. WebAsk is a web agency, not a law firm. This summarises published guidance; it is not legal advice.

This post names the medicine because it is commentary on the advertising rule, not an ad for the medicine. A clinic's own pages are in a different position.

So, can I advertise Botox on my website in the UK?

The short answer: not to the public

Botox is a trading name for a botulinum toxin product. It is a prescription-only medicine, or POM. The CAP Code, which the ASA enforces, prohibits advertising POMs to the public. The rule covers every brand, not only the best-known one. In fact, it "applies to all 'prescription-only medicines', not just botulinum toxin" (FAQ, 23 January 2020).

What you can promote is the consultation. CAP's advice of 29 October 2025 gives an example that "is likely to be considered acceptable": "a consultation for the treatment of lines and wrinkles". It notes "some exceptions for websites". The sites of clinics offering such consultations "may provide information about a POM, but only in the context of the product being a possible treatment option following a consultation".

The same advice says the medicine "may be advertised directly to the medical, dental, veterinary and allied professions (rule 12.12)". CAP's 2019 guidance, "A fine line", said the permission "does not extend to beauty practitioners, unless they also have those qualifications" to prescribe or supply medicines.

What the rule says, and where it comes from

Rule 12.12 of the CAP Code is one sentence:

"Prescription-only medicines or prescription-only medical treatments may not be advertised to the public."

The exception for health professionals is not in these words. It is stated in CAP's guidance, quoted above.

Behind the rule sits medicines law. Regulation 284 of the Human Medicines Regulations 2012 says:

"A person may not publish an advertisement that is likely to lead to the use of a prescription only medicine."

The MHRA's guidance for treatment providers highlights regulation 284 too (Blue Guide, Appendix 6, November 2020).

Your own channels count. CAP's Bitesize guidance (April 2025 disclaimer; read 28 September 2026) says: "Posts on your own social media channels or website also count as ads."

Where the name should not appear

CAP's advice of 29 October 2025 gives this list:

"No reference to a POM should be made in a sponsored ad, on the homepage of a website, in logos, testimonials or hover text. In addition to this, any small print at the bottom of a homepage should not refer to POMs or directly link consumers to a page where they are referenced."

"A fine line" (17 October 2019) said the prohibition "includes logos, testimonials, links, hover text, small print and price lists". The MHRA's Blue Guide (Appendix 6, November 2020) says a clinic's home page "should not include any reference to named POMs, including price information". It adds: "Links and navigation aids may be given for particular conditions and diseases but not to specific POMs."

The idea behind these lists is in CAP's advice:

"Marketers should therefore ensure that the casually browsing consumer does not come across information relating to POMs with ease."

So can the name appear anywhere on your site? The FAQ says "Yes, in very narrow circumstances". You need to "make very clear that you are advertising the 'consultation' rather than Botox", and "any references should be incidental, balanced and factual".

Price lists are where the lists differ. The 2019 list included them. Later guidance treats them separately: the FAQ says a price list on your website "depends", and sets out when it "might be acceptable". Our post on price lists sets out that route.

Indirect references: rulings and guidance

A softer phrase can still be a reference to the medicine. Bitesize says: "Don't mention Botox or use indirect references to it in your ads". Its video transcript goes further: "The ASA will consider almost any reference to Botox – direct or indirect – as likely to breach the rules."

The phrases, side by side

Each row quotes its source and gives its date where the page has one. The date is part of the evidence.

"Line Relaxing" (2012). A skincare practitioner's price list offered "Line Relaxing" treatment, and elsewhere the site said "Line Relaxing Treatment (Botox)". The ASA held that, "In conjunction with the other references to Botox and its effects", consumers would take the price-list entry as a reference to the medicine. The phrase did not stand alone.

"Wrinkle relaxing" (2020). Asked about "wrinkle relaxing injections", the FAQ answers: "No, we'd advise against it." That holds "Even if you sell both" the medicine and treatments such as fillers. CAP's Enforcement Update of the same month was about social media. It warned against swapping a direct reference for a phrase that "can only refer to a POM", such as "wrinkle relaxing injections". That, it said, "is indirect promotion of a POM, and just as much of a problem".

"Cosmetic injections" (2024). A paid Facebook ad offered "COSMETIC INJECTIONS" for three areas, with a price. The ASA acknowledged that the clinic's "Cosmetic Injections" "referred to both POM and non-POM treatments". But the ad set cosmetic injections apart from its fillers, and the offer applied only to its "Anti-Wrinkle" treatments. The FAQ on the clinic's own website said its "anti-wrinkle injections" were "also known as botulinum toxin injections". The ASA held that "the ad indirectly advertised a POM".

The newest ruling on this point that the ASA's rulings search returned on 1 October 2026 is Valterous (18 December 2024). That search did not return the 2012 ruling above, so it is not a full record.

What CAP and the ASA say about "anti-wrinkle injections"

The FAQ's answer turns on what else the clinic offers, and on what sits next to the phrase. The FAQ of 23 January 2020 and an Enforcement Update from the same month set out the conditions.

If you also offer treatments that are not prescription-only, such as fillers:

"this might be acceptable – but, you must ensure that nothing else in the ad implies that the term 'injections' refers exclusively to Botox."

It warns that saying "anti-wrinkle injections and fillers" "suggests that the 'injections' is referring to Botox". It recommends "anti-wrinkle injections" or "anti-wrinkle treatments" "as a collective term for both" kinds of treatment.

If you offer only the medicine:

"we'd advise against 'Anti-wrinkle injections', as it's likely to be seen as an implied ad for a 'prescription-only medicine'."

If the phrase sits beside a price for the medicine: CAP's Enforcement Update (9 January 2020) says "the ASA considers that a reference to 'anti-wrinkle injections' alongside a price that relates to a POM, will be seen as an ad for that POM". That update was about social media. For a website, read it with the FAQ.

Two rulings show "anti-wrinkle" wording failing in context. In LIFT Aesthetics (17 May 2023), one Story also used a name the ASA understood to be "another brand of Botox". The Stories showed a face being injected and talked about results in two weeks. The ASA held that "doing anti-wrinkle" and "anti-wrinkle injections" "were indirect references to Botox". In Dr Bunny Aesthetics (24 April 2024), a listing on a booking platform also named the toxin. The treatment could be booked and paid for from it without a consultation. Its "anti-wrinkle" wording was held to be an indirect reference too. In both, the wording sat beside other signals.

WebAsk's build standard is stricter than the FAQ: it leaves "anti-wrinkle injections" out of client sales copy altogether. That is our choice, not CAP's or the ASA's rule. The FAQ's conditions turn on a clinic's full treatment list and on what sits beside the phrase. Both can change after a page goes live.

Endorsements, and a second medicine with the same trap

Rule 12.18 of the CAP Code reads: "Marketers must not use health professionals or celebrities to endorse medicines." CAP's advice applies it here: "using health professionals to endorse the product breaches rule 12.18".

In LIFT Aesthetics, the Stories featured a reality TV star with "approximately 230,000 followers on Instagram". The clinic had given him the treatment free. The ASA counted that as payment when it found that the Stories he reposted were ads. It held that he "was a celebrity for the purposes of the CAP Code" and had endorsed a medicine, so the ads broke the Code.

Indirect references turn up with a second medicine too. On 2 April 2026 the ASA reported on ads for prescription-only weight-loss medicines. It identified "around 900 ads likely to breach the rules, from 38 of the 44 advertisers monitored". One problem it named was "descriptors clearly understood as references to prescription-only medicine such as 'weight-loss injection', 'pen', 'jab' or 'GLP1'".

That monitoring covered paid online ads from February 2025 to January 2026, starting with pharmacies and online clinics (CAP Enforcement Report, April 2026). Nothing in it says aesthetic clinics were among the 44 advertisers, and none of its figures is about botulinum toxin. The rule is the same, and so is the lesson. Wording can point to a medicine without naming it.

How ads get found

In January 2020 CAP said that "From 31 January" it would use "new monitoring technology to discover problem ads on social media" (CAP News, 9 January 2020). Advertisers who do not follow the rules, it added, "run the risk of being referred to the MHRA or their professional regulatory body".

The ASA now describes an "Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules". That line is from its Glow Up LLC ruling of 2 September 2026, which was about an app, not a clinic. No page we read says whether it checks ads for this medicine today.

Complaints matter too: the Joint Council for Cosmetic Practitioners complained in both Dr Bunny Aesthetics and Valterous.

A figure this post does not repeat

Some web pages give a figure for MHRA enforcement notices to aesthetic businesses in 2024. We did not find that figure in the MHRA material we read, so we leave it out.

The MHRA's annual report for 2024 to 2025 does say this, with no number:

"A particular focus continues to be advertisements by treatment service providers for prescription medicines for weight loss, aesthetics treatments, and hay fever."

Nor does this post say how many aesthetic clinic websites break the rule. We have no audit data, and none of the sources above counts them.

Where to start

1. Search your own site and accounts for the name. Start with the homepage, logos, testimonials, hover text and small print. Then check your ads and posts for each phrase in the table.
2. Rewrite around the consultation. CAP's own example is "a consultation for the treatment of lines and wrinkles". If you keep "anti-wrinkle injections", test it against the FAQ's conditions and against what sits beside it.
3. Ask before you publish. CAP's Copy Advice service advises on ads before they run. The standard service is free and takes 3 to 5 working days; faster replies are paid. It covers the CAP Code only and gives no legal advice. It says its advice "is not binding on you, CAP or the ASA".

For more, see what aesthetic clinics can say in adverts, the whole-site checklist, the other clinic compliance guides and our page for aesthetic clinics. The free audit includes a rules check for clinics that gives no legal verdict. Or get in touch.