Between April and December 2025, CAP's AI monitoring captured 928 unique paid ads on Meta for one filler procedure, the non-surgical liquid BBL. As of December 2025, "only 11.5% of ads assessed complied with the CAP Code's social responsibility rules" (CAP Enforcement Report, 12 March 2026).
CAP's FAQ says the ban on advertising prescription-only medicines does not apply to dermal fillers. The rest of the Code does.
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.
Here, "the medicine" means the prescription-only medicine, or POM, in our post on the advertising rule. We leave its name out.
So what can aesthetic clinics say in adverts in the UK?
TL;DR
Promote the clinic, your non-POM services such as fillers, and a consultation for the concern, and hold evidence for every objective claim, photo and testimonial before it runs. CAP's advice says before-and-after images of a prescription-only product are "very likely to be seen as an implied ad", and that marketers should hold signed and dated proof that any before-and-after photos are genuine.
The short answer: start from the consultation
CAP's Bitesize guidance (undated; April 2025 disclaimer) lists what "You can promote". It names "your clinic and other non-POM services, such as dermal fillers" and "your experience and qualifications". What the CAP Code bars is advertising a POM to the public (rule 12.12).
For the medicine, promote the consultation. CAP's advice of 29 October 2025 says "a consultation for the treatment of lines and wrinkles" "is likely to be considered acceptable". It adds that "the name of the POM should not be referenced in the initial ad".
Our build standard goes further. On a consultation page that can lead to the medicine, we would name the concern the patient wants addressed. We would describe neither the product nor its effect. CAP's advice keeps the name out of the initial ad. The rest is our choice, not a CAP rule.
"Injectables" are two categories, not one
The POM rule "does not apply" to "dermal fillers", says CAP's FAQ (CAP News, 23 January 2020). CAP's newer advice on fillers (6 August 2025) is less absolute: "Dermal fillers are unlikely to be prescription-only (POMs)."
Name fillers as fillers. For a clinic that offers both, CAP's Enforcement Notice on social media (9 January 2020) says to use "terms such as 'dermal fillers' or 'cosmetic fillers'". It warns against pairings such as "anti-wrinkle injections and dermal fillers", which "would imply that the 'injections' in question are POMs".
The FAQ's view of "anti-wrinkle injections" turns on what else a clinic offers, and on what sits beside it. Our post on the advertising rule sets out those conditions. It also sets out our stricter standard of leaving the phrase out of client sales copy. That standard is ours, not CAP's.
If the medicine is your only injectable, the trap runs the other way. CAP's fillers advice says marketers "should not advertise 'fillers'" then, because "that would be an indirect promotion of a prescription-only medicine".
Filler claims have limits. The same advice says:
"Marketers may refer to fillers as being capable of temporarily reducing the appearance of fine lines and wrinkles but should not suggest either that treatment can cure or rejuvenate skin (rule 12.7) or that lines and wrinkles will be permanently eliminated. Unqualified claims, such as 'wrinkle reduction', are unlikely to be acceptable."
Every ad must also be responsible (rule 1.3 of the CAP Code). Among the liquid BBL ads that broke the rules, CAP's report lists claims such as "0% infection rate", "safe" and "transform your body effortlessly".
Before-and-after photos: two tests
The pages we read do not rule out before-and-after photos in general. We read two tests in CAP's advice on before-and-after photos (5 June 2025).
Test one: is the photo genuine, and fair to the treatment?
CAP and the ASA treat these photos "in the same way as testimonials", so marketers should meet rules 3.47 to 3.50. Marketers "should hold signed and dated proof that the photos are genuine and have not been manipulated". They also need "relevant evidence to substantiate the impression created by the images".
Retouching the treated area "could be problematic" even with a disclaimer, says CAP and BCAP's guidance on cosmetic procedures (revised November 2021). Bitesize says a caption such as "filter used" "probably won't be enough to fix a misleading impression".
The newest dated example we read is about an app, not a clinic (Glow Up LLC, 2 September 2026):
"As we had not seen any evidence to substantiate that the before-and-after footage and photos were genuine, including that they used the same models, or were representative of typical results, we concluded that the ads were misleading."
Test two: does the photo advertise the medicine?
CAP's advice of 5 June 2025 says:
"'Before and after' imagery of a prescription-only product, even in isolation without any accompanying claims, is very likely to be seen as an implied ad for a prescription-only product"
CAP's advice on the medicine (29 October 2025) goes further:
"The use of before and after photographs is likely to be interpreted by the ASA as an efficacy claim, which is not permitted. Marketers should, therefore, avoid featuring any before and after images in their marketing communications."
For a clinic that offers the medicine and fillers, the FAQ (23 January 2020) gives a narrow route:
"you are able to include images if they show someone who has received a non-prescription only treatment – however, make sure you're explicit the photos relate to the non-prescription only treatment."
Showing a result of the medicine and "falsely" calling it a filler result "is likely to be seen as materially misleading", the FAQ adds.
CAP's general advice on prescription-only medicines, redated 30 September 2026, takes the FAQ's side. After the same "avoid" line, it adds: "If the marketer also promotes non-POM treatments alongside their POM counterparts, the use of before and after images may be acceptable if they are clearly attributed to the non-POM product." "May be acceptable" is still not a promise. Before you build a gallery, put the question to CAP's Copy Advice team, which advises on ads before they run.
Our build standard follows CAP's general advice. For a clinic that offers the medicine, it allows before-and-after photos only of treatments that are not prescription-only. Each photo must be clearly labelled with the treatment shown and backed by signed and dated proof that it is genuine. Photos of the medicine's results are never allowed. That is our standard, following CAP's advice. It does not guarantee that a gallery complies.
Consent to use a patient's photo
Here the guidance we read is thin. Rule 3.50 bars a testimonial "without permission", and CAP treats these photos the same way. CAP and BCAP's guidance says marketers "must hold" evidence that the photos are genuine, and hold "signed and dated proof from the subject shown". Rule 6.1 of the CAP Code says marketers "are urged to obtain written permission before" portraying "a member of the public".
For doctors, the GMC's guidance on recordings of patients (in effect since 9 May 2011; we read an archived copy of 12 January 2025) covers "widely accessible public media". There, doctors "must get the patient's consent", which "should usually be in writing". The pages we read do not mention marketing, so applying the guidance to a gallery is our reading. For nurses, the NMC's social media guidance (last updated 2 July 2025) lists posting pictures of patients "without their consent". That is conduct that "may put their registration at risk". We read nothing further on aesthetic photos, so we add no rule of our own.
Testimonials, endorsements and reviews
Rule 3.47 of the CAP Code says marketers "must hold documentary evidence" that a testimonial "is genuine", and contact details for the person who gives it. Rule 3.48 says: "Testimonials must relate to the advertised product."
For the medicine, CAP's advice of 29 October 2025 says no reference to a POM "should be made in" testimonials. Rule 12.18 says: "Marketers must not use health professionals or celebrities to endorse medicines." CAP's advice on endorsements (24 March 2026) adds a warning. A health professional "does not have to be named" for the ASA to find such an endorsement.
Reviews: ask everyone, and show what you get
Since 6 April 2025, the DMCC Act 2024 has prohibited these practices, among others (Schedule 20, paragraph 13):
"(1) Submitting, or commissioning another person to submit or write— (a) a fake consumer review, or (b) a consumer review that conceals the fact it has been incentivised. (2) Publishing consumer reviews, or consumer review information, in a misleading way."
The CMA's guidance on fake reviews (CMA208, 4 April 2025) says that encouraging reviews "without predetermining the contents or sentiment expressed in the review, for example by merely emailing customers generally to ask if they wish to provide a review, is not prohibited under the banned practice". Google's policy for Maps, read on 29 September 2026, goes further. Under "We do not allow merchants to:" it lists "Offer incentives" in exchange for a review. It also lists "selectively solicit positive reviews from customers".
A patient's review can name the medicine. So under our build standard for aesthetic sites, reviews stay on Google, not embedded on the site. That holds until the advertising position on treatment names is settled. It is our interim rule, not the law.
Claims about results, safety and offers
Rule 3.7 says marketers "must hold documentary evidence" for objective claims before an ad runs. Rule 12.9 says marketers "must hold proof" before suggesting a treatment is "guaranteed to work, absolutely safe or without side-effects". CAP and BCAP's guidance says marketers "should avoid irresponsibly describing cosmetic interventions as 'safe' or 'easy'". And do not claim approval: rule 3.51 bars implying "endorsement by the ASA or CAP".
For the medicine, the FAQ's answer on a price promotion is: "No, this is likely to breach the Code." Offers on other non-surgical treatments "are not prohibited", says CAP's advice on non-surgical procedures (1 July 2025). But "the promotion must be responsible and never should pressure those seeing the ad into booking". CAP and BCAP's guidance adds that countdown clocks and claims such as "Hurry, offer must end Friday" "should not be used".
Practitioner pages and age
Rule 12.3 says: "Practitioners must have relevant and recognised qualifications." CAP and BCAP's guidance says marketers "should hold proof of practitioners' qualifications from a reputable, independent source before making claims that relate to those qualifications". Marketers "should not misleadingly claim or imply that a practitioner is a medical professional or regulated by a professional body if that is not the case".
Names count too. The ASA ruled on an ad for a clinic called Dr Bunny Aesthetics (24 April 2024). It said consumers would take the name to mean the clinic was run by "someone who held a general medical qualification". It had no evidence of that, and "concluded the ad was misleading".
On a practitioner page, we would show qualifications and indemnity cover. We would also link to any register the practitioner is on, such as the JCCP's or Save Face's. These are our design choices, not CAP rules. We have not reviewed what the registers require. Rule 3.52 does bar showing "a trust mark, quality mark or equivalent without the necessary authorisation".
Two age rules: one for ads, one for treatment
The advertising rule came into force on 25 May 2022 (CAP News). Rule 12.25 says:
"Marketing communications for cosmetic interventions must not be directed at those aged below 18 years through the selection of media or context in which they appear."
CAP and BCAP's guidance rules out media "in which 25% or more of the audience profile is under-18s".
The treatment rule is criminal law. The 2021 Act (2021 c. 19) covers filler injections for a cosmetic purpose and one named prescription-only medicine. Since 1 October 2021 it has been an offence to administer either, in England, to anyone under 18 (s.1(1)). The Act gives three defences (s.1(4)). The person administering was a registered medical practitioner. Or they were a regulated health professional acting on such a practitioner's directions. Or they took reasonable steps to establish the person's age, and reasonably believed the person was 18 or over. The penalty is a fine (s.1(6)). We would state the age rule on the booking page for both treatments. That is our standard.
Say this, not this: page by page
Each row quotes the words that decide it. The date is part of the evidence.
| Page element | Say this | Not this | Why, in the source's words | Source and date |
|---|---|---|---|---|
| Consultation page | A consultation for the concern, such as "a consultation for the treatment of lines and wrinkles" | The medicine's name | "is likely to be considered acceptable"; "the name of the POM should not be referenced in the initial ad" | CAP's advice, 29 October 2025 |
| Filler page | "dermal fillers" or "cosmetic fillers"; "temporarily reducing the appearance of fine lines and wrinkles" | "anti-wrinkle injections and dermal fillers"; "cure", "rejuvenate" or permanent results; unqualified "wrinkle reduction" | "would imply that the 'injections' in question are POMs"; "are unlikely to be acceptable" | Enforcement Notice, 9 January 2020 (social media); CAP's advice on fillers, 6 August 2025 |
| Before-and-after gallery | Results of treatments that are not prescription-only, clearly labelled with the treatment shown, with signed and dated proof and evidence for the impression. If you also offer the medicine, ask Copy Advice first | Any result of the medicine; a result of the medicine labelled as filler; retouching in the treated area | "very likely to be seen as an implied ad for a prescription-only product"; "make sure you're explicit the photos relate to the non-prescription only treatment"; retouching the treated area "could be problematic" | CAP's advice, 5 June 2025; FAQ, 23 January 2020; CAP and BCAP guidance, revised November 2021 |
| Testimonials | Genuine, with permission and contact details, about the treatment advertised | A testimonial that names the medicine | Rules 3.47, 3.48 and 3.50; no reference to a POM "should be made in" testimonials | CAP Code; CAP's advice, 29 October 2025 |
| Reviews | The same request to every customer; reviews shown as they are | Fake reviews; hidden incentives; asking only happy customers | "a consumer review that conceals the fact it has been incentivised"; "selectively solicit positive reviews from customers" | DMCC Act 2024, in force 6 April 2025; Google's policy, read 29 September 2026 |
| Practitioner bio | Qualifications held, with proof; registers the practitioner is actually on | A "Dr" name without a general medical qualification; implied regulation; a health professional endorsing the medicine | "Practitioners must have relevant and recognised qualifications"; "should not misleadingly claim or imply that a practitioner is a medical professional" | CAP Code rules 12.3 and 12.18; CAP and BCAP guidance, revised November 2021; Dr Bunny Aesthetics, 24 April 2024 |
| Social post | The clinic, the consultation, fillers | The medicine's name, including in hashtags; media where 25% or more of the audience profile is under 18 | A reference to the medicine on social media pages, "including hashtags, is likely to be seen as an implied ad for a POM"; rule 12.25; "25% or more of the audience profile is under-18s" | CAP's advice, 29 October 2025; CAP Code rule 12.25, in force 25 May 2022; CAP and BCAP guidance, revised November 2021 |
| Offer | A responsible offer on a non-surgical treatment that is not prescription-only, with no pressure to book | Any price promotion on the medicine; countdown clocks; "Hurry, offer must end Friday" | "No, this is likely to breach the Code"; "the promotion must be responsible" | FAQ, 23 January 2020; CAP's advice, 1 July 2025; CAP and BCAP guidance |
| Results and safety | Results you hold evidence for | "safe" or "easy" used irresponsibly; "guaranteed" without proof; a claim of approval by the ASA | "should avoid irresponsibly describing cosmetic interventions as 'safe' or 'easy'"; rules 12.9 and 3.51 | CAP and BCAP guidance, revised November 2021; CAP Code |
What this post does not say
That before-and-after photos are banned. No page we read bans them for every treatment. The firm lines concern the medicine.
That a licensing scheme is in force. As at 1 October 2026, the proposed licensing scheme for non-surgical cosmetic procedures in England is not in force. We found no regulations made under the power in the Health and Care Act 2022 (s.180, in force since 1 July 2022). On 23 June 2026 the Government said it was "preparing a consultation on the draft legislation" for its proposals on the highest-risk procedures. We found no such consultation on GOV.UK on 29 September 2026.
How many clinic ads break the rules. We have no audit data. The liquid BBL figures are CAP's, for one procedure on Meta.
Where to start
- Rewrite the consultation page first. Name the concern, and leave the medicine's name off it.
- Gather the evidence. Hold proof for each objective claim and each qualification you name. Hold signed and dated proof for each photo, and permission and contact details for each testimonial.
- Check the medicine appears nowhere it should not. Our post on the advertising rule covers its name and the softer phrases. Our post on price lists covers the route CAP describes for a price list.
Our page for aesthetic clinics sets out the consultation-first structure, and the whole-site checklist covers the rest of a clinic site. The free audit includes a rules check for clinics that gives no legal verdict. Or get in touch.