Plastic Surgery Advertising Rules: Before And After Photos, Reviews And HIPAA

Last updated: November 12, 2026

Short answer: plastic surgery advertising in the US is governed by four layers of rules: HIPAA (patient photos and details need written authorization for marketing), the FTC (claims must be truthful and substantiated, and fake or incentivized reviews are prohibited), state medical boards (which regulate claims such as “board certified” and testimonials), and ad platform policies from Google and Meta (which restrict before-and-after images and require age targeting for cosmetic procedures). This guide explains each layer in plain language. It is general information, not legal advice.

1. HIPAA: patient photos and information

• Before-and-after photos are protected health information. Using them on your website, social media or ads requires the patient’s signed HIPAA marketing authorization, separate from the surgical consent.
• Remove identifiers such as tattoos, jewelry and backgrounds unless the patient has agreed to be identifiable.
• Never confirm a patient relationship in public. Replying to a review with “we’re sorry your recovery was hard” can confirm the person is a patient and has led to HIPAA penalties.
• Use HIPAA-aware forms and tracking. Website forms, chat tools and some analytics pixels can expose health information; vendors that handle it should sign a business associate agreement.

2. FTC: truthful claims and genuine reviews

• Claims must be truthful and backed by evidence. Avoid promising results, “painless” procedures or “no downtime” unless you can support them.
• Results that are not typical need context. If you show dramatic outcomes, make clear that results vary.
• Fake and incentivized reviews are prohibited. The FTC’s rule on consumer reviews bans fake reviews, buying reviews and suppressing negative ones, with civil penalties for violations.
• Disclose material connections. Influencers and patients who receive free or discounted treatments in exchange for posts must clearly disclose it.

3. State medical board rules

• Board certification claims. Many states limit “board certified” to boards recognized by the American Board of Medical Specialties or an equivalent, and require naming the board.
• Testimonials and guarantees. Some states restrict testimonials or ban guarantees of results.
• Pricing and discounts. Some states regulate how discounts and package prices can be advertised.
• Who can advertise what. Non-physician providers must describe their credentials accurately.

Rules vary by state, so check your state medical board’s advertising rules or ask a healthcare attorney.

4. Google and Meta ad policies

• Meta limits cosmetic procedure ads to adults and restricts before-and-after imagery and content that implies negative self-perception about appearance.
• Google Ads treats healthcare as a restricted category, limits some prescription drug terms and can disapprove ads with shocking or sensational imagery.
• Prescription products such as neurotoxin brand names are restricted in ads on both platforms.

A quick compliance checklist

1. Signed HIPAA marketing authorization for every photo, video and testimonial
2. Results-vary language near before-and-after galleries
3. Board certification stated accurately with the board’s name
4. No guarantees, no unsupported “best” or “safest” claims
5. Influencer and patient-ambassador disclosures
6. Review requests sent to all patients, with no incentives and no gating
7. BAAs with website, CRM, chat and call-tracking vendors
8. Ad creative reviewed against Google and Meta policies before launch

Frequently asked questions

Can I post before-and-after photos on Instagram?

On your organic profile, yes, with the patient’s written HIPAA marketing authorization. In paid Meta ads, before-and-after images for cosmetic procedures are restricted.

Can I offer a discount in exchange for a review?

No. Incentivizing reviews violates FTC rules and most review platforms’ terms.

Can I say I am the best plastic surgeon in my city?

Superlatives that cannot be substantiated can be considered misleading by the FTC and state boards. Use verifiable facts, such as years in practice or procedures performed.

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