Prescription-Only Medicines and Aesthetic Clinic Websites

The rule in one sentence

Rule 12.12 of the CAP Code says: "Prescription-only medicines or prescription-only medical treatments may not be advertised to the public"^[1]. The MHRA's guidance for businesses puts it the same way: you cannot advertise prescription-only medicines to the general public, although you can promote them to healthcare professionals and others who can prescribe or supply them^[2]. The legal requirements sit in Part 14 of the Human Medicines Regulations 2012, which the MHRA's guidance links to.

The rule applies to the medicine, not to the clinic. A clinic can advertise that it exists, what concerns it helps with and that it offers consultations. What it cannot do is promote a prescription-only medicine itself.

Which treatments this affects

For most private clinics, the treatments affected are:

• Botulinum toxin products used for lines and wrinkles, often called anti-wrinkle injections.
• Weight management medicines that are prescription-only, including the injectable medicines widely discussed in the news.
• Some treatments for hair loss, skin conditions and sexual health that rely on prescription medicines.

Dermal fillers are not prescription-only medicines, so rule 12.12 does not apply to them in the same way, but they are still covered by the CAP Code's rules on cosmetic interventions, including the rule that such marketing must not be directed at under-18s^[1].

What the ASA says about Botox on websites

The ASA and CAP published guidance on advertising Botox in October 2019 that gives a clear summary for clinic websites^[3]. The key points:

• Neither the products nor treatments using them can be advertised to the public.
• The ban covers "logos, testimonials, links, hover text, small print and price lists", so prices for Botox treatments should not be advertised.
• References to Botox should not appear on the home page, and casually browsing consumers should not be able to come across information about Botox or other prescription-only medicines with ease.
• A clinic that offers Botox among other treatments can promote consultations, using wording such as "a consultation for the treatment of lines and wrinkles".
• Consultation advertising should make clear that various treatment options will be discussed and that a product will not be sold or administered if the person is not suitable.
• Limited references to Botox on a website may be acceptable if they are balanced and factual, in line with patient information leaflets or similar non-promotional material.

Weight management medicines

Advertising of prescription-only weight management medicines has drawn particular attention. The ASA, together with the MHRA and the General Pharmaceutical Council, issued an Enforcement Notice on the advertising of prescription-only medicines used for weight management. The current version is dated 23 September 2025, replacing a version that applied from 11 April to 22 September 2025, and it states that no prescription-only medicine may be advertised to the public^[4].

The MHRA's announcement of the updated notice, published on 26 September 2025, says advertisers should avoid language that refers to prescription-only medicines, giving "weight-loss injection", "obesity treatment jab" and "GLP-1" as examples. It also warns against imagery likely to be understood as denoting a prescription medicine, and against ads for general weight-loss products or services that direct people to other ads. The MHRA said it had taken action against more than 25 businesses that year for promoting prescription-only weight-loss medicines^[5]. The notice is aimed primarily at pharmacies, but the underlying rule applies to anyone advertising to the public.

How to structure an aesthetic or weight management site

A website built around consultations, rather than products, works within the rules. In practice:

1. Name pages after concerns, not products. "Lines and wrinkles consultation" or "medical weight management consultation", not product or brand names.
2. Describe the consultation. Who carries it out, what they assess, that all suitable options are discussed, including non-medical ones, and that no medicine is prescribed unless it is clinically appropriate.
3. Price the consultation, not the medicine. The consultation fee can be shown. Prices for prescription-only medicines should not be.
4. Keep the home page clear. No product names, images of pens or vials, or offers on prescription treatments.
5. Keep information balanced. If you provide factual information about a medicine after the consultation, keep it non-promotional and consistent with the patient information leaflet.
6. Avoid offers and urgency. Time-limited discounts and "book now" pressure on prescription treatments are hard to reconcile with the rule and with professional standards.

A short set of questions and answers on each consultation page helps patients understand the process without turning the page into product promotion: how long the consultation takes, who carries it out, what happens if treatment is not suitable, and whether the consultation fee is deducted from any later treatment. Keep the answers about the consultation, not the medicine.

Professional standards for prescribers

Doctors who prescribe or carry out cosmetic interventions have their own standards. Medical Protection's summary of GMC guidance says doctors must not minimise the risks of interventions or claim that an intervention is risk free, must not falsely state or imply that results are guaranteed, and should make clear where a medical assessment is needed first^[6]. Nurses and pharmacists who prescribe are bound by their own regulators' codes. A website that names prescribers should reflect those standards.

Search ads and social media

Paid search and social media are covered by the same rule as your website. Google's advertising policies allow some promotion of prescription drug services in the UK, but only by advertisers who are certified, and certification is required before such ads can run^[7]. Certification by Google does not change the UK legal position on advertising prescription-only medicines to the public, so ads still need to promote consultations rather than medicines.

Regulation of non-surgical cosmetic procedures

Regulation of the sector is changing. The Health and Care Act 2022 gave the Secretary of State power to set up a licensing scheme for non-surgical cosmetic procedures. Clyde and Co, writing in June 2026, described proposals that would sort procedures into risk tiers, with higher risk procedures limited to qualified, regulated healthcare professionals at CQC-registered premises, and said the timescale for implementation was unknown^[8]. If a licensing scheme is introduced, aesthetic clinic websites may need to show licence details alongside regulator and register information.