Read enough ASA adjudications involving aesthetic clinics and a pattern emerges. The same types of violation appear across different businesses, different practitioners, different regions. Most of them are not the result of deliberate deception. They are the result of marketing that was produced without a system for catching problems before they went out.
What follows is a list of the ten violations we encounter most frequently — in ASA rulings, in accounts flagged by Meta, and in clinic marketing reviewed as part of governance audits. For each one: what it is, how it typically appears in practice, why it is a violation, and what doing it correctly looks like.
Unsubstantiated efficacy claims
What it isMaking claims about the effectiveness or results of a treatment that cannot be substantiated by adequate evidence.
How it appearsCopy like "the most effective treatment for facial rejuvenation", "clinically proven to reduce wrinkles by 80%", "results guaranteed", or "the gold standard in lip augmentation". These claims appear on clinic websites, in paid ads, and in organic social content — often because they have been copied from manufacturer marketing materials, which are written for a different regulatory context.
Why it is a violationRule 3.7 of the CAP Code requires that marketing communications not mislead consumers about a product or service's efficacy. Superlative claims ("the most effective") require evidence that the treatment outperforms all comparable treatments. Percentage claims require clinical substantiation specific to the treatment as administered at the clinic. "Clinically proven" as a phrase carries specific evidential requirements.
The correct approachClaims should describe outcomes that can be substantiated by evidence the clinic holds — typically a combination of peer-reviewed literature, clinical trial data where it exists for the specific treatment and protocol, and documented patient outcomes. Claims should be hedged appropriately: "may help to reduce the appearance of" rather than "eliminates". Every claim should have a corresponding piece of evidence on file.
Before-and-after images that create misleading impressions
What it isUsing imagery in which the photographic conditions, editing, or selection of result create a false impression of what a treatment typically achieves.
How it appearsThe "after" image is lit more flatteringly than the "before". Makeup has been removed in the before and applied in the after. The camera angle is different. The result shown was exceptional rather than typical. The after image was taken at peak effect rather than at a representative point in the results timeline.
Why it is a violationCAP Code Rule 12.23 prohibits the use of imagery that creates a misleading impression about the likely results of a cosmetic treatment. The test is not whether the result shown is genuine — it is whether a consumer would form an accurate impression of what they could typically expect.
The correct approachConsistent photography conditions across before and after. No makeup in either image or identical presentation. After image taken at a timeframe representative of durable typical results. Accompanying copy that contextualises the result as one individual's experience. Documented approval process for each image used in marketing.
Pressure tactics and artificial urgency
What it isCreating a false impression that an offer, price, or availability is more time-limited than it is, in order to pressure a consumer into making a faster decision.
How it appearsCountdown timers on promotional offers that reset when they reach zero. "Only 3 consultation slots remaining this month" messaging that does not reflect genuine availability. "Book before midnight tonight to secure this price" promotions where the price is available indefinitely. Flash sale emails sent repeatedly with the same deadline.
Why it is a violationThis falls under CAP Code Rule 3 (misleading advertising) and, since April 2025, is explicitly within the scope of the DMCCA's provisions on unfair commercial practices. The CMA has direct enforcement powers in this area and has published guidance specifically noting urgency tactics as a priority enforcement concern.
The correct approachUrgency messaging must be genuine. If an offer ends on a specific date, that date is real and not extended. If availability is limited, it is genuinely limited and the messaging is removed when it is no longer accurate. Promotions should be reviewed by someone with the authority to confirm their accuracy before they go out.
Testimonials that imply typical results
What it isUsing patient testimonials in a way that implies the result described is what patients in general can expect from the treatment.
How it appearsA testimonial from a patient who experienced an exceptional result, presented without any context indicating this is one person's experience. A video testimonial where the patient describes results that are demonstrably atypical. A selection of testimonials that represents a best-case subset of the clinic's patient outcomes, presented as representative.
Why it is a violationCAP Code Rule 3.45 requires that testimonials used in advertising must not be taken out of context or misleadingly presented. Where a testimonial describes results, those results must be consistent with what consumers could typically expect. Using exclusively best-case testimonials without appropriate context breaches the requirement not to mislead about typical outcomes.
The correct approachTestimonials should be accompanied by context indicating they represent one individual's experience. If the result described is exceptional, the testimonial should include or be accompanied by information about the range of typical outcomes. Consent must be documented for each testimonial, including consent for the specific channels and uses for which it appears.
Comparative claims without substantiation
What it isClaiming that one treatment is superior to another treatment, or that one clinic's approach is superior to competitors, without adequate evidence.
How it appears"Better results than traditional Botox", "more natural-looking than standard fillers", "outperforms laser therapy", "the only clinic in London offering [specific technique]". Comparative language is used casually in copy without any recognition that it carries a specific evidential burden.
Why it is a violationCAP Code Rule 3.33 requires that comparative claims — claims that a product or service is superior to a competitor or alternative — be substantiated. The burden of evidence for a comparative claim is higher than for an absolute claim. "Reduces wrinkles" requires evidence. "Reduces wrinkles better than product X" requires head-to-head evidence comparing the two.
The correct approachEither avoid comparative claims or ensure they are backed by specific evidence. This includes brand-name comparisons ("better than Botox"), category comparisons ("more effective than laser"), and implied comparisons ("unlike other clinics, we..."). Each comparative claim should have a documented evidential basis.
Price advertising that omits necessary information
What it isAdvertising a price for a procedure or treatment that does not represent the full cost a consumer will incur.
How it appearsA headline price for a procedure that excludes an obligatory consultation fee. Filler pricing that omits the cost of a recommended review appointment. Surgery pricing that excludes anaesthetic costs, facility fees, or post-operative consultations that are in practice required. "From £X" pricing where the lower price applies only to a configuration that most patients do not purchase.
Why it is a violationThis is the drip pricing practice that the DMCCA explicitly targets, and it also falls under CAP Code Rule 3.17 (prices should include VAT and other taxes, and should not be misleading by virtue of omitting mandatory associated costs). The principle is that the consumer should be able to understand the total cost they will incur from the pricing information provided at the outset.
The correct approachAdvertised prices should reflect the total cost a typical patient will pay, or should clearly explain what is and is not included alongside the headline figure. "From" pricing should only be used where the lower price applies to a realistic purchasing option, and the conditions that determine which price a specific patient pays should be explained clearly.
Targeting advertising at under-18s for cosmetic procedures
What it isRunning advertising for cosmetic surgery or non-surgical procedures on channels or with targeting parameters that allow it to be seen by users under 18.
How it appearsMeta ad campaigns for lip filler or anti-wrinkle treatments with no minimum age gate. TikTok content promoting cosmetic procedures with no age restriction. Instagram organic content that would reach a significant proportion of under-18 followers without restriction. Email marketing to a list that has not been age-screened.
Why it is a violationCAP Code Rule 12.14 prohibits marketing for cosmetic surgery from being directed at under-18s. This applies to paid advertising and organic content. The Children and Young Persons Act 1933 and related legislation also restricts certain types of commercial communications directed at minors. Since 2021, the law explicitly prohibits the performance of certain cosmetic procedures on under-18s — marketing that targets this age group compounds the legal exposure.
The correct approachAge gates of 18+ should be applied at the account level for all paid advertising for cosmetic procedures, not just at the campaign level where they can be accidentally omitted. Organic content strategy should consider the demographic composition of the audience. Marketing plans for any procedure available only to adults should include an explicit confirmation that age-appropriate targeting is in place.
Claims about practitioner qualifications that overstate scope
What it isDescribing a practitioner's qualifications in terms that imply a broader scope of practice or level of clinical expertise than their actual credentials support.
How it appears"Medically trained specialist" applied to a practitioner whose medical training is not specific to the procedures they perform. "Award-winning surgeon" where the award was for a category unrelated to the procedure being advertised. Titles used without their qualifying context ("Doctor" used without specifying the field and registration status). Claims about specific qualifications that have not been verified as currently held.
Why it is a violationCAP Code Rule 12.1 requires that claims about health professionals be accurate and not misleading. Claims about qualifications that create a false impression of expertise in a specific area violate the requirement not to mislead. In the context of aesthetic medicine, where consumer trust in practitioner credentials directly influences decision-making, the stakes of a misleading qualification claim are high.
The correct approachAll qualification claims should be verified before use. The specific qualification held, the registering body, and the currency of registration should be confirmed. Descriptions should accurately reflect the practitioner's scope of practice. "Medically trained" should only be used where the medical training is relevant to the procedures being performed.
Failing to include required disclaimers for prescription treatments
What it isAdvertising treatments that involve prescription-only medicines without the required regulatory context, or in a way that effectively promotes the prescription product to consumers.
How it appearsUsing brand names for botulinum toxin products in consumer-facing advertising in a way that promotes the specific product rather than the aesthetic outcome. Advertising for treatment packages that involve prescription-only medicines without any indication of the prescribing pathway. Social media content that names prescription products in connection with availability and pricing.
Why it is a violationThe Human Medicines Regulations 2012 prohibit the advertising of prescription-only medicines to the general public. The CAP Code incorporates these requirements. This does not prohibit advertising that a clinic offers treatments for specific aesthetic concerns — it prohibits advertising that promotes specific prescription products by name in a consumer context. The distinction is between advertising an outcome (a reduction in the appearance of facial lines) and advertising a product (a named botulinum toxin brand).
The correct approachConsumer-facing content should describe aesthetic outcomes and the category of treatment, not specific prescription product names. Where a consultation is required before treatment can be provided (as it is for all treatments involving prescription-only medicines), the advertising should make clear that a consultation is part of the pathway. Marketing should not imply that a prescription treatment can be obtained without the required prescribing assessment.
Reposting UGC without governance review
What it isSharing or reposting patient-generated content — photos, videos, testimonials — without reviewing it against the applicable advertising standards before use.
How it appearsA clinic reposts a patient's Instagram story showing their results. A positive Google review is screenshot and shared to the clinic's social media. A patient's TikTok video is duetted or shared by the clinic's account. Patient photos tagged in the clinic's posts are reshared to the clinic's stories. In each case, the content passes directly from patient to clinic audience without any review of whether it meets the standards applicable to the clinic's marketing.
Why it is a violationWhen a clinic shares, reposts, or promotes content created by a third party, that content becomes the clinic's marketing communication for regulatory purposes. The CAP Code and ASA's remit covers content the clinic is responsible for — and a clinic that actively promotes or shares content is responsible for that content, regardless of who originally created it. UGC that includes unsubstantiated result claims, misleading imagery, or inappropriate targeting reaches an audience under the clinic's name and is assessed accordingly.
The correct approachUGC should be subject to the same review process as any other marketing content before it is shared or promoted. This means assessing the content against the CAP Code standards on claims, imagery, and context. Consent for resharing should be obtained and documented. Content that would not pass a compliance review should not be reshared, regardless of its source.
The governance principle
Most of these violations are not the result of bad intent. They are the result of a system that was not built to catch them. A marketing team under pressure to produce content, working without a compliance review process, will eventually produce content that violates these standards. Not because they wanted to — but because there was no mechanism to prevent it.
The solution is not a more comprehensive checklist. The solution is a system: a consistent review process, applied to every piece of content, before it is published. A record of what was reviewed, what standard was applied, and what the decision was. The capacity to answer, for any piece of marketing content in circulation, the question: why was this approved, and against what standard?
That is what a governance framework for aesthetic marketing looks like in practice. And it is the difference between an operation that catches violations before they become complaints, and one that learns about them afterwards.