Med spa, beauty and wellness: the numbers, the rules, the AI picture.

• FTC Act section 5 and the FTC Health Products Compliance Guidance (December 2022)

  Health claims must be truthful, not misleading and backed by competent and reliable scientific evidence, which for health benefits generally means randomized, controlled human trials. The FTC judges the net impression, including implied claims. It says consumer testimonials are never enough to substantiate a health claim, and that "results not typical" does not cure an ad that shows exceptional results.

  What it means: Remove claims such as melts fat, reverses aging, detoxes or boosts immunity unless you hold the science for that exact claim. Show typical results, not your best case. Weight loss claims need studies that measure weight change. The guidance speaks to health-related products, so apply the same standard to claims about treatments and devices.

  [9] ftc.gov

• FTC Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465) and the Endorsement Guides

  The rule, announced August 14, 2024, bans fake reviews, incentives conditioned on a positive or negative review and undisclosed insider reviews by officers and managers. It also bans review suppression through unfounded legal threats, or by misrepresenting that displayed reviews are all or most of them. The FTC can seek civil penalties against knowing violators. The Endorsement Guides, revised in 2023, require influencers to disclose free treatments, discounts and payment clearly.

  What it means: Do not trade a free facial or a discount for a five-star review, and do not ask staff to review you without disclosure. Gifted influencer treatments need a clear disclosure such as 'Ad' at the start of the post, and the FTC says the brand stays responsible for what influencers claim. Pre-approve paid posts.

  [10] ftc.gov

• FDA position on compounded and unapproved GLP-1 drugs

  The FDA says compounded drugs are not FDA approved and are not reviewed for safety, effectiveness or quality before marketing. It lists as a red flag any provider that claims a compounded drug is the same as an FDA-approved drug. It says salt forms such as semaglutide sodium and semaglutide acetate are different active ingredients. It has issued warning letters to telehealth companies marketing unapproved GLP-1 drugs.

  What it means: Do not write 'same as Ozempic', 'generic Wegovy' or 'FDA-approved ingredient' about a compounded product. Say plainly that compounded medicines are not FDA approved, that a licensed clinician decides eligibility, and who prescribes. Have a healthcare attorney review every weight loss page and ad before launch.

  [11] fda.gov

• FDA approved uses for dermal fillers and devices

  The FDA approves fillers for specific uses in adults aged 22 and over. These include facial wrinkles and folds and augmenting the lips, cheeks, chin and back of the hand. It says injection into the glabella, nose, periorbital area, forehead or neck is not approved. It recommends against fillers for body contouring and says injectable silicone is not approved for any aesthetic use. It warns against needle-free filler pens.

  What it means: Do not call a non-surgical nose job, a filler buttock lift or a hyaluron pen treatment FDA approved. If a clinician uses a product off label, do not imply FDA approval for that use. State the risks the FDA lists, including vascular injection, on the treatment page.

  [12] fda.gov

• State medical board supervision rules (California example) and Texas elective IV therapy law

  The Medical Board of California says injections and lasers are medical treatment, performed by a physician or by a registered nurse or physician assistant under physician supervision. The supervising physician need not be on site but must be immediately reachable, and medical spas must be owned by physicians. Cosmetologists may not inject or use lasers. Texas HB 3749 (Jenifer’s Law) limits who may give elective IV therapy, from September 1, 2025.

  What it means: Name the medical director on the site, describe each provider’s license accurately and never let an esthetician page advertise injections or lasers. Ownership and supervision rules differ widely by state, so confirm yours before you write the about page. Do not promote IV drips as a spa add-on given by unlicensed staff.

  [13] mbc.ca.gov

• California Business and Professions Code section 651 (before-and-after photos and prices)

  Section 651 bars false or misleading advertising by healing arts licensees. Before-and-after photos must name the procedure, be comparable in pose and lighting and state that the same results may not occur for all patients. Models must be labelled. Price ads must be exact, and phrases such as 'as low as' and 'and up' are prohibited. Knowing violations by physicians can bring fines of up to $10,000 per event.

  What it means: If a California licensee is behind the ad, caption every photo with the treatment and the results statement, match the lighting, label models and drop 'starting at' pricing. Many states have similar rules, so treat 651 as the strictest common case and check your own state.

  [14] california.public.law

• HIPAA Privacy Rule (where the business is a covered entity) and state health data laws

  A provider is a HIPAA covered entity if it transmits health information electronically in a standard transaction, such as billing insurance. A covered entity needs a signed authorization before using protected health information for marketing, and full-face photos are listed identifiers. Washington’s My Health My Data Act also protects health data outside HIPAA, including data from which a health status is inferred.

  What it means: Get a signed, specific authorization before you post any client photo, video or story, whether or not you are covered by HIPAA. Never confirm in a review reply that someone is a client. Cash-only spas should still check state health data laws before adding tracking pixels to treatment and booking pages.

  [15] law.cornell.edu

• Google Ads healthcare and medicines policy, and Meta health and wellness ad standards

  Since an update enforced from October 29, 2025, US advertisers may use prescription drug terms in ads and landing pages without certification but must be certified to keyword-target them. Google treats health as a sensitive interest category, so advertiser-curated audiences and Customer Match are not supported. Meta requires cosmetic procedure and weight loss ads to target people 18 or older and bans statements of inferiority about appearance.

  What it means: Do not bid on prescription drug names without certification, and do not build remarketing lists from client data for health ads. On Meta, target adults only, avoid copy that attacks how someone looks and state the time taken to see weight loss results. Prescription drug ads on Meta need LegitScript certification for telehealth and Meta’s authorization.

  [16] support.google.com

• United Kingdom and Canada: prescription-only medicine advertising

  In the UK, botulinum toxin is a prescription-only medicine, and CAP Code rule 12.12 bars advertising it to the public. The ASA treats almost any reference to Botox, including hashtags and names like Beautox, as an ad. The Botulinum Toxin and Cosmetic Fillers (Children) Act 2021 bans these treatments for under-18s in England. In Canada, an ad for a prescription drug to the public may state only its name, price and quantity.

  What it means: UK clinics should promote 'a consultation for lines and wrinkles' and never name the toxin in ads, social posts or hashtags. Canadian clinics should keep toxin and GLP-1 claims to name, price and quantity. US-style Botox specials do not travel across the border.

  [17] asa.org.uk

This is general information, not legal advice. Rules on who may perform and advertise aesthetic and wellness treatments differ by state, province and country and change often. Check your medical or cosmetology board, the platform policies and a qualified healthcare attorney before you publish.