Advertising Rules Every Cosmetic Surgery Practice Should Know in Ontario and the U.S.

Cosmetic surgery is one of the most competitive categories in local advertising, and one of the most regulated. Practices that win long term are the ones that market with confidence inside the rules. This guide summarizes the key requirements in Ontario and the United States.

This article is general information, not legal advice. Advertising rules vary by jurisdiction and change over time. Consult your regulatory college, medical board, or legal counsel for guidance specific to your practice.

Ontario: the CPSO Advertising policy

Physicians in Ontario are governed by the College of Physicians and Surgeons of Ontario (CPSO), whose Advertising policy sets out what physicians may and may not do.¹ Several requirements are especially relevant to cosmetic practices.

No testimonials

Physicians must not use testimonials in their advertising.¹ That rules out patient quotes and star-rated praise inside your ads.

Before and after photos, with conditions

Before and after photos and videos that meet the policy's requirements are not treated as testimonials, and may be used on your website and social media profiles.^1,2 They must be educational, show realistic outcomes of actual patients, use consistent lighting, pose and technique, and must not be manipulated. They must also carry a statement that results are not guaranteed and may vary between patients.¹

Critically, they must not be displayed where members of the public are likely to see them unsolicited.¹ In practice, before and after galleries belong on pages a patient chooses to visit, not in paid ads served to people scrolling a feed.

No comparisons or superlatives

Advertising must not compare a physician to others or suggest a better or more effective service than any other physician.¹ Phrases like "the best surgeon in Toronto" are out.

You are responsible for your agency's work

Physicians must ensure that any advertisement prepared on their behalf by a third party complies with the policy.¹ If your marketing agency runs a non-compliant ad, the responsibility sits with you.

United States: the FTC rule on fake reviews

In the U.S., advertising by physicians is shaped by state medical boards and by federal consumer protection law. The most significant recent development is the Federal Trade Commission's final rule on consumer reviews and testimonials, announced on August 14, 2024 and in effect since October 21, 2024.³

The rule prohibits, among other practices:^3,4

• Fake or false reviews and testimonials, including AI-generated ones.
• Offering compensation or incentives conditioned on a review expressing a particular sentiment.
• Reviews by owners, managers or employees that do not clearly disclose their connection.
• Suppressing negative reviews through unfounded legal threats or intimidation.
• Buying or selling fake social media indicators, such as followers or views.

The FTC can seek civil penalties against knowing violators.³

Why reviews still matter

None of this makes reviews less important. BrightLocal's 2025 Local Consumer Review Survey found that only 4% of consumers say they never read online reviews of local businesses, with Google the most-used review platform.⁵ The goal is to earn reviews honestly and consistently, not to manufacture them.

A compliance-first marketing checklist

1. Remove superlatives and comparisons from every ad and landing page.
2. Keep before and after galleries on your website, with the required disclaimer, and out of paid ads if you practise in Ontario.
3. Ask every patient for a review, not only the happy ones, and never tie incentives to positive sentiment.
4. Document patient consent for any image you publish.
5. Review your agency's creative before it runs. Their compliance is your compliance.

Education-first advertising, which explains procedures, recovery and candidacy honestly, fits comfortably within these rules and tends to attract better-qualified patients anyway.