SOVE7GN
Med spa before and after rules: what a reel or TikTok may show in the US and UK
Updated 25 October 2026 · Written by Reyansh Juneja and Naman Dhiman, the co-founders of SOVE7GN, who run the campaigns and review the clips
A med spa may post before and after photos and clips, but only of a real patient who signed consent, shot the same way before and after, labeled with the treatment, and never retouched. In the US the clip also counts as a claim about typical results, and in the UK the clinic must hold signed, dated proof that the images are genuine.
Short answer: in California, before and after images must be comparable in pose and lighting, name the procedure performed and carry a statement that the same results may not occur for all patients (B&P 651). The FTC says "results not typical" does not fix a misleading result (16 CFR 255.2). UK clinics need signed and dated proof the photos are genuine (ASA). Checked 25 October 2026. General information, not legal advice.
What does each rule require from a before and after clip?
| Rule | Who it binds | What it requires | What it means for a reel |
|---|---|---|---|
| California B&P 651(b)(3) | Healing arts licensees in California: physicians, nurses, dentists and others | No altered image. A model must be labeled as a model "in a prominent location". A real patient's image must say which procedures were performed. Before and after views must be "comparable in presentation" and state that the same results may not occur for all patients. | Treatment name and the results statement on screen or in the caption, same light and angle in both halves, no filter on either |
| Texas 22 TAC 164.3 | Physicians licensed in Texas (Texas Medical Board rules) | Models and actors must be identified as such. A testimonial needs a disclaimer about the speaker's credentials and a disclosure of any compensation. | Label any model. If the patient got a discount for filming, say so. |
| FTC 16 CFR 255.2 | Every US advertiser | A consumer endorsement implies the result is what people generally get. If it is not, disclose the generally expected result, and the disclosure must change the overall impression. | Your best result is not a fair sample. Pick typical cases or state what most patients see. |
| FTC 16 CFR 255.5 | Every US advertiser | Disclose a connection the audience would not expect, such as payment, a free or discounted treatment, or a work or family relationship. | A staff member or a comped patient in the clip needs a clear disclosure. |
| FTC 16 CFR 465.2 | Every US business | No testimonial that misrepresents whether the person exists, used the service, or their experience. | Never present a model or stock image as a patient result. |
| ASA before and after advice | UK advertisers | Before and after photos are treated like testimonials (CAP Code rules 3.47 to 3.50). Hold signed and dated proof they are genuine and not manipulated, and do not exaggerate. | Keep the raw files with dates and the patient's signed statement. |
| ASA cosmetic surgery advice | UK cosmetic intervention ads | Since November 2021, cosmetic intervention ads may not be targeted at under-18s (CAP Code rule 12.25). | Check the age split of your followers before posting results. |
| Meta health and wellness ad standard | Paid ads on Facebook and Instagram | Cosmetic procedure ads, including before and after depictions, must target people 18 or older. Ads may not insult a person's appearance or body parts. | Boosting a result reel means an 18+ audience and no "fix your flaws" copy. |
The Meta rule applies to paid ads only. The others apply to your own organic posts too: B&P 651 covers "any form of public communication", and the ASA has ruled against a clinic's own Facebook post (Linia Cosmetic Surgery, 4 May 2022, cited on the ASA cosmetic surgery page).
How do you film a before and after so it passes?
Most failing before and afters fail on the shoot, not the caption: the before is filmed on a phone in the treatment room and the after in better light at the follow-up, which breaks California's "comparable in presentation" test.
- Mark one spot in one room for every before and after: same wall, same light, lights on, blinds closed.
- Tape a mark on the floor and keep the phone on a fixed stand at the same height and distance.
- Same angle, same expression, hair back, no makeup change between the two.
- No beauty filter, no skin smoothing, no re-lighting in the edit, on either half.
- Film the date into the clip or keep the original files with their capture dates.
- Note the treatment, the amount used and the weeks since treatment, for the caption.
- Get the signed authorization first. Our patient photo consent form checklist lists what it must say.
When we cut these for a clinic, we do not retouch the treated area. The clinic keeps the consent and the proof file.
Which captions pass and which fail?
| Caption or on-screen text | Verdict | Why |
|---|---|---|
| "Lip filler, 1 syringe. After photo taken 2 weeks later. The same results may not occur for all patients." | Pass in California, if shot the same way | Names the procedure and carries the B&P 651 statement |
| "Erase 10 years in 20 minutes" | Fail | Creates an unjustified expectation; the FTC reads it as a typical result |
| A dramatic result with "Results not typical" underneath | Fail in the US | FTC 255.2 says that wording does not change the overall impression |
| A stock face with no label | Fail | B&P 651 requires a prominent "model" label; FTC 465.2 bars presenting it as a patient |
| "Our front desk lead tried it first" with no mention of her job | Fail | A work relationship is a material connection (255.5); disclose it |
| "Black Friday before and afters, booking closes Friday" (UK) | Fail | The ASA ruled that a Black Friday price post for breast surgery created urgency and broke the Code (Transform, 13 April 2022) |
| "Real patient. Results after 2 sessions. Results vary; a consultation comes first." (UK) | Pass, with the signed proof on file | Treated as a testimonial: genuine, dated, not exaggerated |
Two extra limits for UK clinics: no before and after of a prescription-only treatment such as Botox (see can you advertise Botox on Instagram), and no targeting of under-18s, so check who follows you before posting results.
What should never go in a before and after reel?
- A result from another clinic, a supplier's brochure or the internet.
- A patient who has not signed, even if the face is cropped. HHS says masking a patient afterwards does not replace a missing authorization (HHS film and media FAQ).
- The best result you have ever had, posted as if it were normal, with no statement of what most patients see.
- Copy that attacks how the viewer looks. Meta bars it in ads, and the ASA warns against ads that exploit insecurities.
For how before and afters fit into a full posting plan, see our med spa reel ideas or plastic surgery content ideas clip maps. If you want us to cut and post them, book a 30-minute call: you approve 2 example clips before anything goes live, and we go live within 48 hours. The service is on med spa video marketing, and the other niches we work with are on our founders page.
Questions people ask
Can med spas post before and after pictures?
Yes, in the US and the UK, if the patient signed consent, the images are genuine and unretouched, and the post does not imply everyone gets that result. California adds a procedure label, matching presentation and a results statement. UK clinics should not post before and afters of prescription-only treatments such as Botox.
Do before and after photos need a disclaimer?
In California, yes: a statement that the same results may not occur for all patients, plus the procedure performed. Elsewhere in the US, a disclaimer only helps if it tells viewers what most patients actually get; "results not typical" is not enough under the FTC guides.
Can you use a model in before and after photos?
Only if the post clearly says the person is a model, and never as a stand-in for a treatment result. California requires the model label in a prominent place, and Texas physicians must identify models and actors.
Can I boost a before and after reel on Instagram?
Meta allows before and after depictions for cosmetic procedures in ads targeted at people 18 or older, without copy that insults the viewer's appearance. Your state or UK rules still apply to the boosted version.
Want a straight answer for your videos?
Book a 30-minute call. Send us a link first and we'll tell you which plan fits and how many clips we can make.
Book a call See plans and pricing- Patient photo consent form for social mediaThe clauses a patient photo and video release needs in the US, UK and Canada.
- Med spa reel ideasOne recorded consult session, about 30 reels, and a 4-week posting calendar.
- Clipping for med spas and aesthetics clinicsDaily clips for med spas and aesthetics clinics, with the ad rules each must follow.