Last Updated on September 8, 2026
Cosmetic dentistry is regulated as a cosmetic intervention for advertising purposes, which means the rules are stricter than most practices assume and more specific than most agencies know.
All rule references below are from CAP’s advertising guidance on cosmetic interventions, dated November 2021, and CAP’s advice pages, read on 8 September 2026.
What applies
Teeth whitening is listed as a cosmetic intervention example in CAP’s guidance, so the whole of the cosmetic interventions guidance applies to it.
| Rule | What it requires |
|---|---|
| CAP 1.3 | Marketing communications must be prepared with a sense of responsibility to consumers and to society |
| CAP 3.1 | Communications must not materially mislead or be likely to do so |
| CAP 3.7 | Marketers must hold evidence for objective claims before publication |
| CAP 3.11 | Communications must not mislead by exaggerating capability or performance |
| CAP 12.1 | Objective claims need backing by evidence, potentially including trials on people |
| CAP 12.25 | Ads must not be directed at those aged below 18, nor appear in media aimed at under-18s or where 25 per cent or more of the audience is under 18 |
That last one is the one practices trip over, because social advertising audience composition is not something most people check before running a campaign about smiles.
Before and after photographs
CAP’s requirements are specific and most practice galleries do not meet them.
- Marketers must retain documentary evidence that the before and after photographs used are genuine, with signed proof from the subjects.
- Even genuine photographs require evidence substantiating the level of efficacy shown.
- Photographs must not result from digital manipulation.
Read that middle point carefully. It is not enough that the photographs are real. You need evidence that the result shown is representative of what the treatment achieves, because the photograph is functioning as an efficacy claim.
The practical response is an audit. Go through the gallery, keep only images where you hold signed dated consent and can evidence the result, and record the rest as removed. That is an afternoon of work and it closes the easiest complaint anybody could make about your marketing.
Testimonials
Under CAP 3.45 to 3.47, testimonials must be genuine, supported by evidence, and must not mislead about likely average consumer outcomes.
Layered on top is the general UK position that since 6 April 2025 fake and concealed incentivised reviews are a banned practice, with fines of up to £300,000 or 10 per cent of global turnover for businesses and £150,000 for individuals, and in March 2026 the CMA opened investigations into five named businesses.
The safe approach is the one that also works better: ask everyone, about the consultation, the explanation and the aftercare, and incentivise nobody. Whito’s August 2026 study found the median quoted review count for AI-named dental practices was 368, so volume matters, and volume is achievable honestly.
Whitening claims specifically
From CAP’s teeth whitening advice page, dated 16 September 2025:
- Advertisers must substantiate shade-improvement claims, and studies must be blinded and controlled.
- Ads must not promise results fast, or after one or minimal use.
- Before and after photographs must not result from digital manipulation.
- Savings claims need evidence that the service was previously sold at the stated price.
- Tooth whitening carried out by non-dental professionals could be illegal, and the ASA directs marketers to check with the GDC.
The savings claims rule is worth a moment. Was £900, now £600 requires evidence that you actually sold it at £900. That is a records question as much as a copy question.
The title Dr, and endorsement
CAP advice is that use of Dr must not imply medical qualifications if the dentist does not hold a general medical degree. It is a small point, it is checked, and it is easy to get right with a line explaining the qualification.
CAP 12.18 prohibits using health professionals or celebrities to endorse medicines. A dentist may not endorse a medicinal toothpaste but may endorse a cosmetic dental product. If your practice does any brand work, that distinction matters.
Related, and relevant if your practice also offers facial aesthetics: botulinum toxin is a prescription-only medicine and may not be advertised to the public at all, and CAP’s guidance states public materials must not mention Botox, Dysport or botulinum toxin. That is covered in full in our aesthetics advertising guide.
What CAP does not say, which is also useful
In the interests of not overstating: the ASA’s dental advice page does not state specific rule numbers for price claims, for implants, or any requirement to show GDC registration in advertisements. We record that as not published rather than inferring a rule that is not there.
Publishing your GDC registration is therefore best practice and a strong trust signal, not an advertising requirement. It is worth doing for the first two reasons.
A compliance pass you can run this week
- Search every page, title, meta description and image alt text for the word specialist. Keep it only where the clinician is on the relevant GDC list.
- Audit the before and after gallery against signed consent and efficacy evidence. Remove anything you cannot support.
- Check whitening copy for speed promises, unsubstantiated shade claims and savings claims you cannot evidence.
- Check audience settings on any social advertising against the under-18 rules.
- Check for any mention of a botulinum toxin brand if you offer facial aesthetics.
- Check the use of Dr and add a line explaining the qualification.
- Add GDC registration numbers as text with a link to the free register.
None of that costs money. All of it reduces risk, and items one and seven materially improve how a patient reads the page.
Common questions
Can a dental practice use before and after photos?
Yes, if it holds documentary evidence that they are genuine with signed proof from the subjects, evidence substantiating the level of efficacy shown, and the images are not digitally manipulated.
Can dental ads target under-18s?
No. CAP 12.25 states ads must not be directed at those aged below 18, and must not appear in media aimed at under-18s or where 25 per cent or more of the audience is under 18.
Does a dental ad have to show GDC registration?
The ASA’s dental advice page does not state such a requirement, so we do not claim one. Publishing registration numbers is strong practice and a real trust signal, particularly for implant work where no specialist list exists.
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