When Google's AI Writes Your Clinic's Ads: Who Is Responsible?

When my team audits a clinic's Google Ads account now, one of the first things we open is the asset report. The clinic may have approved every headline it wrote. The question is what else is running: lines written by Google's AI from the clinic's own website, marked "Google AI" in the "Added by" column.

That is now normal. Google Ads can write headlines and descriptions, choose a different landing page, add callouts and images from your site and generate new images. Each of these is switched on in a different place, and some are on by default. Meanwhile, Singapore's healthcare advertising rules haven't changed, and they put the responsibility on the clinic.

From this guide, you will learn:

• which Google Ads features can create or change your ad content, using Google's own names for them
• what the Healthcare Services Act and the advertisement regulations say about who is responsible
• how these features can produce a non-compliant ad from a compliant-looking account
• a control checklist my team uses, and what to do if something has already run

I'm a marketer, not a lawyer, and this isn't legal advice. It's how my team reads the rules when we run Google Ads for clinics. For a specific situation, check MOH's guidance or speak to a lawyer.

What Google's AI can now write for you

Google renames these features often, so I've used the names on Google's help pages as of writing.

Text customization (formerly automatically created assets)

Google's page on text customization notes it "was formerly known as automatically created assets." It generates additional headlines and descriptions for your responsive search ads, based on your domain, landing page, existing ads and ad group keywords, using light-touch extraction (such as snippets from page titles, descriptions and meta tags) and generative AI grounded in your landing page content.

In Search campaigns it is a campaign-level setting within AI Max. Google says that starting in September 2026, campaigns using text customization are being upgraded to AI Max automatically. If your account had automatically created assets switched on at some point, check it now.

According to Google's AI Max page, turning AI Max on switches on search term matching, text customization and Final URL expansion together, though each can be turned off separately. Performance Max campaigns have their own text customization controls.

Final URL expansion

Final URL expansion lets Google send a click to a different page on your site from the one you chose. In Search, Google says that when text customization is also on, it may "generate a dynamic headline, description, and additional assets to match your landing page content" (see Final URL expansion in Search). In Performance Max, Google says Final URL expansion "is turned on by default."

For a clinic, that means an ad can land on, and write copy from, an old promotion page, a blog post or a doctor profile you never meant to advertise.

Account-level automated assets

These are separate from text customization and are set for the whole account. Google's page on account level automated assets lists: dynamic sitelinks, dynamic structured snippets, automated location assets, seller ratings, dynamic callouts, dynamic business information, dynamic image assets, automated promotions and site visits.

Three of these matter most for clinics:

• Dynamic callouts show "relevant information about the products and services offered on your site," taken from your landing page.
• Dynamic image assets let Google "curate relevant visuals from your ad's landing page."
• Automated promotions "automatically sources, validates, and displays high-quality deals and offers from your website and other sources."

Seller ratings, in Google's words, "show a combination of information and reviews next to your ads." Performance Max campaigns use the account-level setting by default, though you can override it per campaign.

Generated images and video

Google's page on generated images describes generative AI tools that create new image assets, either from your prompts or as suggestions for you to review. Access is limited and rolling out gradually. Google states: "Advertisers should review any generated or suggested assets to ensure that they're accurate, not misleading," and that generated assets "aren't guaranteed to be approved by Ads Policy." In Performance Max, Google also says that if you don't upload video, it "will automatically create video assets using the text and images in your asset groups."

Who is responsible under HCSA

Here is what the law says, in the words of the statute. Read the current text yourself on Singapore Statutes Online: the Healthcare Services Act 2020 and the Healthcare Services (Advertisement) Regulations 2021.

• Section 31(1) of the Act says a person must not advertise, or cause to be advertised, a licensable healthcare service unless they are the licensee or are "acting on the authority of the licensee."
• Section 31(2) says that for every advertisement by or caused by the licensee or such a person, "the licensee and that person (if applicable) must ensure that the advertisement complies" with the prescribed requirements on medium, content and form.
• Regulation 2 defines an advertisement as information "published, disseminated or conveyed, or caused to be published, disseminated or conveyed, by any means or in any form or medium" to advertise the service.
• Regulation 5(1) says "A licensee must ensure that any advertisement" published or caused to be published "by the licensee or an authorised person (if applicable)" meets the content requirements.

The regulations also define an "authorised publisher": someone who publishes on the licensee's authority but "does not prepare, determine or influence (wholly or partially) the contents of the advertisement." An ad platform whose AI writes your headlines doesn't fit neatly into either category, and I'm not going to guess how MOH or a court would classify it. What is clear is that the duty in section 31(2) and regulation 5(1) is placed on the licensee, and that your clinic chose to run the campaign and to leave the feature on.

MOH's advertising regulations FAQs point the same way. They say search engine marketing "is governed by the HCS (Advertisement) Regulations," and that even where an agency is appointed by contract, "the licensee ultimately is responsible to ensure all advertisements relating to the licensable healthcare service(s) comply."

The penalty for failing to comply with section 31(1) or (2) is a fine of up to S$20,000, imprisonment of up to 12 months, or both, with further daily fines for a continuing offence. That alone is a reason to know what your account is generating.

What can go wrong

Google's AI isn't trying to break Singapore law. It is trying to write ads that perform, using whatever is on your website. Google's text customization page tells advertisers to "Ensure your website content is accurate, not misleading, and not in violation of Google Ads policies." It doesn't check the HCSA rules, which are stricter.

These are the patterns I'd watch for, with the regulation each one runs into:

• Superlatives lifted from your site. Say your "About us" page says "one of the most experienced teams in Singapore." A generated headline becomes "Singapore's Most Experienced Team." Regulation 5(1)(e) rules out "any laudatory statement (including a statement of prominence or uniqueness) or superlative."
• Offers surfaced from old pages. Say a 2022 page still mentions a complimentary review. Automated promotions or a generated description turns it into an offer. MOH's FAQs list words like "complimentary", "free", "offer" and "promotion" as examples of soliciting or encouraging use of a service, which regulation 5(1)(g) prohibits.
• Outcome claims. Say a treatment page says patients "can see results in two weeks." A generated headline drops the qualifier. Regulation 5(1)(c)(ii) prohibits information that "creates an unjustified expectation," and MOH's FAQs give "straight teeth in 2 weeks" as an example of soliciting.
• Reviews. Seller ratings show reviews next to ads. Regulation 5(1)(f) bars reviews, testimonials and endorsements in a licensee's ad, and regulation 2 defines a review to include a rating.
• Images that imply a result. A generated or curated image of smooth skin next to a treatment name. Regulation 5(1)(d) bars before-and-after images and images "only after" treatment.
• Prices with a prefix. MOH's FAQs say licensees may list only the exact and final price, without a prefix or a comparison price. Google notes that its term exclusions "can't prevent assets with prices from being generated."

None of this needs anyone at your clinic to type a non-compliant word into Google Ads. That's the point.

A practical control checklist

This is what my team does on every clinic account. Adapt it to yours.

1. Decide on text customization. For most clinics I turn it off. In a Search campaign, Google's steps are: Campaigns, Settings, select the campaign, AI Max, then untick "Text customization" in the Asset optimization panel (see Google's instructions). Google notes that this also turns off Final URL expansion if it was on.
2. Turn off risky account-level automated assets. Go to Assets, open the Associations view, then the three-dot menu, "Account level automated assets", then "Advanced settings", and turn off the ones you don't want. For clinics I always turn off automated promotions and seller ratings, and usually dynamic callouts and dynamic image assets too.
3. Control Final URL expansion in Performance Max and AI Max. Turn it off, or exclude every URL that isn't a reviewed landing page.
4. Use text guidelines if you keep generation on. Google's text guidelines are a beta, campaign-level feature for Performance Max and AI Max Search campaigns. They need text customization switched on, and allow up to 25 term exclusions and 40 messaging restrictions per campaign. I'd exclude terms such as best, leading, top, free, complimentary, discount, promotion, offer, guaranteed and painless, and add a restriction such as "Don't generate assets with prices," which is Google's own suggested wording for prices.
5. Use brand exclusions where Google offers them, in Performance Max and AI Max, to stop ads showing alongside brands you don't want to be associated with.
6. Review the asset report weekly. Filter by the "Added by" column for assets added by Google AI, and check every one. In Performance Max, check the "Expanded Final URL assets" tab too. Google notes that a removed Google-customised text asset "is permanently removed."
7. Upload your own video for Performance Max, so Google doesn't assemble one from your images and text.
8. Clean your landing pages, because they are the source material. Remove superlatives, old offers, review widgets and results images across the whole site, not just the pages you advertise. Our HCSA advertising rules guide has a word list to scan for.
9. Log every review. Date, who checked it, what was removed and why. If a question ever comes up, a log shows that the clinic was managing the account, not leaving it to a machine.
10. Put it in your agency agreement. MOH's FAQs say appointments of authorised persons should be documented, for example by contract or letter of appointment. State who is allowed to turn automated features on, and who signs off.

If a non-compliant ad has already run

Regulation 17(1) says that where a licensee becomes aware of a non-compliant advertisement, it "must take all reasonable steps to procure the rectification or withdrawal of the non-compliant advertisement and to prevent its recurrence." Where an authorised person, such as an agency, published it, regulation 17(2) requires the licensee to tell them, and regulation 17(3) requires them to fix it and report back. Regulation 17(8) also lets MOH's Director-General order an advertisement to be altered, withdrawn or removed.

In practice, this is the order I'd work in:

1. Stop it serving. Remove the asset, or pause the campaign if you can't isolate it.
2. Record it first. Screenshot the asset report showing the text, the date range and the "Added by" source before you remove anything, since some removals are permanent.
3. Switch off the feature that generated it, or add a term exclusion that blocks it.
4. Fix the source. Find the page the wording came from and correct it.
5. Check the rest of the account for the same pattern in other campaigns.
6. Write it up in your compliance log: what ran, for how long, what you did and what you changed to prevent it recurring. If your agency runs the account, ask for this in writing, as regulation 17(3) expects.
7. Get legal advice if MOH contacts you, or if the ad ran widely or for a long time.

Automation is fine, unreviewed automation isn't

I'm not against Google's AI features. Smart Bidding is useful once tracking counts real bookings, and Performance Max can suit some clinics. The difference is between automation that decides how much to bid and automation that decides what your clinic says to the public. The second kind needs a human to check it, because the law expects the clinic to stand behind every word.

If you're setting up campaigns from scratch, our guide to Google Ads for Singapore clinics covers structure, tracking and bidding. If you'd like us to audit an existing account for generated assets, that's part of our Google Ads service and our wider medical advertising work.