Clinic Advertising Rules in Singapore: The HCSA Guide (formerly PHMC)

When clinics come to us, one of the first things my team checks is their existing advertising. Almost every time, we find something that was either fine under the old rules or never fine at all: a "best aesthetic clinic in Orchard" headline, a Google rating widget on the homepage, a "free first consultation" banner.

This guide explains the advertising rules that apply to Singapore clinics today, in plain English. From this guide, you will learn:

• how the old PHMC rules became the HCSA rules, and why "PHMC-compliant" is now out of date
• what counts as an advertisement (it's more than most clinics think)
• the core things licensed clinics can't say or show, with examples
• what you can still do, and a checklist to run before anything goes live

One caution before we start. I'm a marketer, not a lawyer. This guide reflects how my team reads the rules and applies them day to day, but regulations get amended. Always check the current text of the Healthcare Services Act 2020 and the Healthcare Services (Advertisement) Regulations 2021 on Singapore Statutes Online (the Act and the advertising regulations), read the guidance on the MOH website, and speak to a lawyer about anything borderline.

From PHMC to HCSA: what changed

For decades, private clinics in Singapore were licensed under the Private Hospitals and Medical Clinics Act (the PHMC Act), and their advertising was governed by the PHMC (Publicity) Regulations. Plenty of clinic websites and agency pitches still say "PHMC-compliant".

The PHMC Act has since been replaced by the Healthcare Services Act 2020, usually shortened to HCSA. It came into force in phases from 3 January 2022, and outpatient medical and dental clinics moved across on 26 June 2023. Once a service is licensed under HCSA, its advertising is subject to the Healthcare Services (Advertisement) Regulations 2021.

The spirit is similar to PHMC: healthcare advertising should be factual, accurate and should not exploit patients' worries. What changed is the scope and the detail. The regulations cover a wider range of licensed services, and they deal more directly with how clinics actually advertise today, on websites, search ads and social media. So if your marketing was last reviewed "for PHMC", treat that review as out of date and look at everything again.

Who and what the rules cover

Who

The advertising regulations apply to HCSA licensees. For most clinic owners reading this, that means:

• medical clinics, including GP, specialist and aesthetic practices
• dental clinics
• other licensed services such as ambulatory surgical centres, nursing homes and home care providers

Two groups sit outside the HCSA advertising rules, or partly outside them. TCM practitioners are regulated by the TCM Practitioners Board, and their advertising is governed by the TCMPB Ethical Code and Ethical Guidelines, which take a similarly conservative line on testimonials and claims. If a TCM practice also holds an HCSA licence for another service, both sets of rules matter. Businesses that aren't licensees, such as a marketing agency's own website, aren't caught in the same way. But once an agency or creator publishes content for a clinic, that content is the clinic's advertising.

Doctors and dentists are also bound individually by their professional codes: the SMC Ethical Code and Ethical Guidelines for doctors, and the Singapore Dental Council's ethical code for dentists. Those codes apply whoever runs the ad.

What counts as an advertisement

A simple way to think about it: anything that promotes your clinic or its services to the public, in any medium. In practice that includes:

• your website, including blog articles and doctor profiles
• Google Ads, Meta ads, YouTube and TikTok ads
• organic posts on Instagram, Facebook, TikTok, RedNote (Xiaohongshu) and LinkedIn
• creator content you pay for or arrange, even if the only payment is a free treatment
• your Google Business Profile description and posts
• WhatsApp broadcasts, emails and SMS
• chatbot replies on your website

My team also treats links and embeds as part of your advertising. If your Instagram bio links to a creator's review video, or your website embeds a patient story from YouTube, you have effectively republished it.

The core prohibitions

These are the areas where we see clinics get caught most often. Each comes with an example of what to avoid and what works instead.

Testimonials, reviews and star ratings

Licensees can't use patient testimonials in their advertising. That includes quoted reviews, patient video stories, "what our patients say" sections, star ratings, and widgets that pull your Google rating onto your website.

• Avoid: "Rated 4.9 stars by our patients" on a landing page, or a carousel of Google reviews on your homepage.
• Instead: leave reviews where patients posted them. A map or directions link to your Google Business Profile is fine; a "read our 5-star reviews" button is, in our view, using the reviews as advertising.

We cover reviews in more detail, including how to reply safely, in our guide to removing Google reviews.

Before/after and after-only photos

Before-and-after images are out, and so are "after" images on their own that imply a result, such as a close-up of flawless skin captioned with a treatment name. This hits aesthetic clinics, dermatology and dental practices hardest, because results photos used to be their main selling tool.

• Avoid: a slider showing a patient's teeth before and after veneers.
• Instead: diagrams explaining how a procedure works, photos of your facility and equipment, and a doctor on camera explaining what the treatment involves and what recovery is like.

Superlatives and comparisons

Words like "best", "leading", "No. 1", "top", "most advanced" and "most trusted" are out, as are comparisons with other clinics or practitioners. Claims you can't substantiate as fact, such as "painless", cause trouble too.

• Avoid: "Singapore's leading LASIK centre."
• Instead: "LASIK and SMILE, performed by Dr [name], an ophthalmologist on the SMC Specialist Register."

This catches SEO work too: a page title like "Best Dentist in Tampines" is part of your advertising. Target the service and location instead.

Inducements: free consults, discounts, packages

Licensees can't offer inducements to attract patients. My team treats all of these as off-limits in ads, on the website and on social media:

• "free consultation" or "complimentary assessment"
• percentage discounts, first-visit promos, limited-time and festive offers
• bundled packages such as "3 sessions for $X"
• "from $X" pricing used as a hook
• lucky draws, gifts and referral rewards

What is generally allowed is plain, factual pricing. A price list stating the fee for a consultation or procedure, and what it includes, is information. The same number in a red starburst with "Limited slots!" is a lure.

Promised or guaranteed outcomes

You can't promise results. "Pain-free in 3 sessions", "guaranteed hair regrowth", "look 10 years younger" and "100% success rate" all fall foul of this. Softer phrasing like "get rid of your back pain for good" still implies an outcome that depends on the patient.

• Avoid: "Fix your slipped disc without surgery."
• Instead: "Physiotherapy for a slipped disc: how we assess it, what treatment involves, and when we'd refer you to a specialist."

Push marketing without consent

The rules also restrict how you reach people, not only what you say. Sending promotional messages by SMS, WhatsApp, email or phone to people who haven't agreed to receive them is a problem under the advertising regulations and, separately, under the PDPA's Do Not Call provisions (see the PDPC website). Build your lists from patients who have given clear consent, keep a record of it, and make opting out easy.

Doctors' titles and credentials

This is where the SMC Ethical Code and Ethical Guidelines sit alongside HCSA. These are the checks we apply on every clinic website:

• "Specialist" is reserved. Only doctors on the SMC Specialist Register in a given specialty should be described as specialists in that field. A GP with an interest in skin conditions can say so; they shouldn't be called a dermatologist or skin specialist.
• List registrable qualifications only. The SMC Ethical Code limits the qualifications a doctor can display to those on SMC's lists of registrable basic and postgraduate qualifications. Certificates from short courses or device training don't belong in the title line.
• Be careful with past appointments. "Formerly consultant at [hospital]" is factual history. Wording that implies a current hospital role that has ended is misleading.
• Aesthetic procedures. SMC's Guidelines on Aesthetic Practices for Doctors set out which aesthetic procedures doctors may offer. Outside a few specialties, a doctor needs a Certificate of Competence, or the required procedure experience, before offering some of them. Check before you list a procedure against a doctor's name.

Dentists have an equivalent specialist register kept by the Singapore Dental Council, and the same logic applies. For how this plays out on a specialist practice's website, see our notes on marketing for specialist clinics.

What you can still say

After all that, clinic owners often ask me what's left. Quite a lot. Compliant marketing is informative marketing, and informative content tends to rank and convert well anyway.

• Who your doctors are: registered qualifications, specialty, years in practice stated as fact, languages spoken, professional memberships.
• What you treat and how: conditions, procedures, what an assessment involves, typical recovery, risks and alternatives.
• Your facility and technology: photos of the clinic and the equipment you use, described factually.
• Practical information: location, opening hours, how to book, and whether you accept MediSave, CHAS or Integrated Shield Plan claims, where that's true.
• Plain pricing: fees stated as information.
• Education: articles and videos that help patients understand a condition, written in neutral language.
• Reviews patients leave on Google: encourage them and reply to them. Just don't copy them into your own advertising.

If you run paid campaigns, Google and Meta add their own healthcare rules on top of HCSA. Read Google's Healthcare and medicines policy and Meta's Advertising Standards, or see how we set up compliant medical advertising campaigns.

Social media and influencers

Social media is where most breaches happen now, because content is made quickly, by more people, and often by someone outside the clinic.

Creator content that you've paid for, arranged or exchanged for a free treatment is your advertising. If a creator posts "Best facial I've ever had, zero downtime, go to @yourclinic", that is a testimonial, a superlative and an outcome claim in one sentence, attached to your clinic's name.

What we do when briefing creators for a clinic:

1. Give them a written brief listing what they can't say: no results claims, no "best", no before/after, no discount codes, no "free".
2. Focus the content on experience and information: the clinic environment, meeting the doctor, what the consultation covered.
3. Review every caption and video before it goes live, and keep a record of the approval.
4. Don't reshare or boost content that breaks the rules, even if the creator posted it on their own.

The same applies to patients' comments. A comment under your post belongs to the patient. Pinning it, screenshotting it into a story or quoting it in a caption turns it into your testimonial.

A compliant clinic video looks like a doctor explaining a condition in 60 seconds, a walk through the treatment room, or a nurse describing what happens on the day. That content also does well on Instagram, TikTok and RedNote, because it answers questions patients actually have. There's more on how we approach it on our social media marketing page.

Penalties and responsibility

Breaching the advertising regulations is an offence under the HCSA, and MOH can impose fines, direct you to remove or correct an advertisement, and take regulatory action against the licence. The maximum penalties are set out in the Act; check the current text rather than relying on figures quoted in articles, this one included.

Three practical points matter more than the maximum fine:

• The licensee is responsible. "Our agency wrote it" or "the influencer said it" doesn't move responsibility off the clinic.
• Put your agency on paper, and name one approver. Under the HCSA, only the licensee, or someone acting on the licensee's authority (MOH calls this an "authorised person"), may advertise the clinic's licensed services. If an agency or creator publishes for you, appoint them in writing, and name one person at the clinic who approves every piece before it goes out. MOH explains this in its advertising regulations FAQs.
• Act fast on MOH instructions. If MOH asks you to take something down, remove it everywhere: old posts, landing pages still live for past campaigns, boosted posts and anything creators published for you.

Doctors can also face SMC disciplinary proceedings for advertising that breaches the Ethical Code, separately from any HCSA action against the clinic.

A pre-publish checklist

My team runs every ad, page, post and video through this list before it goes live. Copy it into your own approval process.

1. Scan for risky words: best, top, leading, No. 1, most, premier, guaranteed, 100%, painless, permanent, free, complimentary, discount, promo, offer, package, bundle, "from $".
2. Remove patient voices: quotes, reviews, star ratings, rating widgets, patient videos and reshared comments.
3. Check every image: no before/after, no after-only results shots, nothing that implies a result.
4. Check every claim can be backed as fact, and that no sentence promises an outcome.
5. Check doctor titles against the SMC register: "specialist" only for Specialist Register doctors in that specialty, and registered qualifications only.
6. Check links and embeds: does anything you link to break these rules?
7. Check consent for any SMS, WhatsApp or email list.
8. Check privacy: no identifiable patient, and no case details that could identify one.
9. Record who approved it and when.