HCSA advertising guidelines for clinics in Singapore (Updated)
A complete guide to advertising your medical, dental or aesthetic clinic legally under the Healthcare Services Act — written for clinic owners and the marketers who run their campaigns. Includes free tools to check your ads before you publish.
What is the HCSA — and what happened to the PHMC guidelines?
The Healthcare Services Act 2020 (HCSA) is the law that governs how licensed healthcare services are run and advertised in Singapore. Advertising is regulated specifically by the Healthcare Services (Advertisement) Regulations 2021, which came into force on 3 January 2022.
If you've been searching for the "PHMC guidelines" (the Private Hospitals and Medical Clinics advertising rules), this is the page you want. The HCSA progressively replaced the PHMC Act and its 2019 advertising regulations from 3 January 2022. The PHMC advertising guidelines are no longer the operative framework — you now work to the HCSA and its Advertisement Regulations. The guiding principle is unchanged: healthcare advertising should inform, not solicit. Adverts must give the public accurate information to make sensible decisions — not push, pressure or entice them into consuming a service.
The advertising-content principles carried over largely intact, so most PHMC-era habits still apply. But the legal references, definitions and enforcement now sit under the HCSA. The two pieces of subsidiary law you need are the Healthcare Services (Advertisement) Regulations 2021 and the Healthcare Services (Advertisement — Exemption) Order 2021.
PHMC guidelines vs HCSA advertising regulations
| PHMC guidelines (old) | HCSA advertising regulations (current) | |
|---|---|---|
| Governing law | Private Hospitals and Medical Clinics Act | Healthcare Services Act 2020 (in force 3 Jan 2022) |
| Advertising rules | PHMC (Advertisement) Regulations 2019 | HCS (Advertisement) Regulations 2021 + Exemption Order 2021 |
| What is regulated | Mainly the premises — private hospitals and medical/dental clinics | The service — every licensable healthcare service, wherever it's delivered |
| Scope of services | Hospitals, medical & dental clinics | Adds clinical labs, telemedicine, and many clinical-support, inpatient & outpatient services |
| Channels addressed | Pre-dates much of today's digital landscape | Expressly covers websites, social media, mobile apps, and third-party "authorised persons" (agencies/influencers) |
| Core content rules | No laudatory terms, no before/after, no promotions, restricted testimonials | Substantially the same principles — carried over and updated |
The two laws that govern your ads
- Healthcare Services (Advertisement) Regulations 2021 — what an advert can say (content), where it can appear (media), and the rules for reviews, awards, promotions, hyperlinks and corrections.
- Healthcare Services (Advertisement — Exemption) Order 2021 — the narrow categories of factual material (e.g. directories, directional signs, certain national-scheme publicity) that fall outside the Advertisement Regulations.
These rules apply only to licensable healthcare services. Non-licensable services — such as Traditional Chinese Medicine, physiotherapy or chiropractic — are governed by other laws, primarily the Medicines (Advertisement and Sale) Act (MASA). Notably, section 4 of MASA prohibits advertisements that refer to any skill or service relating to the treatment of an ailment, disease, injury or condition affecting the body. So non-healthcare businesses such as beauty salons, spas and wellness centres must not advertise the treatment of medical conditions at all. If you're unsure which regime applies, ask one question first: is the content about a healthcare service, or about a product? (See the Health products section below.)
Who must comply — and why marketers are on the hook too
Under section 31 of the HCSA, only a licensee or a person acting on the licensee's authority may advertise a licensable healthcare service. That single sentence is the most important thing for an agency or in-house marketer to understand.
Who the rules cover
- Private hospitals, community hospitals and nursing homes
- Medical clinics — GP, specialist and aesthetic
- Dental clinics
- Clinical laboratories and other clinical support services
- Telemedicine and other remote licensable services
A marketing agency, freelancer or staff member engaged by a clinic to advertise is an "authorised person" under the Advertisement Regulations — and can be held personally liable for breaches in the work you publish.
The licensee (the clinic) and the authorised person are generally jointly responsible for compliance, and the licensee's duty to keep its advertising compliant is non-delegable — it cannot be contracted away to you. Anyone who advertises a licensable service while being neither a licensee nor an authorised person commits an offence under section 31(1) of the HCSA.
The "Singapore link" test
The Advertisement Regulations apply to any advert with a Singapore link — that is, an advert that can be accessed by someone physically in Singapore, or that is aimed at people the advertiser knows or believes are in Singapore. In practice, almost any public website, social post or search ad you run for a Singapore clinic is caught.
Where can you advertise?
Regulation 6 limits the media you may use for advertising outside your own premises. Get the channel wrong and the ad is non-compliant no matter how clean the wording is.
Approved media (outside your premises)
Outside your licensed premises or conveyance, an advert may appear only in: newspapers, directories, medical journals, magazines, brochures, leaflets, flyers, pamphlets, and the Internet — which expressly includes websites, mobile application software and social media platforms.
Your Website
Allowed. Compliant testimonials and qualifying awards may also appear here.
✓ AllowedSocial Media
Facebook, Instagram, YouTube, TikTok and similar are allowed media. Content must still comply.
✓ AllowedGoogle Ads & SEO
Search marketing is allowed media. SEO is not "advertising"; paid search (SEM) is.
✓ AllowedNot approved media
TV & Radio
Broadcast media are not on the approved list for advertising.
✗ Not AllowedBillboards / Outdoor
Outdoor billboards and signage are not approved media (a narrow exemption exists for factual directional signs).
✗ Not AllowedPush Messaging
SMS, WhatsApp, Messenger and unsolicited free flyers/mailers — only with prior written consent.
✗ Restricted** "Push technology" (SMS/MMS/WhatsApp/Messenger) and free distribution of advertising material — e.g. dropping leaflets into mailboxes — require the recipient's prior written consent under Regulation 6(4).
Within your licensed premises or conveyance, an advert may appear in any form or medium. You may also affix advertising to your own door, window, wall, fence or partition — even if it is visible from outside. Brochures, leaflets, flyers and pamphlets must always carry a date of publication.
SEO vs SEM — a key distinction for marketers
MOH treats search engine optimisation (SEO) and paid search marketing (SEM) differently. SEO — optimising content to improve organic traffic — is not in itself "advertising," because the process does not push a particular service. But if your SEO surfaces patient reviews and ratings, that content is an advertisement and must comply. SEM (paid search) is advertising in full, because you are paying for visibility, so every paid ad must meet the content rules below.
Quick platform checker
Select where you want to advertise to see the rule that applies.
What can you say in your ads? (Regulation 5)
Even on an approved channel, the content of every advert must satisfy Regulation 5. These are the rules that trip up most clinic campaigns. Tap each to expand.
Everything in an advert must be factually accurate and capable of being substantiated — and must not be exaggerated, false, misleading or deceptive.
- Be ready to back every claim with credible evidence if MOH asks.
- Avoid implied claims you cannot prove (e.g. unrealistic timeframes for results).
You cannot use words that praise, or imply prominence or uniqueness. MOH publishes a non-exhaustive list of laudatory terms — these are banned even if they happen to be true.
An advert must not contain any photo, picture, video or film showing a person's appearance before and after — or only after — a treatment. This holds even with disclaimers, and whether the images sit in one ad or are spread across several.
The only exception: a doctor or staff member may show such images to a patient privately, during that patient's own consultation.
Reg 5(1)(d) · Reg 5(2)An advert must not create an unjustified expectation, or imply results that other providers cannot achieve. Time-bound promises are treated as soliciting consumption.
You may not compare or contrast the quality of your service with another provider's, or disparage another provider — and this applies even when the other provider is not named. If, taken together with information already in the public domain, the wording would be understood as a dig at a known competitor (for example, a reference to not doing "one-second consults" after a competitor was reported for exactly that), it can breach the rules.
Reg 5(1)(c)(iii) & (iv)You cannot advertise the potential to obtain a medical certificate (MC) through your service — including acronyms or terms like "sick leave," "medical leave" or "medical excuse." It implies an MC will be issued regardless of the patient's actual condition, which solicits consumption. Examples MOH flags: "Get MC for as little as $10," "MC in 1 minute!", "Medical consultation from $10."
Similarly, you may not claim teleconsultations are completed within a fixed short time (e.g. "consult done in 60 seconds"), because a proper clinical evaluation can't be promised within an arbitrary window.
Reg 5(1)(a) & (g)An advert must not be offensive, ostentatious or in bad taste, and must not undermine the honour and dignity of any healthcare profession.
Reg 5(1)(b)Educational vs promotional: intent is what matters
A subtle point that separates compliant clinics from the rest: MOH looks at the intent of your content, not just its format. The same blog post, profile page or social clip can be fine or non-compliant depending on whether it informs or solicits.
Content that builds genuine understanding — explaining a condition, its causes, symptoms and the broad options in neutral terms — is generally educational and is not treated as advertising. The moment the content steers a reader toward choosing or buying a specific service, it crosses into regulated advertising and must satisfy every Regulation 5 rule. Two useful illustrations from MOH's guidance:
- SEO is a process, not an advert. Optimising your pages for search isn't "advertising" in itself — but the moment that content carries patient reviews, ratings or soliciting language, it is an advertisement and must comply.
- Educational talks and webinars are generally not advertisements — unless they contain information that seeks to solicit use of your service (for example, slipping in before/after images or a promotional offer), in which case the rules apply.
Let public-facing content build understanding and help patients know what questions to ask — and leave specific treatment recommendations to the consultation room. If a page would only make sense as a pitch to book a particular service, treat it as a regulated advertisement and review it accordingly.
Advertising prices the right way
You can show prices — many clinics do — but the moment a price looks like a deal, it becomes prohibited solicitation. Here's the line.
You CAN
- List the exact, final price of a service
- State the full total without any prefix or label
- Tell patients about payment plans or packages at the point of payment only
You CANNOT
- Use prefixes like "from", "as low as" or "lowest price"
- Show a usual price crossed out next to a lower price
- State an instalment amount without the total price
- Attach a "validity period" or time-limited price
Membership packages, referral incentives and instalment plans are not illegal — but advertising them is. Patients may only be told about them at the point of payment.
Reviews, testimonials & awards
Two of the most misunderstood areas for clinics. The rules are narrow but workable if you respect them.
Reviews, testimonials & endorsements (Regulation 14)
As a default, you may not display, publish or disseminate reviews, testimonials or endorsements about your service. There is a limited exception: you may show them within your premises, on your own website, or on your own social media account — but only if the review was given directly to you by the patient and is not reproduced by you or your marketer.
- Allowed: a genuine, organic review the patient gave you directly, unpaid and unedited (you may remove expletives, but not change the substance).
- Not allowed: paid or incentivised reviews; soliciting reviews; editing them; and re-sharing or screenshotting a patient's or influencer's social post onto your channels (that counts as reproduction).
- Outside your control: a patient's own unsolicited review on a third-party blog or platform is not your advertisement — but you must not have initiated, paid for or influenced it.
Paying an influencer to post a positive experience is a paid review and is prohibited — disclosing the sponsorship does not make it compliant. Reproducing a celebrity or influencer patient's post on your page is also not allowed.
You'll see other guides state flatly that patient testimonials are banned in Singapore. That overstates it. Under Regulation 14, a genuine, direct, unpaid, unedited and un-reproduced testimonial is permitted on your own premises, website or social media.
However, doctors are separately bound by the Singapore Medical Council's Ethical Code and Ethical Guidelines (ECEG), which state that testimonials are subjective and must not be used in advertising on any media over which the doctor has control of the content — and that doctors must not ask or induce anyone to write positive testimonials. In practice, that means medical practitioners should treat testimonials with great caution even where Regulation 14 might technically allow them. When in doubt, leave them out.
Accreditations, certifications & awards (Regulation 13)
By default you may not publicise an award, accreditation or honour given to your service. The exception mirrors testimonials: you may display it within your premises, on your website, or on your social media — and only if the honour was given for meeting genuine technical standards in your service. You cannot put such honours in newspaper ads or external brochures.
- This does not cover individual professional qualifications of your registered doctors/dentists — those are stated separately and are not "honours."
- If a third party independently publishes a list of awarded clinics without your involvement, you are not liable; but a non-licensee that publishes such promotional listings may itself breach section 31.
Promotions, referrals, gifts & partnerships
Regulation 15 bans the advertising of promotional programmes that dangle a gift or benefit to encourage consumption. A few narrow carve-outs exist.
- Prohibited to advertise: programmes where a gift, freebie, lucky draw, voucher or other benefit is obtained based on the value or type of service purchased — anything designed to solicit consumption.
- Referral rewards: you may run a friends-and-family referral scheme with incentives, but you cannot advertise it. Patients may be told only at the point of payment. If a patient screenshots and shares it, you must take reasonable steps to have it removed once you are aware.
- Allowed carve-outs: a payment-plan programme (disclosed only at point of payment); a genuine corporate social responsibility programme (clearly labelled as CSR, with no direct financial benefit and not used to recruit patients); and certain charitable-provider programmes.
- Partnerships & co-branding: an advert run jointly with another business (e.g. selling face creams, an insurer, or a financial institution) is still fully subject to Regulation 5. In particular, discounts offered through such partners must not be mentioned in the advertising.
- Co-location: if you share space with a non-licensable service, clearly distinguish and label what is, and isn't, a licensable healthcare service (e.g. separate sections, colours or pages).
Healthcare services vs health products
The HCSA Advertisement Regulations govern advertising of the licensable service. Advertising a product — a medicine or medical device — is a separate regime enforced by the Health Sciences Authority (HSA).
MOH's own decision tree is simple: ask whether the content relates to a healthcare service or a product. If it's a service, the HCSA and these Advertisement Regulations apply. If it's a product, you look to product-related law — chiefly the Health Products Act, the Medicines Act, and the Medicines (Advertisement and Sale) Act. Your healthcare-service advert must also comply with these product-advertising laws wherever it touches on products.
Under HSA's product-advertising rules, certain products generally cannot be advertised to the public — for example prescription-only medicines (POMs), professional-use-only medical devices, and cell, tissue or gene therapy products. When in doubt, describe the treatment category rather than naming a specific product, and check HSA's guidance directly.
Two regulators, two sets of rules
This is the trap that catches aesthetic and cosmetic clinics: an advert can be perfectly fine under MOH's service rules and still breach HSA's product rules. MOH (via the HCSA Advertisement Regulations) governs how you advertise the service; HSA (via the Health Products Act and related laws) governs how you advertise the product. Clearing one does not clear the other.
Common aesthetic injectables are a good example. Botulinum toxin and dermal fillers are HSA-regulated health products that must be registered before supply and administered only by qualified practitioners — and as prescription-only products, they generally cannot be advertised to the public at all. Naming them, listing their prices, or showing treatment images in public-facing ads is high-risk. Separately, advertising or running a sales promotion for certain health products to the general public requires a valid HSA advertising permit (typically valid for one year), with the permit number shown in the material.
Practical approach
- Safer: describe the procedure or treatment type (e.g. "wrinkle-reduction injectable treatment").
- Riskier: naming a specific branded prescription medicine or professional-use device to the general public.
For product-advertising specifics, refer to HSA. This page covers the HCSA service-advertising rules only.
Restricted terms in your clinic's name & branding
A branding decision that quietly breaches the rules: using a medical specialty in your business name without actually employing the relevant accredited specialist.
MOH maintains a (non-exhaustive) list of restricted terms that a licensee cannot use in its business name — either alone or as part of a longer word — unless it engages or employs the relevant specialist accredited under the Specialists Accreditation Board (SAB) or Dental Specialists Accreditation Board (DSAB). This matters for clinic naming, domains, signage and ad copy.
The full list is longer and updated periodically — see the official "List of restricted terms" linked in the sources below.
What's exempt from the Advertisement Regulations
A small set of factual material falls outside the rules under the Exemption Order 2021. Even then, it must be factually accurate and not misleading.
- Pure directory listings — contact details only, listing all licensees in alphabetical/sequential order with no licensee given greater prominence.
- Directional signs — fixed signs containing only contact information, factual service information, and a healthcare professional's name, qualifications and title.
- Blood & organ donation — factual publicity for non-directed blood, bone-marrow and organ donation, or donation for medical/dental education or research.
- Government / HPB schemes — factual publicity for national programmes such as health screening and vaccination initiatives funded, initiated or endorsed by the Government or Health Promotion Board (e.g. CHAS, Screen for Life, national vaccination programmes).
Compliance, corrections & penalties
Regulation 17 puts the onus on the licensee to fix non-compliant advertising fast — and to make sure its marketers do the same.
Your duty to correct (Regulation 17)
- If you become aware of a non-compliant advert for your service, you must take all reasonable steps to rectify or withdraw it and prevent recurrence — regardless of how you found out.
- Where your authorised person (e.g. your agency) published it, you must inform them, ensure they fix it, and verify they did. The duty is non-delegable.
- If an authorised person fails to act after being told, the authorised person commits the offence — not you.
- The same correction logic applies to non-compliant hyperlinks from your website (Regulation 16): remove them once you're aware.
Penalties
Content (Reg 5) and media (Reg 6) breaches are punishable under section 31(3) of the HCSA. Breaches of other provisions — interviews, filming, awards, testimonials, hyperlinks and the duty to correct — carry a fine of up to $20,000, up to 12 months' imprisonment, or both, plus a continuing-offence fine. Advertising without being a licensee or authorised person is itself an offence under section 31(1). Separately, persistent non-compliance can expose a licensee to regulatory action under the broader HCSA.
You can report it to MOH at HCSA_Enquiries@moh.gov.sg with the advertisement's details.
Free compliance tools
Check your advertisements against the HCSA content rules before you publish.
Ad copy checker
Scan your advertisement text for prohibited and restricted terms before publishing.
Our free tool scans your ad copy against the HCSA Advertisement Regulations and flags laudatory, comparative, promotional and other prohibited language. You get instant feedback and shareable results you can send to your team or clients.
Open the Ad Copy CheckerQuick reference: do's and don'ts
You CAN
- Factually describe the services you offer
- State your doctors' registered qualifications and titles
- List exact, final prices (no prefixes or comparisons)
- Run SEO and compliant Google/social ads
- Show genuine, direct, unedited reviews on your own channels
You CANNOT
- Use laudatory/superlative terms ("best", "leading", "latest")
- Show before/after photos in ads
- Advertise discounts, packages, freebies or promos
- Guarantee results or promise fixed timeframes
- Pay for reviews or re-share patient/influencer posts
Frequently asked questions
Service-specific regulatory requirements
Beyond advertising, each licensable service has its own regulations (clinical, operational and otherwise). If you run or market for a specific service, check its dedicated MOH page below.
- Acute Hospital Service
- Ambulatory Surgical Centre Service
- Assisted Reproduction Service
- Blood Banking Service
- Clinical Laboratory Service
- Community Hospital Service
- Cord Blood Banking Service
- Emergency Ambulance Service
- Medical Transport Service
- Human Tissue Banking Service
- Nuclear Medicine Service
- Nursing Home Service
- Outpatient Dental Service
- Outpatient Medical Service
- Outpatient Renal Dialysis Service
- Radiological Service