If you advertise a licensable healthcare service in Singapore, seven categories of content are either banned outright or tightly restricted under the Healthcare Services (Advertisement) Regulations 2021 (HCSAR). Breaching them carries a fine of up to S$20,000, up to 12 months' imprisonment, and up to S$1,000 per day for a continuing offence. This is a plain-language summary, not legal advice. Confirm your own advertising with your licensing officer or counsel before it runs.
1. Before-and-after imagery
Prohibited in any advertisement. The only place it's permitted is inside the clinic itself, during a clinical consultation, where it's shown to a specific patient rather than published to the public. There's no compliant version of a before/after social post or ad creative.
2. Reviews, testimonials, and endorsements
Prohibited in advertising, with limited exceptions under Regulation 14. This extends further than most clinics expect: screenshotting a Google review and posting it counts as a prohibited testimonial, even though you didn't write it yourself.
3. Superlatives
Words like "best", "leading", "most advanced", and "number one" are prohibited, including when they appear as a visual banner or badge rather than in body copy. A graphic that says "#1 clinic" breaches the same rule as the sentence would.
4. Discounts and price promotions
Price promotions and discounts that could induce unnecessary consumption of a healthcare service aren't allowed. The test isn't whether the discount is real. It's whether it could push someone toward a treatment they wouldn't otherwise seek.
5. Institutional awards in general advertising
Institutional awards can't be promoted in general public advertising. They can appear on the clinic's own website, the clinic's own social accounts, and within the premises. Individual practitioner credentials are treated differently and are exempt from this restriction, which is why a named doctor's registered qualifications can appear where a clinic-wide award can't.
6. Influencer promotion without a licence
A non-medical person, including an influencer, can't advertise a licensable healthcare service without an HCSA licence. No benefits in kind are permitted in exchange for promotion, and any content that does run has to be pre-approved by the licensee, not the influencer.
7. Paid search treated as advertising
Search engine marketing is treated as advertising under the regulations, not as a separate, lower-scrutiny channel. A search ad carries the same restrictions as a display ad or a social post. If your search campaigns still use a superlative in the headline or a before/after extension, that's the same breach as running it on a billboard.
The layer most clinics forget
Clearing MOH's advertising rules doesn't clear the product layer. The Health Sciences Authority (HSA) has separate rules under the Health Products Act, and prescription-only medicines and professional-use-only devices generally can't be advertised to the public regardless of what MOH has approved on the advertising side. If your clinic advertises around specific devices or prescription treatments, check the HSA layer separately. Passing MOH review is not the same as passing HSA review.
Who's actually liable
The clinic, as the licensee, is legally responsible for advertising content under HCSA. That responsibility doesn't transfer to an agency, a freelancer, or an influencer you worked with. If you outsource your marketing, you still carry the liability for what gets published under your name.
What a compliant approach actually looks like
Strip out superlatives, before/after material, testimonials, and induced-discount language, and what's left is still a real marketing asset: factual condition and procedure pages, neutral practitioner credentials, educational content, transparent non-comparative pricing, and structured content that helps patients (and AI assistants) find the right specialist. That's a narrower brief than most agencies are used to writing to, but it's the entire brief that's actually legal here.
If you want a second read on your current campaigns against these seven points, get in touch and tell us what's running.