In this guide · 8 sections
- 01Which rules apply to aesthetic clinic advertising
- 02Before-and-after photos: what the rules actually say
- 03Prices, packages and promotions
- 04Influencers, reviews and paid social ads
- 05Doctor titles and what you can say about procedures
- 06Patient photos, consent and PDPA
- 07Do it yourself or get help?
- 08Frequently asked questions
Short answer
An aesthetic clinic may describe procedures, risks, fees and doctors' registered qualifications factually. It may not show before-and-after or after-only photos, run discounts or time-limited offers, use influencer endorsements, or give doctors titles like "aesthetic physician".
Which rules apply to aesthetic clinic advertising
Three texts set the limits. All three are written for the clinic and its doctors, but agencies and anyone posting on the clinic's behalf are caught too.
| Rule | Applies to | Relevant parts |
|---|---|---|
| Healthcare Services (Advertisement) Regulations 2021 | Licensed clinic and any authorised person, such as an agency | Regulation 5 (content), 6 (media and push messages), 14 (reviews and endorsements), 15 (promotional programmes) |
| SMC Ethical Code and Ethical Guidelines (2016 edition) | Every registered doctor | Section G (advertising) and B10 (aesthetic practice) |
| SMC Guidelines on Aesthetic Practices for Doctors (2016 edition) | Doctors performing aesthetic procedures | Titles and designations, misleading images, approved procedures |
The regulations define an advertisement as information published in any form or medium to promote a licensable healthcare service. That covers your website, social accounts, Google and Meta ads, and posts made for you by others.
Before-and-after photos: what the rules actually say
Regulation 5(1)(d) says an advertisement must not contain any photograph, picture, video or film showing the appearance or a feature of any individual before and after, or only after, receiving any treatment. It adds that this applies whether or not the image creates an unjustified expectation, and whether the images sit in one advertisement or are spread across several.
The SMC code, section G2, says the same for doctors: no "before" and "after", or even only "after", images in medical advertising in the public domain, because anecdotal cases create unjustified expectations of results, which may vary.
- Banned: results galleries, split-screen reels, "after" selfies of patients, carousel posts of a treatment journey, and the same content in paid ads.
- Splitting does not help: posting the before in one post and the after in another is expressly covered.
- Allowed: showing before-and-after images to a patient during a consultation (regulation 5(2)).
- Careful with stock images: a flawless model next to a procedure name can imply a result. Neutral images of the clinic, equipment or diagrams are safer.
Prices, packages and promotions
Publishing fees is fine; fees are factual and help patients. Promoting them is where aesthetic marketing goes wrong.
Generally acceptable
- A fee list with what each fee includes
- Fee ranges with the factors that change the price
- Stating that a consultation fee applies and how much
- Payment plans, mentioned only when payment is being sought from the patient
Not allowed
- Discounted or free treatments to attract patients (SMC G2)
- Time-limited offers such as this month only or first 50 patients (SMC G2)
- Credit card or brand tie-ups to win patients (SMC G2)
- Free gifts based on the value or type of treatment bought (HCSA reg 15)
- Treatments offered as prizes or in giveaways (SMC G2)
Regulation 15 bans advertising any programme in which a patient gets a gift or benefit based on the value or type of treatment bought, where the aim is to encourage use of the service. Package deals marketed as "buy 5 sessions, get 1 free" fit that description.
Doctor titles and what you can say about procedures
SMC's Guidelines on Aesthetic Practices say aesthetic practice is not a specialty or subspecialty, so titles such as aesthetic plastic surgeon, aesthetic dermatologist or aesthetic physician, or similar titles, are not allowed. A dermatologist or plastic surgeon should use only that title; a GP who performs aesthetic procedures should use GP or family physician.
SMC ethical code section B10 adds that doctors must not mislead the public into thinking they are specialists in aesthetic medicine, must not exploit patients' insecurities about self-esteem and body image, and must give objective information about procedures and reasonably expected outcomes.
Procedure page checklist
Patient photos, consent and PDPA
Clinical photos are personal data, and often sensitive. Even when you are not advertising with them, the PDPA governs how you collect, store and share them.
Take consent for clinical photos separately
Explain on the consent form that photos are for the medical record. Do not bundle consent for marketing into it.
Never use results photos to advertise
Patient consent does not override regulation 5(1)(d). Consent lets you show photos in a consultation, not on Instagram.
Store photos in the clinic system, not on phones
Use your clinic management system or a secured cloud folder with access controls and MFA. Remove photos from staff phones and chat apps.
Limit who can see them
Give access only to staff involved in the patient's care, and keep an access log where your system allows.
Publish a privacy notice
Cover photos, enquiries, booking and marketing consent. Our privacy policy and cookie consent guide explains what to include.
AI-generated faces are no workaround. A generated "result" image presents an outcome that never happened, which risks breaching the rule that advertising must be factually accurate and not misleading (regulation 5(1)(a)), on top of the before-and-after ban. Our guide to AI image generators for commercial use covers the wider rules.
Do it yourself or get help?
Start with an audit: every page, every social post from the past year, every running ad. Search for words like best, guaranteed, results, free, promo and limited, and check every image. Our general clinic website rules guide has a fuller checklist.
Our Business Website package (S$1,490, paid upfront) builds a fast site with factual procedure and fee pages and no results galleries or review widgets. Speed & SEO Fix (S$390) helps factual pages rank, and the PDPA Compliance Pack (S$690) covers consent forms and the privacy notice. The doctors remain responsible for final content.
Frequently asked questions
No. The Healthcare Services (Advertisement) Regulations 2021 ban any photo, picture or video showing a person before and after, or only after, treatment in an advertisement, and a clinic's Instagram is advertising. It does not matter whether the image is realistic or split across posts. Clinics may show such photos to a patient during a consultation.
Doctors must not offer discounted or free treatments, time-limited offers, credit card tie-ups or gifts to attract patients under the SMC ethical code. The HCSA regulations also ban advertising gifts or benefits based on the value or type of treatment bought. Publishing a factual fee list is allowed.
It is very risky. Regulation 14 bans publishing endorsements by any person about the clinic's services, and the only exception is an unpaid, unedited review a patient gives directly to the clinic. A paid creator acting for the clinic is an authorised person who can also be prosecuted, with fines of up to S$20,000.
No. SMC's Guidelines on Aesthetic Practices for Doctors say aesthetic practice is not a specialty or subspecialty, so titles such as aesthetic physician, aesthetic dermatologist or aesthetic plastic surgeon are not allowed. Doctors should use only their registered designation, such as dermatologist, plastic surgeon or general practitioner.
Yes. Photos of patients are personal data under the PDPA, so you need consent for the purpose you collect them for, and must protect and limit access to them. Consent for clinical records does not allow marketing use, and even with consent, results photos cannot be used in advertising under the HCSA regulations.