In this guide · 8 sections
- 01Do the HCSA advertising rules apply to clinic websites?
- 02What your clinic website must not contain
- 03Patient reviews, endorsements and star ratings
- 04Awards, promotions, links and push messages
- 05What a compliant clinic website should include
- 06Online booking and patient data (PDPA)
- 07Do it yourself or get help?
- 08Frequently asked questions
Short answer
Show factual, verifiable information only. No superlatives ('best', 'leading'), before-and-after photos, comparisons with other clinics or gifts tied to treatments. Patient reviews may appear on your own site or social account only if given directly to you, unpaid and unedited.
Do the HCSA advertising rules apply to clinic websites?
Yes. The Healthcare Services (Advertisement) Regulations 2021 took effect on 3 January 2022 and were amended in June 2023. They apply to advertisements by HCSA licensees, such as medical and dental clinics, and by people acting on their authority, such as marketing agencies, in any form or medium, if the advertisement is accessible by someone in Singapore.
'Advertise' is defined broadly: publishing any information related to a licensable healthcare service to promote it, directly or indirectly. Your website, Facebook and Instagram pages, Google Business Profile posts and paid ads all fall within that.
MOH's answer on approved media confirms that the internet, including websites, social media platforms and mobile apps, is one of the permitted channels, and that licensees and their agencies are jointly responsible for compliance.
What your clinic website must not contain
Regulation 5 sets the content rules. Every advertisement must be factually accurate, capable of being substantiated, and not exaggerated, false, misleading or deceptive. It also must not:
| Not allowed | Typical website example | Regulation |
|---|---|---|
| Laudatory statements or superlatives | 'Singapore's best dental clinic', 'leading aesthetic doctor', 'No. 1' | 5(1)(e) |
| Before-and-after or after-only treatment photos | Gallery of patient results, even if realistic | 5(1)(d) |
| Unjustified expectations or unique results | 'Guaranteed results', 'pain-free in one session' | 5(1)(c) |
| Comparisons with or criticism of other clinics | 'Cheaper and better than other clinics' | 5(1)(c) |
| Soliciting or encouraging use | Pushy calls to book treatments you do not need | 5(1)(g) |
| Offensive, ostentatious or undignified content | Gimmicky claims that undermine the profession | 5(1)(b) |
Before-and-after photos can still be shown to a patient during a consultation (regulation 5(2)); they just cannot be used to advertise.
Patient reviews, endorsements and star ratings
Regulation 14 is the one most clinic websites get wrong. The general rule is that patient reviews and endorsements must not be displayed or published. There is a narrow exception for your premises, your own website and your own social media accounts, if the review:
- was given by a patient, or their next of kin or carer, about their own experience;
- was given directly to the clinic and is not reproduced by the clinic or its agency;
- was not given in return for money, a discount or any other benefit; and
- was not substantively modified before publication.
In practice, that rules out a homepage carousel of hand-picked quotes copied from Google, review widgets that pull in third-party reviews, and 'leave a review for a discount' campaigns. A 'review' includes ratings such as stars. The exception does not apply at all to assisted reproduction services.
Awards, promotions, links and push messages
Accreditations and awards (regulation 13)
You may show an accreditation or certification on your premises, website or social accounts only if it was given because you met technical standards for the service, and only alongside that service. Popularity awards and 'best clinic' prizes from magazines do not qualify. Doctors' professional qualifications are treated separately and are not 'honours'.
Promotional programmes (regulation 15)
Do not advertise gifts or benefits that depend on the value or type of treatment bought, such as 'free facial with every package'. Payment plans may be mentioned only when payment is being sought from the patient.
Hyperlinks (regulation 16)
Your website must not link to other sites that break the content rules, such as a magazine article calling you the best clinic or a page of before-and-after photos. If you find such a link, remove it immediately.
SMS, WhatsApp and email marketing (regulation 6)
You must not send advertisements by push technology, such as SMS, WhatsApp or app notifications, or hand out free promotional material, without the person's prior written consent. This sits on top of PDPA and Do Not Call rules.
What a compliant clinic website should include
The regulations are restrictive, but a clear, factual website is still a strong marketing tool. Patients mostly want to know what you treat, who will see them, what it costs and how to book.
Clinic website content checklist
Google Business Profile is useful for clinics too: patients review you there directly, and you can respond. Just do not copy those reviews onto your website. Our Google Business Profile guide covers set-up.
Online booking and patient data (PDPA)
A booking form is where a clinic website collects personal data, sometimes health information. Keep it minimal and secure.
Collect only what you need to book
Name, contact number, preferred time and reason for visit at most. Leave detailed medical history for the consultation.
Avoid collecting full NRIC numbers online
PDPC guidance restricts NRIC collection to cases required by law or to verify identity to a high degree. Our NRIC rules guide explains when it is allowed.
Use a booking system with access controls and MFA
Booking data should not sit in a shared inbox. Our clinic and salon booking guide compares options.
Publish a clear privacy policy
Explain purposes, retention and who to contact. See our privacy policy and cookie consent guide.
Get written consent for reminders and marketing
Promotions sent by SMS, WhatsApp or app notification need prior written consent under the advertising rules. Ask for consent to reminders and updates at the booking step too.
Do it yourself or get help?
Auditing an existing site against the checklist above takes an hour or two. Fixing it may mean rewriting service pages without superlatives, removing galleries and widgets, and checking every link.
Business Website (S$1,490) builds a clean, fast site of up to six pages with factual service pages and a contact form, written to avoid superlatives and results photos. Online Booking System (S$390) sets up booking with deposits, reminders and calendar sync in your own account. You remain responsible for the final content as the licensee.
Frequently asked questions
No. The Healthcare Services (Advertisement) Regulations 2021 prohibit advertisements containing photographs, pictures or videos showing an individual before and after, or only after, receiving treatment, whether or not they create unjustified expectations. Clinics may still show such photos to a patient during a consultation.
Only in narrow cases. A review may appear on the clinic's own website or social media account if a patient, next of kin or carer gave it directly to the clinic, it was not paid for or rewarded, and it was not substantively edited or reproduced. Copying Google reviews into a website slider does not meet this test.
No. Advertisements must not contain laudatory statements, including statements of prominence or uniqueness, or superlatives to describe the clinic's services. Words such as best, leading, top or number one should be removed from websites, social posts and ads, along with claims that imply results other clinics cannot achieve.
Only with the person's prior written consent. The regulations prohibit sending healthcare advertisements through push technology, such as SMS, WhatsApp or app notifications, without it. PDPA consent and Do Not Call rules also apply, so record consent at the point of booking and keep it on file.
It depends on the regulation breached. For example, breaching the rules on reviews, accreditations or hyperlinks can lead to a fine of up to S$20,000, imprisonment of up to 12 months, or both, with further daily fines for continuing offences. Content breaches are offences under section 31 of the Healthcare Services Act.