Healthcare Advertising Rules in Singapore (HCSA): 2026 Guide

Part of our Marketing Law & Compliance guide →

Updated November 2026 Singapore clinics advertise under the Healthcare Services Act 2020 (HCSA) and its Healthcare Services (Advertisement) Regulations 2021. Together they replaced the old Private Hospitals and Medical Clinics Act (PHMCA) regime. Many guides still quote the 2019 PHMC rules. The principles carried over, but the regulation numbers, the scope and MOH’s interpretations have moved on. MOH’s FAQs were last updated in November 2024 to cover medical certificates, unnamed comparisons and teleconsultation timing.

This guide covers what the rules mean in practice for a clinic’s website, Google Ads, social media and SEO. It includes MOH’s full list of banned laudatory terms, set against how often Singapore patients actually search with those words. We work on this daily as an agency. Under the Regulations, an agency running a clinic’s ads is an “authorised person” and is itself liable if it doesn’t comply.

This is a practitioner’s guide, not legal advice. For a specific campaign, check the Regulations, MOH’s FAQs (linked at the end) and your own legal adviser.

Who the rules apply to

The HCS (Advertisement) Regulations apply to advertisements of licensable healthcare services: the services listed in the First Schedule of the HCSA, such as medical and dental clinics, hospitals, clinical laboratories and other licensed services. Three scope points catch people out:

• Only licensees, or people they authorise, may advertise a licensable service. Under section 31 of the HCSA, an agency, influencer or telemedicine platform advertising a clinic’s services must be authorised by the licensee. Advertising without that authority is an offence carrying a fine of up to S$20,000, up to 12 months’ imprisonment, or both. The authorised person is also liable if it fails to correct a non-compliant ad after the clinic tells it to.
• Non-licensable services aren’t covered by these Regulations, but they aren’t unregulated. MOH’s FAQ names traditional Chinese medicine, physiotherapy and chiropractic as examples. Their ads fall under other legislation, notably the Medicines (Advertisement and Sale) Act. In practice, section 3 of that Act still bars advertising any product as a medicine, appliance or remedy for 19 listed conditions, including cancer, diabetes, hypertension, infertility and sexual function. (MOH’s FAQ also cites section 4, a broader ban on advertising treatment services, but section 4 was repealed on 26 June 2023.)
• Spas and beauty salons can’t advertise medical procedures. MOH is explicit that a spa channelling customers to a clinic in the same group would breach section 31 and the Medicines (Advertisement and Sale) Act, unless it is an authorised person and the ad complies with the Regulations.

Where clinics may advertise

Outside their own premises, licensees may only advertise in newspapers, directories, medical journals, magazines, brochures, leaflets, pamphlets and the Internet. The Internet includes websites, mobile apps and social media. Inside the premises, any medium is allowed. Two practical consequences:

• Push messaging needs prior written consent. Flyers in letterboxes and unsolicited SMS, MMS, WhatsApp or Facebook Messenger broadcasts are prohibited without the recipient’s prior written consent.
• SEO and SEM are not push technology. MOH confirms search engine optimisation and search engine marketing aren’t push messaging. The content they lead to still has to comply.

The content rules, in plain English

Regulation 5 sets out what an advertisement may contain. In practice it comes down to eight tests.

1. Factually accurate and capable of being substantiated. Every claim needs evidence you could hand to MOH. MOH’s guidance points to credible, authoritative sources such as peer-reviewed literature.
2. Not offensive, ostentatious or in bad taste, and not undermining the dignity of the profession.
3. No unjustified expectations. MOH’s own examples: “instant / immediate teeth whitening”, “straight teeth in 2 weeks”, “see results after 1 treatment session”. A result within a fixed time or number of sessions is a red flag.
4. No comparisons with other licensees, even unnamed ones. The November 2024 FAQ gives the example of a clinic advertising that it doesn’t do “one-second consults” after news reports named a competitor that did. That can count as a comparison.
5. No before-and-after (or “after”-only) photos or videos, even with a disclaimer. They can only be shown to a patient during a consultation on your premises.
6. No laudatory statements or superlatives, even when true. The full list is below.
7. No testimonials or endorsements in advertising. The rules on reviews are covered further down.
8. No soliciting or encouraging use of the service, which in practice means no promotions. See the price wording section.

MOH’s list of laudatory terms

Annex A of MOH’s FAQ sets out a non-exhaustive list of terms likely to be regarded as laudatory. MOH is clear that laudatory statements are prohibited “regardless of whether they are factually accurate or not”.

Watch the less obvious entries. “Precise”, “improved”, “extensive experience”, “well-established” and “whiter” all appear on the list, and all turn up regularly in clinic copy.

Patients search with the words you can’t use

From our Singapore Medical CPC Index, built from Google Ads API data each month: here’s how often patients search with laudatory and price modifiers, and what advertisers bid for those clicks.

Clinics can’t answer these searches in their own words. You may bid on “best dentist singapore” because searchers never see your keyword list. But an ad, sitelink or landing page that says “best” is a breach. That leaves two compliant routes:

• Neutral ads on laudatory keywords. Bid on the term, show a factual ad (services, qualifications, location, exact price), and turn off dynamic keyword insertion so Google can’t write “Best” into your headline.
• Organic rankings. MOH’s FAQ says “SEO is not considered as ‘advertising’ as the process itself does not seek to encourage the consumption of a healthcare service”, while SEM “is governed by the HCS (Advertisement) Regulations, as SEM involves paid advertising”. Your web pages must still comply. But Google can rank a factual page for “best gynae singapore” on relevance, authority and independent reviews, without the page ever claiming to be the best.

Price wording: what you can and can’t say

You can publish prices. You can’t promote them. MOH’s FAQ allows only the exact and final price of a service, with no prefix or description and no comparison with another price. The following count as soliciting:

• “Usual” vs “now” prices, crossed-out prices, or any comparative price listing
• “As low as”, “from $X”, “lowest prices”, or an instalment amount without the total price
• Prices with a validity period (“until 31 December”)
• “Discount”, “promotion”, “offer”, “preferential rate”, “interest free”, “complimentary”, “free”
• Group-buy deals, giveaways, lucky draws and freebies
• “Package” in connection with a price discount

Promotional packages and referral incentives aren’t banned as business practices. MOH says patients may be told about them only at the point of payment, at the counter or on the payment page. Advertising them is the breach. MOH even treats a patient’s screenshot of a referral programme posted on social media as material the clinic must get removed.

Reviews, testimonials and influencers

Reviews are allowed when they are organically provided by patients; unpaid, unsolicited and not modified (removing expletives is fine); and not reproduced by the clinic. In practice:

• A patient can post a review on your Google Business Profile, website or social page. You can’t copy it into an ad, a banner or a “What patients say” carousel built from screenshots.
• Paid reviews aren’t allowed, even with the sponsorship disclosed. Offering anything of value for a review breaches the rules.
• Influencers advertising a clinic are authorised persons. Their posts must comply in full, which usually rules out the before-and-after, “my experience” format influencers rely on.

Newer MOH positions (November 2024)

• Medical certificates. Ads can’t mention or reference MCs, including “sick leave”, “medical leave” or MC imagery, if this could be read as advertising the chance of getting an MC. MOH’s examples: “Get MC for as little as $10”, “Get sick leave MC from the comfort of your couch”, “MC in 1 minute!”, “Medical Consultation from $10”.
• Teleconsultation timing. Ads can’t claim or imply that a teleconsult is completed within a set time if that would be inaccurate or misleading.
• Unnamed comparisons. Covered above. Not naming the competitor doesn’t make a comparison compliant.
• Health products. Clinic ads must also comply with the laws on health product advertising. MOH notes that advertising prescription-only medicines to the general public is prohibited under the Health Products Act.

Google Ads for clinics: a compliance checklist

Google’s own healthcare and medicines policy applies on top of MOH’s rules. In Singapore, Google restricts the promotion of prescription drugs: keywords and ads that reference prescription drugs get flagged under Google’s healthcare and medicines policy and typically need a manual review by Google before they serve. In our data, Keyword Planner shows “botox singapore” at 1,000 monthly searches with no bid estimate. Google opened Singapore to LegitScript-certified telemedicine providers in 2025, but the ads still can’t promote the drugs themselves. Before any clinic campaign goes live, check:

1. Dynamic keyword insertion is off in ad groups that contain laudatory or price-modifier keywords.
2. Headlines, descriptions, sitelinks, callouts and structured snippets use no Annex A terms. Callouts are where “Free Consultation” and “Best Price” usually slip in.
3. Price assets show exact prices only: no “from”, no “starting at”, no crossed-out prices.
4. Image assets contain no before-and-after or results photography.
5. No review extensions and no testimonials quoted in ads or landing-page hero sections.
6. Landing pages pass the same eight content tests. MOH treats your website as advertising.
7. No prescription drug names in ads, keywords used in ad text, or landing pages built to promote the drug.
8. The agency managing the account is documented as the clinic’s authorised person.

This is the process we used in our dental group Google Ads rebuild, where compliant creative ended a cycle of ad disapprovals and the cost per booked appointment fell 47%.

SEO for clinics within the rules

Organic search is where clinics have the most room, as long as the content stays factual:

• Write treatment pages as patient education. Cover what the procedure involves, who it suits, risks, recovery and cost factors. Educational content is the safe default, and it’s also what Google’s YMYL quality standards reward.
• Doctor profiles carry the E-E-A-T. List registered qualifications, specialist accreditation and titles exactly as registered. Keep laudatory adjectives out.
• Your Google Business Profile does the review work. Patients’ own reviews on Google aren’t reproduced by you, so they can build trust without breaching the testimonial rules. Just don’t incentivise them.
• Watch your outbound links. A licensee mustn’t link to a website it knows contains non-compliant content about its services, and must remove the link once it becomes aware. Review sites and “best clinics” listicles are the usual problem.

Our medical SEO service is built around these constraints. See the Harley Street Heart & Vascular Centre case study for how it plays out on commercial keywords like “cardiologist singapore”.

Frequently asked questions

Is PHMCA still the law for clinic advertising in Singapore?

No. The Private Hospitals and Medical Clinics Act and its 2019 Advertisement Regulations have been replaced by the Healthcare Services Act 2020 and the Healthcare Services (Advertisement) Regulations 2021. Many PHMC-era principles carried over, including the bans on laudatory claims, before-and-after photos, testimonials and promotions. Cite the HCSA regime today.

Can a clinic say “best” or “leading” if it’s true?

No. MOH’s FAQ states that laudatory statements are prohibited regardless of whether they are factually accurate. That includes “top [specialty] doctor”, “number 1”, “state-of-the-art”, “most experienced” and the rest of Annex A.

Can we show prices on our website and in Google Ads?

Yes, as exact and final prices with no prefix, description or comparison. “Invisalign: $X” is fine. “Invisalign from $X”, “was $Y, now $X” and “interest-free instalments” are not.

Can we run a referral programme?

Yes, but you can’t advertise it. Patients may be told about referral incentives only at the point of payment. Flyers, social posts or web pages promoting the programme breach the Regulations.

Do the rules apply to TCM, physiotherapy and aesthetic spas?

The HCS (Advertisement) Regulations cover licensable healthcare services only. TCM, physiotherapy and chiropractic fall outside them, but their ads are subject to other law, including the Medicines (Advertisement and Sale) Act. Spas can’t advertise medical procedures at all. Aesthetic treatments performed by doctors in licensed clinics are fully covered.

Is our marketing agency liable too?

Yes. An agency advertising for a licensee is an authorised person. It can be held liable for non-compliant ads, and for failing to correct one after the clinic asks. Advertising a licensable service without authorisation is itself an offence under section 31 of the HCSA.

Sources

• Ministry of Health, Healthcare Services (Advertisement) Regulations 2021 FAQs (updated November 2024)
• Ministry of Health, MOH Circular 87/2024 on telemedicine services and advertisements
• Ministry of Health, Explanatory Guidance to the PHMC (Advertisement) Regulations 2019 (superseded; for historical context)
• Google Ads policy, Update to Healthcare and Medicines policy (July 2025)