MOH and SMC Advertising Rules for Singapore Clinic Marketing: What You Can and Cannot Say (2026)

The two regimes, and who each binds

The statutory regime is the Healthcare Services (Advertisement) Regulations 2021 (the Regulations), made under the Healthcare Services Act 2020. The Regulations bind the clinic as licensee, and a breach is an offence under regulation 18.

The professional regime is Section G of the Singapore Medical Council (SMC) Ethical Code and Ethical Guidelines (2016), abbreviated ECEG below. Section G binds the doctor's professional conduct through the Medical Registration Act. The ECEG states that it "has to be read in conjunction with current directives and guidelines issued by the Ministry of Health", so the two regimes apply together. The 2016 edition remains the operative edition as of July 2026. The Singapore Medical Association (SMA) reproduces Section G verbatim in its Advisory on Advertising Standards for Doctors (22 November 2020). The advisory states that the standards apply whether a doctor advertises directly or through a proxy the doctor authorises, which includes an agency running the clinic's marketing.

What counts as an advertisement, including a clinic website

Regulation 2 of the Healthcare Services (Advertisement) Regulations 2021 defines the scope broadly. To "advertise" means:

"to publish, disseminate or convey any information that is related to the provision of a licensable healthcare service, for the purpose of promoting (directly or indirectly) that licensable healthcare service", and an advertisement is such information conveyed "by any means or in any form or medium". (reg 2)

The definition in regulation 2 covers the clinic's website copy, treatment pages, blog articles and social media. SEO for clinics is therefore regulated work.

What is banned, clause by clause

Regulation 5(1) sets the content rules for the clinic. The advertisement's information "must be factually accurate and capable of being substantiated" and "must not be exaggerated, false, misleading or deceptive" (reg 5(1)(a)). Beyond that baseline, the advertisement must not:

• 5(1)(c) contain information that implies results "not achievable by other licensees", creates "an unjustified expectation", "compares and contrasts the quality" of one clinic's service with the same service from another licensee, or "deprecates" another licensee's service
• 5(1)(d) 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"
• 5(1)(e) contain "any laudatory statement (including a statement of prominence or uniqueness) or superlative", for example "best", "#1", "leading" or "the only". MOH publishes a non-exhaustive list of 61 laudatory terms in Annex A of its FAQ on the Healthcare Services (Advertisement) Regulations, including "cutting-edge", "state-of-the-art" and "world's most advanced"
• 5(1)(f) contain "any review, testimonial or endorsement", except as provided in regulation 14
• 5(1)(g) provide information "in such a manner as to amount to soliciting or encouraging" use of the service

ECEG Section G sets matching standards for doctors. G2(1) requires that medical advertising be, verbatim: "(a) Factual. (b) Accurate. (c) Verifiable. (d) Not misleading. (e) Not unduly persuasive. (f) No extravagant claims. (g) Not sensational. (h) Not enticing or alluring. (i) No financial inducements. (j) Not laudatory. (k) Not comparative. (l) Not disparaging." G2(3) prohibits before-and-after images and after-only images. G2(8) forbids "any impression that you and your practice are superior in any way compared to other doctors".

Two lesser-known clauses of the Healthcare Services (Advertisement) Regulations 2021 matter for SEO specifically. Regulation 13 restricts the display of accreditations, certifications and awards by default. Regulation 13 permits an accreditation, certification or award only where the awarding body conferred it because the clinic met technical standards, and only in defined places: within the clinic's premises or conveyance, and on the clinic's own website or social media accounts. An honour for meeting technical standards for a specific service may be shown only in relation to that service; an honour for meeting technical standards for the clinic's healthcare services in general may be shown in relation to any service the clinic is licensed to provide. An authorised person acting for the clinic, such as an agency, must not publish information about an honour at all. Regulation 16 prohibits a clinic's website from hyperlinking to another website whose content would itself breach the regulation 5 standards. Regulation 16 also includes a safe harbour: the prohibition does not apply if, at the time of setting the hyperlink, the licensee or authorised person "does not know, and has no reason to believe," that the linked website breaches the regulation 5 standards. On becoming aware of a non-compliant hyperlink, the licensee or authorised person "must immediately remove" it from the clinic's website, subject to the exceptions in regulation 16(4) and (5). Outbound links and link-building are regulated work.

Penalties for breaching the Healthcare Services (Advertisement) Regulations 2021

Regulation 18 is the offence provision of the Healthcare Services (Advertisement) Regulations 2021. Regulation 18 does two different things.

For a breach of the regulation 5(1) content rules, which cover superlatives, comparisons, before-and-after images, testimonials and inducement, regulation 18(1) does not set a figure itself. Regulation 18(1) states that a licensee who contravenes regulation 5(1) "shall be guilty of an offence under section 31(3) of the Act ... and shall be liable on conviction to be punished in accordance with section 31(3) of the Act". The penalty for the rules that most clinic marketing touches is therefore set in the Healthcare Services Act 2020, not in the Regulations.

For breaches of regulation 13 (accreditations and awards), regulation 14(1) (reviews, testimonials and endorsements) and regulation 16 (hyperlinks), regulation 18 states the penalty directly. A testimonial displayed outside the regulation 14 exception therefore breaches both regulation 5(1)(f) and regulation 14(1), and the regulation 14(1) breach carries this penalty, verbatim:

"a fine not exceeding $20,000 or to imprisonment for a term not exceeding 12 months or to both and, in the case of a continuing offence, to a further fine not exceeding $1,000 for every day or part of a day during which the offence continues after conviction." (reg 18(3)–(4))

Figures circulating on agency blogs tend to attach the $20,000 figure in regulation 18(3)–(4) to every breach. The Regulations do not apply the $20,000 figure to every breach. Cite the provision that applies to the conduct in question, and if the number matters to a decision, check the number with legal counsel.

The testimonial exception (regulation 14)

Reviews and testimonials are prohibited by default, with one narrow exception: regulation 14(2) permits them on the clinic's own website or social media only where the review "was given by P directly to the licensee and is not reproduced by the licensee or an authorised person". Aggregating star ratings or reposting Google reviews does not qualify. ECEG paragraph G2(7) adds that testimonials "must not be used in advertising on any media where you have any control over the content", and that a doctor "must not ask or induce" patients to write them.

Discounts, free consultations and promotional pricing

Clinics most often ask whether discounts, free consultations and promotional pricing are allowed, and MOH has answered that question in detail. The prohibition sits in regulation 5(1)(g), which bars providing information "in such a manner as to amount to soliciting or encouraging" use of the service. MOH's own FAQ on the Healthcare Services (Advertisement) Regulations (October 2023) lists what regulation 5(1)(g) covers:

"Examples of information that solicit or encourage the use of licensable healthcare services are 'promotions' which refer to free or discounted services or products provided at or by licensees, or interest-free payment plans…" (MOH FAQ on the Healthcare Services (Advertisement) Regulations, October 2023)

The MOH FAQ also lists the following as promotional: price comparisons between usual and discounted rates, packages, "as low as" or "lowest prices" framing, preferential prices with a validity period, free or lower-cost tie-in services, group-buying listings, giveaways, lucky draws and prizes, loyalty miles or points redemption, and the words "discount", "interest free", "preferential rate", "promotion", "offer", "complimentary" and "free".

MOH Circular 87/2024 applies the same reasoning to examples that clinics still run: advertising a medical certificate ("MC in 1 minute") or a headline consultation price ("Medical Consultation from $10"). MOH treats both as soliciting under regulation 5(1)(g). The Regulations govern what a clinic may advertise. A clinic may still operate a fee structure that the clinic does not promote. The compliance question is always what appears in the advertisement, and a clinic's website is an advertisement.

The headline examples above are Novastacks illustrations of the clauses, and no regulator issued the example wording. The clause that each example applies is cited beside the example. Check any borderline case against the clause itself.

Which channels the advertising rules cover

Regulation 2 of the Healthcare Services (Advertisement) Regulations 2021 covers promotional information conveyed "by any means or in any form or medium", so most channels are covered. The table below lists the clause that usually applies to each channel.

One platform rule applies in addition to the Singapore regime: Google requires healthcare and medicines advertisers to be certified under its healthcare and medicines policy before certain campaigns can run. The certification is a Google requirement that MOH does not impose. Google certification does not make an advertisement compliant with regulation 5 of the Healthcare Services (Advertisement) Regulations 2021.

What compliant clinic marketing can do

ECEG paragraph G2(2) states what doctors may advertise:

"You may advertise by providing neutrally toned and objective information about your SMC-registered qualifications, experience, areas of practice and your expertise in procedures." (SMC ECEG G2(2))

In practice, the content that ECEG G2(2) permits maps directly onto the work that earns search rankings and AI citations for clinics: factually accurate condition and procedure pages that answer what patients actually search, doctor profile pages in the neutral tone that the SMC permits, structured data that lets search and AI engines read the site, a properly maintained Google Business Profile, and a review process within regulation 14. ECEG G4(3) permits case studies and images where they are "for educational purposes and not used gratuitously". Under ECEG G4(4), any paid placement must be disclosed "prominently to your audience at the beginning of the article".

Medical SEO in Singapore is a distinct discipline: compliant medical SEO and effective medical SEO are the same work, but only if the marketer knows which clauses apply. Novastacks offers compliant medical SEO as a service: Medical SEO for Singapore clinics.

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