Advertising a clinic in Singapore: what the Healthcare Services (Advertisement) Regulations allow

The Healthcare Services (Advertisement) Regulations 2021 were made under section 57 of the Healthcare Services Act 2020 and came into operation on 3 January 2022. They apply to any advertisement published, disseminated or conveyed by a licensee or a person acting on the licensee's authority, in any form or medium, that has a Singapore link: accessible by someone physically in Singapore, or addressed to such a person.

The definitions are broad on purpose. To advertise means to publish, disseminate or convey information related to a licensable healthcare service for the purpose of promoting it, directly or indirectly. A website, a directory listing, a clinic's social account and a staff member's post about the clinic all sit inside that.

The regulations also define a review to include an opinion expressed through a rating. A five star rating is a review under regulation 14, not just a written testimonial.

Regulation 5(1) is the clause to read in full. Information must be factually accurate and capable of being substantiated, and must not be exaggerated, false, misleading or deceptive. The advertisement must not be offensive, ostentatious or in bad taste, and must not undermine the honour and dignity of any healthcare profession.

It must not imply that the licensee can obtain results others cannot, create an unjustified expectation, compare its quality with another licensee's, or deprecate another licensee's service. It must not contain any photograph, picture, video or film showing an individual's appearance before and after, or only after, treatment. It must not contain any laudatory statement, including a statement of prominence or uniqueness, or a superlative. And it must not present information in a manner that amounts to soliciting or encouraging use of the service.

Read as a list, that removes most of the vocabulary of clinic marketing: best, leading, award winning, number one, miracle results, the only clinic in Singapore to. What survives is description. Who the clinic treats, what a first visit involves, what it costs, who the clinicians are and what they are registered to do.

Regulation 14(1) sets the default: a licensee must not display, publish or disseminate a review, testimonial or endorsement relating to its licensable healthcare service, including the services of its healthcare professionals and employees. Regulation 14(2) then opens a narrow door.

A licensee may display an applicable review or testimonial, or an endorsement, within its approved premises or on its own website or social media accounts, and only if it was given directly to the licensee and is not reproduced by the licensee or an authorised person. An applicable review or testimonial is one given by a patient, or a patient's next of kin or carer, about their experience or opinion, where nothing was given or offered for it and where the licensee did not substantively modify it before publication.

The practical effect: a patient's own words, posted by that patient on the clinic's social account or given to the clinic for its website, can stay. Paid reviews, edited reviews and reviews copied from a third party platform onto the clinic's pages cannot. Assisted reproduction services are excluded from the exception altogether. Regulation 18 attaches a fine of up to $20,000 or twelve months' imprisonment, or both, to a breach of regulation 14(1).

Regulation 6 limits the media. Outside the approved premises, an advertisement may appear only in newspapers, directories, medical journals, magazines, brochures, leaflets, flyers, pamphlets or the internet, including mobile applications. Inside the premises, and on the clinic's own doors, windows and walls, any form or medium is allowed.

Two further rules catch common tactics. Sending an advertisement to an individual through push technology, or handing out advertising material free of charge, needs that individual's prior written consent. And any brochure, leaflet, flyer or pamphlet must carry its date of publication.

Regulation 15 adds the promotional programme rule: a licensee must not advertise a programme under which a patient may obtain a gift or other benefit based on the value or type of service purchased, where the purpose or effect is to encourage consumption. Payment plans shown at the point of payment and properly labelled corporate social responsibility programmes are the stated exceptions.

Most Singapore clinic websites, read against regulation 5, are built from material the regulations rule out. The superlative in the headline, the before and after gallery, the testimonial strip and the limited time package are each a separate breach. Strip them and the page says almost nothing.

That is the brand problem the regulations expose rather than create. A clinic with a position can describe it without any of that vocabulary. Health screening for working professionals, planned around office hours, with results explained in a follow up call, is a factual statement a reader can verify and a reason to choose the clinic that a competitor would have to match in substance rather than in adjectives.

So the order of work is the same as in every regulated market. Write the positioning sentence first. Then the facts about clinicians, services and process, each one substantiated. Then design. Regulatory judgement stays with the clinic, its licensee representative and, where needed, counsel; the brand work sits inside that judgement.