Guide
Facebook ads for a Singapore aesthetic clinic: what the MOH advertising rules say, and how I build around them
Short answer: For a licensed clinic, Singapore's advertising regulations say an ad must be accurate and provable, and must not use before-and-after photos, testimonials (with narrow exceptions), superlatives, comparisons with other clinics, or gift promotions tied to what a patient buys. So I keep clinic ads to facts and a consultation, and the clinic approves every word. I'm not a lawyer and this isn't legal advice.
Want me to check your own follow-up? Get my free review
I run Facebook and Instagram ads and the follow-up behind them, and clinics ask me what the rules allow. I can't tell you whether your ad is lawful. What I can do is show you what the regulations say, in their own numbering, so you can check your ads with your own adviser. I read the text on Singapore Statutes Online on 4 October 2026, where it was shown as the current version.
Which rules apply?
The Ministry of Health's page on regulation of advertisements for aesthetic treatments (dated 9 January 2024) says aesthetic procedures by licensed providers are regulated under the Healthcare Services Act 2020, and their advertising under the Healthcare Services (Advertisement) Regulations 2021. It says advertised content must be accurate, truthful and not induce unnecessary consumption of healthcare services, and that non-medical professionals, including social media influencers, are not allowed to advertise licensable healthcare services unless they hold an HCSA licence.
The regulations themselves are on Singapore Statutes Online. They apply to ads published by a licensee or an authorised person that have a Singapore link, meaning people in Singapore can see them (regulation 3). Whether a particular treatment is a licensable healthcare service is a question for the clinic and MOH, not for me.
What must a clinic ad not contain?
Regulation 5 is the core. In summary, the ad:
- must be factually accurate and capable of being substantiated, and not exaggerated, false, misleading or deceptive (5(1)(a));
- must not imply the clinic gets results other clinics can't, create an unjustified expectation, compare itself with another clinic's quality, or put down another clinic's service (5(1)(c));
- must not show anyone before and after, or only after, a treatment, in a photo, picture, video or film (5(1)(d)). Showing such images to a patient during a consultation is not prohibited (5(2));
- must not use laudatory statements, including claims of prominence or uniqueness, or superlatives (5(1)(e));
- must not contain a review, testimonial or endorsement, except as regulation 14 allows (5(1)(f));
- must not provide information in a way that amounts to soliciting or encouraging use of the service (5(1)(g)).
What about testimonials and reviews?
Regulation 14 says a licensee and an authorised person must not display, publish or disseminate a review, testimonial or endorsement, with exceptions. The main one lets a licensee show an applicable review or testimonial on its own website or its own social media account, only if the person gave it directly to the licensee and it is not reproduced by the licensee or an authorised person. It must not be given in return for money or another benefit, and must not be substantively modified. So a testimonial reposted into a paid ad, or used in a follow-up email, is not something I'd write.
What about offers and promotions?
Regulation 15 says a licensee and an authorised person must not advertise a programme under which a patient can obtain a gift or other benefit based on the value or type of service purchased, where the purpose or effect is to solicit or encourage consumption of the service. It has exceptions, such as a payment plan advertised only at the time payment is sought. Read the exceptions with your adviser before you write any offer.
Do the rules reach an agency like me?
They may. The regulations define an authorised person as someone acting on the licensee's authority in advertising a licensable healthcare service, or causing it to be advertised. Some offences, including the testimonial rule in regulation 14(1), apply to authorised persons directly, with a fine of up to $20,000, up to 12 months in prison, or both (regulation 18(4)). I'm not in a position to say whether I fit the definition for a given clinic, and I don't need to. I treat the rules as binding on my work either way, and the clinic is still the one who must make sure its ads comply (regulation 5(1) is addressed to the licensee).
What about messages sent to people?
Regulation 6(4) says a licensee and an authorised person must not advertise a licensable healthcare service by sending an advertisement to an individual through push technology, or by giving out advertising material free of charge, unless the licensee has the individual's prior written consent. The regulations as I read them don't define push technology. So whether your automatic emails or texts count is a question for your adviser. It's one more reason I keep first replies to booking a consultation and don't promote a treatment in them. The PDPC's separate rules for messages to Singapore numbers are in my general clinic guide.
What does that mean for the ad and the lead form?
This is how I'd build, as my own practice and not as a ruling:
- Ad copy: who you are, where you are, your hours, and an invitation to book a consultation. No result claims, no "best", no comparisons, no gift offers.
- Images: the premises and the team, supplied or approved by the clinic. Nothing showing someone before or after.
- Lead form: contact details and a preferred consultation time. Meta's list of questions prohibited on instant forms includes health information such as medical conditions and treatments, and says a form that breaks it won't run. Medical questions belong in the consultation.
- Approval: the clinic approves every word and image before anything goes live. I'd rather an ad go live a week later than carry a line your doctor wouldn't sign.
What results can you expect?
I don't have a Singapore clinic result to show you, and I won't invent one. The closest on my Work page is a Philippines brow studio, where Messenger campaigns brought 2,028 conversations at ₱10.40 each, lifetime to 23 September 2026. Those are conversations, not appointments, in a different market with different rules.
A checklist for your clinic
Swipe
| Check | Where it comes from |
|---|---|
| Every claim is accurate and can be substantiated | Regulation 5(1)(a) |
| No result claims, comparisons or superlatives | Regulation 5(1)(c) and (e) |
| No before-and-after or after-only images in ads | Regulation 5(1)(d) |
| No reviews or testimonials in ads or messages | Regulations 5(1)(f) and 14 |
| No gift or benefit tied to what a patient buys | Regulation 15 |
| Consent checked before sending advertising to individuals | Regulation 6(4) |
| No health or insurance questions on the lead form | Meta |
| Wording approved by the clinic, then its adviser | Regulation 17 (the licensee must act on non-compliant ads) |
If your enquiries come in faster than you can answer them, the follow-up matters as much as the ad. I cover that in how aesthetic clinics can follow up treatment enquiries. The same problem for property agents is in how property agents follow up Facebook leads.