HCSA Guidelines · Clinic Websites
HCSA guidelines for clinic websites: what you can — and can't — publish.
Your website is one of MOH's approved advertising channels under the HCSA — the rules that replaced the old PHMC guidelines. Anything on it that promotes your services counts as an advertisement, and the parts clinics most want to show off are often the parts that break the rules. Here's the plain-English version for Singapore clinics, element by element.
Start here
Your website is advertising. Treat it that way.
Most clinic owners think of the rules as being about ads — Google, Facebook, flyers. But under the HCSA, your own website is one of the approved places to advertise, which means every claim, photo, and testimonial on it has to pass the same content rules. Three things are worth knowing before you touch a single page.
The rules apply even to overseas patients
If someone sitting in Singapore can load your site, the Advertisement Regulations apply — even if the page is aimed at medical tourists abroad. There's no "foreign audience" loophole for a public website.
The duty can't be handed off
The clinic — the licensee — is always responsible for what's published. You can hire someone to build and run the site, but you can't contract the compliance away. If it's wrong, it's still your name on it.
Your agency is on the hook too
Whoever publishes on your behalf becomes an "authorised person" and can be held personally liable for breaches in their work. A web team that knows this builds compliant by default — because they're exposed as well.
And the stakes are real: breaching the content rules is an offence carrying a fine of up to $20,000, imprisonment of up to 12 months, or both — with further daily fines for continuing breaches. Want the full picture of the advertising rules across every channel, not just websites? Read the complete HCSA advertising guidelines.
Formerly PHMC
Looking for the PHMC guidelines? You're in the right place.
If you've been running a clinic for a while, you may still know these rules as the PHMC guidelines. The Private Hospitals and Medical Clinics Act 1980 (PHMCA) has been repealed and replaced by the Healthcare Services Act 2020 (HCSA), phased in between January 2022 and December 2023. The advertising rules for clinics now sit in the Healthcare Services (Advertisement) Regulations 2021, in force since 3 January 2022.
PHMCA 1980 → HCSA 2020
Licensing moved from a premises-based model to a services-based one. Clinics previously licensed under the PHMCA were transitioned onto HCSA licences — you didn't need to reapply, but the rulebook that governs your advertising changed with it.
Where the rules live today
The current standard is the HCS (Advertisement) Regulations 2021, read together with MOH's published FAQs. The old PHMC advertising regulations and their explanatory guidance no longer apply — any checklist or article still citing them is out of date.
Same spirit, sharper teeth
The principles carried over — factual, substantiable, no hype, no paid testimonials. But the HCSA guidelines made them concrete: a published list of banned laudatory terms, codified testimonial rules, liability for hyperlinks, and personal liability for the agencies that publish for you.
Everything on this page reflects the current HCSA guidelines. If a source you're reading still refers to the PHMC guidelines, treat it as historical.
Interactive · Walk your own site
Tap a part of your website. See what's allowed.
Pick any element of a typical clinic homepage or treatment page. Each one gets a straight verdict and the rule behind it.
The substance
Five things clinics get wrong on their own site.
These are the breaches we see most often when auditing an existing clinic website. Tap any one to open it.
01Superlatives in your headlines
The single most common breach. An advert can't use words that praise, or that imply you're the best, the biggest, or the most advanced — even when the claim is true. MOH keeps a published list, and it's the kind of language most clinic homepages open with.
The fix isn't weaker copy. It's copy that persuades through specifics — what you actually do, for whom, and how — instead of empty superlatives a regulator can strike out.
Easy to forget: this applies to your page titles and meta descriptions too. Those are part of the advertisement, so a title tag reading "Singapore's best aesthetic clinic" is as much a breach as the headline on the page — and it's the bit that shows up in Google results.
02Before & after galleries
An advertisement must not show a person's appearance before and after a treatment — or even after only. This holds with a disclaimer, and it holds whether the images sit in one place or are spread across the site. For aesthetic and dental clinics this is the hardest rule to swallow, because results are the whole pitch.
The one exception is the consultation: these images may be shown to a patient during their own consultation, with the doctor or staff giving proper context and explaining the possible outcomes. Not on a public page, not in a gallery, not in a case-study post.
03Testimonials & reviews
This one is nuanced, and clinics get it wrong in both directions — either avoiding testimonials entirely when they're allowed, or embedding ones that aren't. The line is about where the testimonial came from and whether you're reproducing it.
You can show
- A testimonial the patient gave you directly
- Reviews that are genuine, unpaid and unsolicited
- Comments left as-is (removing expletives is fine)
You cannot
- Re-post or screenshot a Google review onto your site
- Share a patient's Instagram or Facebook post — celebrity or not
- Feature a review that was paid, incentivised or solicited
The catch most clinics miss: pulling a five-star Google review or an influencer patient's post onto your homepage counts as reproducing it — and that's not allowed, even though the review itself is real. Use the testimonial helper below if you're unsure about a specific one.
04Awards & badges — vs credentials
You may display an award only if it was given for meeting a genuine technical or service standard, and only on your own website, social accounts, or inside your premises. Vanity awards you effectively paid for don't qualify, and nothing you show can be misleading.
Good news, and a point clinics often get wrong the cautious way: a doctor's professional qualifications are not "awards" under this rule. Medical registration, specialist accreditation, fellowships and certificates of competence can be stated plainly. Show the credentials; be careful with the trophies.
05Prices that look like deals
You're allowed to publish prices — many clinics do. What you can't do is make a price look like an offer. The moment it reads as a discount or a deal, it becomes prohibited solicitation.
You can
- List the exact, final price of a service
- Show the full total, with no prefix or label
You cannot
- Use "from", "as low as" or "lowest price"
- Cross out a usual price beside a lower one
- Advertise packages, bundles or % off
Packages, referral perks and instalment plans aren't illegal to offer — they're illegal to advertise. Patients can only be told about them at the point of payment, such as your checkout page.
Interactive · Testimonial decision helper
Can this testimonial go on your website?
Answer four quick questions about one specific testimonial or review. You'll get a straight yes or no, with the reason.
Was it given to you directly by the patient — not copied from Google, a blog, or social media?
Did you pay, discount, or incentivise the patient in any way to give it?
Are you reproducing it from elsewhere — a screenshot, an embed, a re-post?
Have you edited or reworded it beyond removing expletives?
Two more traps
Your clinic name and your treatment claims.
These sit outside the "advertising" rules but still shape what your website — and even your domain — is allowed to say.
Specialist words in your name
Certain specialty terms can't appear in your clinic's registered business name or logo — and by extension the domain and site branding built on them — unless you actually employ or engage the accredited specialist behind them. It's a published, non-exhaustive list, and it applies even when the term sits inside a longer word.
So a general practice can't brand itself around "cardio", "derm" or "plastic surgery" without the specialist to back it. One nuance worth knowing: "aesthetic" on its own is not a protected term and is allowed in a clinic name.
Who's allowed to perform what
MOH lists clinical aesthetic procedures — from botulinum toxin and fillers to thread lifts, most lasers, and liposuction — that only a registered doctor, dentist, or oral health therapist may perform. Your treatment pages need to be accurate about this.
And a non-clinical business — a spa, salon, or wellness centre — can't advertise treating a medical condition at all. Different law, same result: the claims on the site have to match what the business is licensed to do.
Before you publish
The HCSA guidelines for clinic websites, as a pre-launch checklist.
Run every page through this before it goes live. It's the short version of the HCSA advertising guidelines that actually applies to a website — the ten checks that catch most breaches.
No superlatives
Scan every headline, subhead, title tag and meta description for "best", "leading", "advanced", "No.1" and the rest of the banned list.
No before & after images
None anywhere — galleries, treatment pages, blog posts, or social embeds. "After only" counts too.
Testimonials given directly only
Every quote on the site came from the patient to you — nothing reproduced from Google or social, nothing paid.
No embedded Google reviews
Link out to your Google profile rather than pulling the reviews onto your own pages.
Prices are plain, not deals
Exact final prices with no "from", no crossed-out figures, no "%off", no packages or limited-time framing.
No promotions advertised
Discounts, referral perks and bundles live at checkout, not on a public page.
Awards vs credentials sorted
Only genuine technical-standard awards shown. Doctor qualifications and accreditations are fine — state them plainly.
No guarantees or fixed timeframes
Nothing promising a result, a cure, "painless", "straight teeth in 2 weeks", an MC, or a teleconsult "done in minutes".
Outbound links checked
Your "as featured in" and partner links don't point to pages carrying laudatory claims about you.
Name & claims match your licence
No restricted specialist terms in the name without the specialist, and treatment claims match what you're licensed to do.
Want to run your actual copy through this instead of eyeballing it? Try the free website copy HCSA checker — paste a headline, page title or meta description and it flags the high-risk words for you. Want the full reasoning behind each item across every channel, not just websites? See the complete HCSA advertising guidelines.
Common questions
What clinic owners ask us.
Are the PHMC guidelines still valid?
No. The Private Hospitals and Medical Clinics Act (PHMCA) has been repealed, and the PHMC advertising regulations and explanatory guidance went with it. The current standard is the HCSA — specifically the Healthcare Services (Advertisement) Regulations 2021, in force since 3 January 2022, read together with MOH's published FAQs. If a checklist, article, or agency brief you're using still cites the PHMC guidelines, it's outdated — check every claim against the HCSA guidelines instead.
What's the difference between the PHMC guidelines and the HCSA guidelines?
The core principles carried over: advertising must be factual and substantiable, no hype, no paid testimonials — that ban existed under the PHMC explanatory guidance too. What changed is precision and accountability. The HCSA publishes a list of banned laudatory terms, codifies exactly when testimonials are allowed, makes you liable for what your outbound links point to, and exposes the agency that publishes for you to personal liability as an "authorised person". Licensing also moved from a premises-based to a services-based model. Practically: if your website was built to PHMC-era standards, it needs re-checking against the current rules.
Does SEO count as advertising?
The process of SEO itself isn't advertising — optimising your pages to rank doesn't, on its own, solicit a service. But the moment your content surfaces patient reviews or ratings, that content becomes a regulated advertisement and has to comply. Paid search (Google Ads) is always advertising and always subject to the rules.
Can I keep my Google reviews if they show up on my site through a widget?
The rules only let you display testimonials a patient gave you directly. Google reviews were given to Google, not to you, and copying, screenshotting, or hand-picking them onto your pages counts as reproduction, which isn't allowed. A live widget showing your full, unedited Google feed is a genuine grey area MOH hasn't ruled on — so the cautious call is to avoid embeds. If you want to point to the reviews, link out to your Google profile instead of pulling them onto the site. That's a link, not a reproduction, and it's clean.
What about educational blog posts — are those safe?
Content that genuinely informs — explaining a condition, its causes and the broad options in neutral terms — is generally educational and not treated as advertising. It tips into a regulated ad the moment it steers the reader toward booking a specific service, or slips in before/after images or an offer. Intent is what MOH looks at, not format.
Does MOH review my website before I publish?
No. There's no pre-approval service. Compliance is self-assessed and sits with you as the licensee. That's exactly why a compliance-aware build and a pre-publish check are worth the effort — nobody's going to catch it for you before it goes live.
I'm not in Singapore — do these rules still apply to my site?
If your clinic is a Singapore licensee and someone in Singapore can view the page, yes. Targeting overseas patients doesn't exempt a public website. The full breakdown of how this works across every channel is in the complete HCSA advertising guidelines.
Our current website probably breaks some of these. What now?
Most do — it's more common than not. The practical move is an audit of every page against the content rules, then a rebuild of the parts that persuade so they work and comply. We do exactly this. If you want a quick first pass on your own, paste your homepage copy into the website copy checker — or the free homepage preview below will show you where your current site stands.
See your site done right
A clinic website that persuades and stays compliant.
We design conversion-focused websites built only for clinics — which means the HCSA rules are baked in from the first draft, not bolted on after. Send us your current site and we'll send back a free homepage preview showing what a compliant, higher-converting version looks like.
Get your free homepage previewThis page is general guidance for clinic owners and marketers, based on the Healthcare Services Act 2020, the Healthcare Services (Advertisement) Regulations 2021, and MOH's published FAQs. It is not legal advice, and the rules are updated periodically — verify against the current official sources before you publish.