Under the healthcare services act singapore (HCSA), a licensee's advertising is governed by the MOH subsidiary regulations for its service class, MOH circulars issued to licensees, and the SMC Ethical Code where a registered doctor is involved. The Singapore Code of Advertising Practice applies on top, as it does to every advertiser in Singapore.
Written for the marketing, corporate communications and practice-management teams of Singapore hospitals, medical groups and clinics. It is an owner-side overview, not medical, legal or regulatory advice; every material statement traces to the named regulator's published text or is left out.
The bodies, and who each one governs
- Singapore Medical Council (SMC) — the statutory body that registers medical practitioners in Singapore and publishes the SMC Ethical Code and Ethical Guidelines, which govern professional conduct, including advertising conduct by registered doctors.
- Singapore Dental Council (SDC) — the statutory body that registers dental practitioners under the Dental Registration Act and publishes ethical guidelines for the dental profession.
- Healthcare Services Act (HCSA) — the licensing framework administered by MOH that replaced the Private Hospitals and Medical Clinics Act. It governs licensable healthcare services, and its subsidiary regulations carry the advertising provisions for those services.
- MOH circulars — administrative circulars MOH issues to licensees on specific practice, safety and advertising matters.
- Advertising Standards Authority of Singapore (ASAS) — administers SCAP, the general advertising code for Singapore.
Where to look, by question type
- Is this advertisement within medical-practitioner conduct rules? — the SMC Ethical Code and Ethical Guidelines.
- Is this dental practice's advertisement compliant? — the SDC ethical guidelines; the Dental Registration Act governs registration.
- Does the service need a licence, and do advertising rules attach to it? — the HCSA licensing framework and its subsidiary regulations, administered by MOH.
- Has MOH addressed this situation specifically? — MOH circulars to licensees.
- Does the general advertising code apply as well? — yes; see the SCAP section below.
Advertising and marketing conduct under the Healthcare Services Act
The healthcare services act singapore (HCSA) is the licensing framework administered by MOH. Under it, a licensee's advertising and marketing conduct sits under three overlapping sources: the HCSA subsidiary regulations that carry the advertising provisions for the licensable service class, MOH circulars issued to licensees, and the SMC Ethical Code where the practitioner is a registered doctor.
MOH publishes hcsa guidelines on top of the hcsa act to explain what a licensee may and may not include in its advertising; the guidelines interpret the act, so a compliance decision made on the guidelines alone is incomplete.
A hcsa license singapore is issued per licensable service class, and the licence identifier appears on the licensee's own MOH-issued documentation. The HCSA regulatory portal (hcsa singapore) and MOH's licensing pages are the places to confirm what applies to a given service. For how we run marketing for hospitals and medical groups inside these rules, see the Singapore healthcare page.
Does an HCSA licensee need approval before advertising a healthcare service in Singapore?
Under the Healthcare Services Act framework, advertising conduct is governed by the MOH subsidiary regulations for the licensable service, MOH circulars issued to licensees, and, where a registered doctor is involved, the SMC Ethical Code.
Whether a specific advertisement needs anything more depends on the service class and the claim being made; the licensee's own MOH-issued licence conditions and the current regulation text are the source for that decision, not this page.
What does the Healthcare Services Act change about how a licensed provider may market its services?
The Healthcare Services Act replaced the private hospitals and medical clinics act as the licensing framework administered by MOH. A licensee's advertising now sits under the HCSA subsidiary regulations for its service class, MOH circulars on specific advertising matters and, for registered doctors, the SMC Ethical Code.
The Healthcare Services (Advertisement) Regulations 2021: reviews, testimonials and honours
The advertising provisions for HCSA licensees are in the Healthcare Services (Advertisement) Regulations 2021 (opens in a new tab), published on Singapore Statutes Online as S 1033/2021 under the Healthcare Services Act 2020. Two regulations matter most to a marketing team.
- Regulation 13 — honours. Except as the regulation provides, a licensee must not display or publish information about an accreditation, certification, award, prize or other honour conferred on it in relation to a licensable healthcare service.
- Regulation 14 — reviews, testimonials and endorsements. Except as the regulation provides, a licensee (and an authorised person) must not display, publish or disseminate a review, testimonial or endorsement by any person relating to a licensable healthcare service it provides, including the services of its healthcare professionals.
MOH's published answers on ask.gov.sg apply regulation 14 to social media directly: a licensee may not reproduce testimonials, endorsements or photos (opens in a new tab) on its premises, website or social media accounts, and that includes sharing a patient's or an influencer's own post.
MOH describes a narrow allowance for testimonials a patient gives directly to the institution, provided they are organic and not induced — read the answer itself before relying on it.
Separately, MOH states that unpaid reviews a patient posts on their own initiative on third-party blogs, platforms and websites are not advertising by the licensee, and it treats paid reviews as prohibited. MOH's FAQ document on the Advertisement Regulations (opens in a new tab) collects these answers in one place.
For a hospital's social team this is the rule that changes daily work most; our guide to healthcare social media marketing in Singapore turns it into a working process.
The Singapore Code of Advertising Practice and healthcare advertisers
The singapore code of advertising practice (SCAP) is the general advertising code for Singapore, administered by the Advertising Standards Authority of Singapore and published on asas.org.sg (opens in a new tab). It applies to healthcare providers on the same terms as any other advertiser: a hospital's campaign answers to the code as well as to the healthcare-specific rules above.
The two layers do different jobs. SCAP sets the general standard every advertisement in Singapore is held to; the HCSA subsidiary regulations, MOH circulars and the SMC Ethical Code add the rules specific to licensed healthcare services. Meeting the general code does not satisfy the healthcare rules, and the healthcare rules do not remove the general code.
For a marketing team, that means creative is checked against both before it runs — which is how we brief every Singapore healthcare campaign.
What this means for a hospital or medical group's marketing team
In practice the rule map turns into a short brief for every campaign. Before creative is drafted, the team confirms which licensable service the advertisement is for (the hcsa singapore portal shows how services are classed), whether a registered doctor is named or quoted, and whether a product, medicine or device is mentioned. Each answer pulls in a different source:
- the HCSA subsidiary regulations and hcsa guidelines for the service,
- the Singapore Medical Council's Ethical Code for anything written by or about a doctor,
- the SDC's guidelines — the dental council Singapore dentists register with — for dental practices,
- and the Health Products Act or the Medicines Act for anything product-side.
The same brief sets what the creative will not do. Outcome guarantees, comparative claims and patient testimonials are the areas the Singapore rules restrict most, so they are designed out at brief stage rather than removed at review.
Practitioner profiles, department pages and doctor-led video are where the Singapore Medical Council's standards matter most, because that is where a hospital speaks in a doctor's voice.
Five recurring creative questions, each answered by the regulation that decides it (Healthcare Services (Advertisement) Regulations 2021, current version on Singapore Statutes Online, checked 9 October 2026):
Sign-off and responsibility
The clinic, as licensee, must make sure every advertisement it or its agency publishes complies, and must have a non-compliant one corrected or withdrawn once it knows of it. An agency acting for the clinic is an "authorised person" under the Regulations (regulations 2, 5 and 17).
Testimonials and reviews
Reviews, testimonials and endorsements cannot be used to advertise the clinic's service. The exception is a review a patient gave directly to the clinic, shown on the clinic's own premises, website or social account and not reproduced (regulation 14).
Before-and-after images
No photograph, picture or video showing a person before and after, or only after, a treatment, in one advertisement or spread across several. Showing them to a patient during a consultation remains allowed (regulation 5).
Influencer content
More detail on What this means for a hospital or medical group's marketing team
A creator's endorsement of the clinic's service is an endorsement under regulation 14, and a joint promotion with another person's goods, event or programme must still meet the content rules in regulation 5 (regulation 7).
Price promotions
A programme offering a gift or other benefit based on the value or type of service bought cannot be advertised. A payment plan may be advertised only to patients at the time payment is sought (regulation 15).
To test a draft against these rules before it runs, use the MOH ad checker; for how we build Singapore clinic campaigns around them, see healthcare marketing in Singapore.
Products, medicines and devices: a separate regime
- Health Products Act — the Health Sciences Authority's product regulation. Where an advertisement mentions a specific medicine, medical device or health product, the health products act governs the product claim regardless of who is advertising, and it is not replaced by HCSA. A clinic advertising a service that names a device or product answers to both at once.
- Medicines Act singapore — governs the advertising and supply of medicines specifically, alongside the Health Products Act.
- Private Hospitals and Medical Clinics Act — the licensing framework before HCSA. It should not be cited as current authority; where an older document still refers to it, treat the reference as historical.
HSA health supplements guidelines: what a supplement brand's marketing can say
Health supplements sold in Singapore are regulated by the Health Sciences Authority, but not through pre-market approval. HSA states that health supplements are not subject to approvals or licensing for import, manufacture or sale, and that dealers are responsible for meeting its guidelines before they supply a product.
For a marketing team the rules that matter are the claims rules, and they cover advertising and promotion as well as the label.
- No medicinal claims. HSA's position is that a health supplement must not be labelled, advertised or promoted for any medicinal purpose, including claims that suggest it treats or prevents a disease, disorder or related condition. General health claims, and claims about supporting or maintaining a body function, are the permitted lane, and the dealer holds the evidence for them.
- No healthcare-professional endorsements. HSA's claims guidance says testimonials or recommendations by healthcare professionals should not be used in the label, advertisement or promotional materials. A doctor or pharmacist fronting a supplement campaign is therefore out, and a creator brief for a supplement brand is written with that in mind.
- No permit, except for quasi-medicinal products. HSA says advertisements and promotions of health supplements are not subject to permit approval, except for products classified as quasi-medicinal. Advertising must still follow the claims guidance and must not mislead, encourage improper use or bring undue harm.
- The Singapore Code of Advertising Practice applies on top. HSA's claims guidance states that health supplement advertisements must also comply with SCAP.
The current reference is HSA's Health Supplements Guidelines (GL-CHPB-3-001, January 2026 revision), read with its guidelines on claims and claims substantiation. HSA consulted in 2026 on proposed changes to how complementary health products are regulated; until final rules are published, the current guidelines are what a campaign is checked against.
For health supplement and health product brands we run the marketing side: content marketing, Meta Ads and creator programmes, with every claim written to these rules from the first draft. We do not file product notifications or give regulatory advice; a regulatory-affairs consultant or HSA itself is the source for that.
More detail on HSA health supplements guidelines: what a supplement brand's marketing can say
Search campaigns for licensed providers and health product brands run through our Google Ads agency in Singapore service, with ad text and landing pages held to the same rules.
Where this page fits
The Malaysian counterpart is Advertising Guidelines for Healthcare Facilities and Services (Malaysia); the two markets run separate rules and separate campaigns. For Singapore programme context, see dental clinic marketing (Singapore), aesthetic clinic marketing (Singapore) and our published Singapore dental group Meta Ads case study.
Before a draft ships, the MOH advertising checker flags common red flags; it does not replace the licensee's own MOH-issued conditions.
How this connects to our Singapore services
shakalakaa does not prepare, file or advise on HCSA licence applications, Health Products Act registrations, MOH submissions or Medicines Act filings; a licensee needing help with a submission goes to a regulatory-affairs consultant.
What we do is turn these rules into campaigns that run: content marketing that gives each specialty page substance, SEO for Singapore for the organic side of every healthcare query the organisation wants to own, and web design and development for the department, location and practitioner pages a licensed provider needs on its own site.
Sources
- Singapore Medical Council — Ethical Code and Ethical Guidelines — checked 2026-09-05
- Singapore Dental Council — ethical guidelines (opens in a new tab) — checked 2026-09-05
- Healthcare Services Act 2020 — Singapore Statutes Online — checked 2026-09-05
- HCSA regulatory portal (opens in a new tab) — checked 2026-09-05
- MOH — healthcare services regulation and licensing — checked 2026-09-05
- Private Hospitals and Medical Clinics (PHMC) (Advertisement) Regulations (historical) — checked 2026-09-05
- Singapore Code of Advertising Practice — ASAS — checked 2026-09-25
- Healthcare Services (Advertisement) Regulations 2021 (S 1033/2021) — Singapore Statutes Online — checked 2026-09-26
- MOH on ask.gov.sg — reproducing testimonials and endorsements — checked 2026-09-26
- MOH on ask.gov.sg — unpaid and paid third-party reviews — checked 2026-09-26
- MOH — FAQs on the HCS (Advertisement) Regulations — checked 2026-09-26
- HSA — regulatory overview of health supplements — checked 2026-09-27
- HSA — health supplement claims (opens in a new tab) — checked 2026-09-27
- HSA — Health Supplements Guidelines (GL-CHPB-3-001, January 2026) — checked 2026-09-27
- Baker McKenzie — HSA consultation on complementary health products regulation (July 2026) — checked 2026-09-27
More detail on Sources
Not covered here: the regulation numbers and section numbers of the instruments above, HSA controls for therapeutic products, medical devices and Chinese proprietary medicines in detail, and PDPA obligations on lead data. For those, read the current text on Singapore Statutes Online (sso.agc.gov.sg) or the regulator's own site. Lead follow-up consent is covered by our PDPA/DNC checker.
How this page is maintained
Every statement on this page summarises the named regulator's published position. Nothing here quotes a fee, timeline, form number or licence class — those live in the regulators' own documents. If a regulator update has changed something on this page, tell us and we will correct or remove it.

