Every time the main text says "see Appendix A" for a rule, you can find the rule number, the original sentence, the link and the label here. **The SDC rules in A.2 govern only dentists. For aesthetic clinics (where the practitioner is a doctor), the corresponding rules are in the SMC Ethical Code and Ethical Guidelines, whose original document was not obtained this round. So any Statute text that rests on SDC alone is treated as Original text not obtained for aesthetic clinics, without exception; see 1.1.** The label column copies the judgement the main text has already made; nothing is re-judged here. This appendix only gives the source line behind each judgement, so you can check it and show the original wording to the client's compliance officer.
Source links: the MOH FAQ is isomer-user-content.by.gov.sg/7/a2d9019f-7617-40f1-8788-7e105b0a77e9/12-10-2023-advert-regs-faqs-(1).pdf (the same text is also at ask.gov.sg/moh/questions/clu6lx3rp00aw314riciuc4ks); wherever the URL column in the table below says "MOH FAQ", it means this document. The original text of the legislation is on SSO: the Healthcare Services (Advertisement) Regulations 2021 (S 1033/2021), sso.agc.gov.sg/SL/HSA2020-S1033-2021; the Healthcare Services Act 2020, section 31, sso.agc.gov.sg/Act/HSA2020; the pure-directory exemption is in the Healthcare Services (Advertisement — Exemption) Order 2021 (S 1034/2021), paragraph 4. The 2018 edition of the SDC ECEG (Updated as at 15 April 2019) is at sdc.gov.sg/for-professionals/regulations-guidelines-circulars/sdc-ethical-code-guidelines/, PDF isomer-user-content.by.gov.sg/76/c10cc4de-6a21-4108-bde8-75b6a6683bec/sdc-eceg-2018---updated-15-april-2019108d468283c14e15b40f36d0ef057467.pdf; wherever the URL column in the table below says "SDC ECEG", it means this document.
A.1 HCSA and the MOH FAQ
What you'll do in this section: when the main text says "see Appendix A" for a rule, look up the rule number in this table and check the original sentence, link and label. Once checked, use it as it is; do not re-decide here whether the ban holds.
The rule numbers in the table below were checked one by one against the current version on SSO on 2026-09-28 (regulations: the consolidated version in force from 2023-06-26; the Act: the version in force from 2023-12-18). The "Original sentence" column quotes MOH's FAQ on the HCS (Advertisement) Regulations (Updated as of Oct 2023; "the MOH FAQ" below), which is MOH's official interpretation of its own regulations. Where the regulations set only the principle and the specifics come from the MOH FAQ, the rule-number column says "detail from the MOH FAQ". By the definition in 1.1, what a regulator's official FAQ states in black and white also counts as Statute text. The MOH FAQ gets one rule number wrong (in the outbound-link row); the regulations' own text prevails, and this is noted on that row.
| Rule number | Original sentence | URL | Label | Used in |
|---|---|---|---|---|
| HCSA section 31(1) (who may advertise), section 31(2) (both the licensee and the authorised person must ensure the advertisement complies), section 31(3) (penalty) | "As stipulated in section 31(1) of HCSA, only a licensee or a person acting on the authority of a HCSA licensee (referred to as an "authorised person"...) may advertise licensable healthcare services. In this regard, third parties who are authorised persons can be held liable..." "Advertisement of a licensable healthcare service by someone who is not a HCSA licensee nor an authorised person contravenes section 31(1) of HCSA." "The appointments and authorisations should be appropriately documented such as through contractual arrangement or letter of appointments." Penalty, the original text of section 31(3): "…liable on conviction to 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 of the regulations sets the same penalty for breaching Reg 13, 14 and 16 | MOH FAQ (original wording on liability); SSO sso.agc.gov.sg/Act/HSA2020, section 31 (original wording on the penalty) | Statute text (the liability sentences and the penalty) | 0.2, 1.1, 6.1, 6.5 |
| Reg 5(1)(a) factually accurate and capable of being substantiated | "there must be sufficient evidence to support and validate the information contained in the advertisement" "If a licensee does not or is unable to provide MOH with the required information, the licensee may have contravened Regulation 5(1)(a)." | MOH FAQ | Statute text | 1.5 |
| Reg 5(1)(d) (the before-and-after photo ban), 5(2) (may be shown to patients at consultation); result timeframes: the MOH FAQ lists this as a Reg 5(1)(g) soliciting example | "advertisements must not feature "before-and-after" or only "after" treatment photographs, pictures, videos or films, even with disclaimers"; at consultation, "may be shown to patients during their consultation with the doctor". Both ""Before-and-after" treatment photos" and "Information that promises or suggests that the services can bring about results within a certain time period, e.g. "Instant / immediate teeth whitening", "straight teeth in 2 weeks"." are listed as soliciting examples | MOH FAQ | Statute text | 1.4, 1.5, 5.13 |
| Reg 5(1)(g) soliciting: promotional and pricing wording (the regulation only bans soliciting; the word list and the miles/points example: detail from the MOH FAQ) | ""promotions" which refer to free or discounted services or products provided at or by licensees" "Words or phrases such as "package", in connection with a price discount" "Preferential prices for licensable healthcare services with a "validity period"" "Words or phrases such as "discount", "interest free", "preferential rate", "promotion", "offer", "complimentary", "free", or other words or phrases to the same effect"; miles / points redemption: "Using miles/points/vouchers has a soliciting effect... and this may contravene Regulation 5(1)(g)" | MOH FAQ | Statute text | 1.2, 5.6 |
| Reg 6(1) advertising media (the current version of the regulations also lists flyers, and only covers advertising outside clinic premises); the two SEO sentences: detail from the MOH FAQ (its answer on Reg 6(4)(a) push technology) | "Such advertisements are only allowed in the following: newspapers, directories, medical journals, magazines, brochures, leaflets, pamphlets and the Internet..." "SEO is not considered as "advertising"... However, if the SEO platform utilises patient reviews and ratings, then such information listed is considered as an advertisement..." | MOH FAQ | Statute text | 1.4, 2.4, 6.2 |
| Reg 12 public talks (the regulation only permits advertising talks the licensee organises itself, and does not list the fields); the allowed fields: detail from the MOH FAQ (the FAQ's original table also has items such as the topic and a synopsis) | "...confine the advertisement of such events to information that is factual... Names; and Registered professional qualification(s); and Professional title(s) reflecting the register(s) in which the speakers are registered (if any); and Qualification(s) accepted and recognised for display by the relevant professional bodies (if any); and Name(s) of the place(s) of practice..." | MOH FAQ | Statute text | 1.6, 3.2 |
| Reg 13(1), 13(3)(b), 13(4)(c), 13(5) certification and third-party lists; also 13(2): an authorised person must not publish information about honours in any manner (this applies to an agency publishing on the client's behalf); the point that the licensee is not liable when a third party publishes on its own accord: detail from the MOH FAQ | "Licensees can only display... any accreditation, certification or award... on their websites and social media accounts... only awards / accreditation that are awarded... for compliance with technical standards..."; "...do not include professional qualifications conferred on registered healthcare professionals, such as professional registration certificates..."; "materials containing... a list of the names of HCSA licensees that have been accorded an honour... are deemed to be an act of advertising... If the party putting up the content is a HCSA licensee and/or an authorised person, they contravene Regulation 13"; "The licensee will not be held responsible if a third party, acting on its own accord, publishes the information on their websites." | MOH FAQ | Statute text | 1.6, 3.3, 6.2, 6.6 |
| HCSA section 31(1); a third party's list of honoured clinics counts as advertising, and once aware, the licensee takes steps to get the publisher to remove it and verifies that it did: detail from the MOH FAQ (pages 15 and 20) | "any organisation that is not a HCSA licensee or an authorised person, and that puts up such information contravenes Section 31(1) HCSA in relation to the publication of that advertisement."; "once the licensee is made aware of such an advertisement, the licensee should take reasonable steps to get the unauthorised person to remove it and verify that the unauthorised person had done so properly." | MOH FAQ | Statute text | 6.2, B.2 |
| Reg 14(2), 14(5)(a), 14(5)(b) reviews, testimonials and endorsements (Reg 2 counts a numeric rating as a review too) | "Licensees are not allowed to reproduce (be it in whole, or in part) any testimonials, endorsements or photos in their premises, website or social media accounts. This includes sharing a user's post that were originally posted on Facebook, Instagram or any social media..."; "Where the review is self-initiated by the patient and not under the influence of the provider, it will be allowed... is not an act of advertising"; "licensees and healthcare professionals must not coerce or offer valuable consideration of any kind to induce patients... to provide testimonials"; an allowed review must be "not modified by the licensee or authorised person... (this does not preclude... removing offensive comments (e.g. expletives))"; paid reviews with the sponsorship disclosed: "...it is unethical and inconsistent to allow licensees to pay for and, in so doing, influence the content of the "review"...". One more sentence: "Displaying or publishing of any testimonial, endorsement, or photos within a licensee's premises, website or social media account is allowed as long as these testimonials, endorsements or photos were given by the patient directly to the healthcare institution." (for how to answer a client who cites this, see 1.4) | MOH FAQ | Statute text | 1.4, 6.2, 6.5, 7.1 |
| Reg 15(1) (gift and referral-type schemes must not be advertised), 15(2)(a) (instalment plans disclosed only at payment); listing only the exact and final price, with no prefix and no comparison with the original price, and disclosing promotional packages only at payment, are not in the regulations: detail from the MOH FAQ, with Reg 5(1)(g) soliciting as the underlying rule | "Licensees would only be able to list the exact and final price of the services, subject to the following conditions: The advertisement does not indicate any prefix/description to the price; and The advertisement does not include a comparative listing of the prices / original price."; promotional packages (the original question also covers referral programmes): "advertisements of promotional packages are not allowed as they may induce consumption of the service" "Patients can be informed of such promotional packages only at the point of payment"; referral incentives: "Licensees and/or authorised person are allowed to provide incentives for referral programmes. However, advertisements of such referrals are not allowed as they may induce consumption of the service." "Patients can be informed of such programmes only at the point of payment" | MOH FAQ | Statute text | 0.4, 1.2, 1.3, 5.1, 5.4 |
| Reg 16(1)(a)(i), 16(3) outbound links (the MOH FAQ text writes "Regulation 17(1)(a)", which is a slip in the FAQ: regulation 17(1) is the general duty to correct and has no (a) sub-item); 16(2) is the defence of not having known when the link was created | "a hyperlink which contains non-factual information about the healthcare service provided by the licensee could potentially be a contravention under Regulation 17(1)(a)... Where the licensee becomes aware of a non-compliant hyperlinked website, the licensee must immediately remove the contravening hyperlink..." | MOH FAQ | Statute text | 1.5, 5.2 |
| Reg 5(1)(e) (for hyperlinked pages, see also 16(1)(e)); MOH FAQ Annex A Table 1, the laudatory terms table (a non-exhaustive list, 40-plus entries in the full table) | FAQ body text: "laudatory statements are strictly prohibited, regardless of whether they are factually accurate or not". Listed in the table exactly as written: "Best e.g. options, available techniques" "Extensive experience" "Fully experienced" "Highest volume e.g. surgeon, precision" "Leading" "Only e.g. expert, key opinion leader" "State-of-the-art e.g. technology" "Latest e.g. version, technology, innovations, evolution, breakthrough" "Cutting-edge" "Five star services" | MOH FAQ | Statute text | 1.5, 1.6, 3.3, 6.1, 6.2, B.3 |
| Exemption Order (S 1034/2021), paragraph 4, the pure-directory exemption | MOH FAQ: "Pure directory listings comprising only factual contact details of licensees and/or other businesses/occupants listed, e.g. building directories." The Exemption Order's paragraph 4(2) sets three conditions: "the listing relating to a licensee in a directory must contain only contact information about the licensee" "the directory must list all licensees — (i) by name in alphabetical order; or (ii) in numerical or other sequential order" "the directory must not give greater prominence to the listing relating to any licensee relative to the listing relating to any other licensee". A paid "featured" or "pinned to top" placement is not covered by the exemption | MOH FAQ; SSO S 1034/2021 | Statute text | 6.2 |
A.2 SDC ECEG, SMC ECEG and SMC documents
What you'll do in this section: when you check the bans on testimonials, before-and-after photos, promotions, comparisons and title layout, come here to check the SDC / SMC original sentences and links. The Circular 2/2022 row is labelled Original text not obtained: write titles only from the register fields, and do not use that row as a basis for judging questions on testimonials, titles and the like.
The original sentence for SMC ECEG G2(7) comes from the verbatim quotation of it in the SMC Advisory of 2020-11-25. The MOH FAQ also quotes this clause under Reg 14, changing the grammatical person in square brackets and leaving out "about yourself".
| Rule number | Original sentence | URL | Label | Used in |
|---|---|---|---|---|
| SDC ECEG 5.4.2 | "In general, dental practitioners may provide information about their qualifications (approved by SDC), areas of practice, practice arrangements and contact details. Such information should be factual, accurate, verifiable, without extravagant claims, not misleading, not sensational, not persuasive, not comparative, and not disparaging." | SDC ECEG | Statute text | 0.2, 1.3, 1.5, 1.6, 3.2 |
| SDC ECEG 5.4.3 | "A dental practitioner must ensure that he/she does not solicit or encourage the public to seek consultation or treatment from him/her or the organisation he/she is associated with. Only the dental practitioner's name, registered field of practice and place of practice may be mentioned in such instances." | SDC ECEG | Statute text | 6.4 |
| SDC ECEG 5.4.3.2 | "If case studies, images (for example, photographs, videos, graphics, animation), devices, models or other props are used to illustrate or explain dental procedures or treatments or their outcomes, dental practitioners must ensure that it is for educational purposes and not used gratuitously. These must not be used in such a way as to exaggerate the quality of their services or to mislead the public into thinking that they are making a claim or guarantee of their expected results." | SDC ECEG | Statute text (the original sentence covers props such as case studies, images, devices and models); the ban on result guarantees in written copy that 1.6 derives from it: Conservative line (not statute text) | 1.6 |
| SDC ECEG 5.4.5 | "Dental practitioners who have any financial or professional relationship with organisations offering dental services have responsibility for the organisation's information output about themselves... it will not be sufficient for the dental practitioner to plead lack of awareness of the nature or the content of the organisation's information... or lack of ability to exert any influence over it." | SDC ECEG | Statute text | 1.4, 3.2 |
| SDC ECEG 5.4.6(a) | "Dental practitioners may advertise by providing neutrally toned and objective information about their SDC-registered qualifications, experience, areas of practice and their expertise in procedures." | SDC ECEG | Statute text | 1.6, 3.2 |
| SDC ECEG 5.4.6(b) | "Dental practitioners must not use "before" and "after", or even only "after" images or information for medical advertising in the public domain as anecdotal cases create unjustified expectations of the results of treatment, which may vary." | SDC ECEG | Statute text | 1.4, 5.2 |
| SDC ECEG 5.4.6(e) | "Dental practitioners must not offer financial inducements such as free or discounted examinations or treatments... must not lure patients through time-limited special offers, tie-ups with unrelated commercial entities (such as credit cards) or offering gifts or other material incentives... must not offer medical services and products as prizes or gifts in any context." | SDC ECEG | Statute text | 1.2, 5.6 |
| SDC ECEG 5.4.6(f) | "Testimonials are subjective and must not be used in advertising on any media where the dental practitioner has any control over the content about himself/herself. Dental practitioners must not ask or induce their patients or anyone to write positive testimonials about themselves in any media." | SDC ECEG | Statute text | 1.4, 3.1, 5.2, 6.5 |
| SDC ECEG 5.4.6(g) | "Dental practitioners must not disparage other dental practitioners or their practices in their advertising and must not give any impression that they and their practice are superior in any way when compared to other dental practitioners who provide similar services." | SDC ECEG | Statute text | 0.2, 1.3, 1.5 |
| SDC ECEG 5.4.6, final paragraph | "the following guidelines are recommended: the websites must not have on its web pages or provide hyperlinks to commercial companies, testimonies from satisfied patients or colleagues." | SDC ECEG | Statute text (covers dentists only); for the 5.15 aesthetic-clinic page: Conservative line (not statute text) | 1.5, 5.2, 5.15, 5.17 |
| SMC ECEG G2(7) | "Testimonials are subjective and must not be used in advertising on any media where you have any control over the content about yourself. You must not ask or induce your patients or anyone to write positive testimonials about you in any media." (quoted verbatim via the SMC Advisory) | smc.gov.sg/publications-and-newsroom/announcements/advisory--medical-practitioners--participation-in-online-search-engine-optimisation-platforms/ | Statute text | 1.4, 6.5 |
| SMC Advisory (2020-11-25) | "Medical practitioners should refrain from participating in online Search Engine Optimisation platforms that make use of patient feedback and ratings, as these feedback and ratings can be considered to be patient testimonials which are forbidden under the circumstances stated in G2(7) of the Singapore Medical Council (SMC) Ethical Code and Ethical Guidelines..." "In particular, medical practitioners should not be paying for such services by purchasing packages from these platforms for the purpose of obtaining patient testimonials, as payment for such packages or services could be considered to be express agreement on the part of medical practitioners to allow patient testimonials to be part of their publicity and medical advertisement activities." | same as the row above | Statute text | 1.4, 6.2 |
| SMC Circular No. 2/2022 | Title layout rule: titles from a Singapore university may be placed before the name, and every other title only below the name; no title that is not legally held may be used, and nothing may imply specialist status that has not been accredited. This sentence is paraphrased; the circular's original text was not opened and checked directly | smc.gov.sg (specific circular page to be verified) | Original text not obtained | 3.2 |
Circular 2/2022: before launch, legal must pull up the circular's original text, check it clause by clause and give a written sign-off. Until that check is done, copy the titles on doctor pages exactly as the two registers below show them.
Register lookup pages (taken from the register lookup links on the SDC and SMC official websites; check date 2026-09-23): dentists prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SDC; doctors prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SMC.
A.3 HSA, PDPA and cross-border
What you'll do in this section: when a clinic also sells skincare or health supplements, when a review reply touches a patient's identity, or when you are putting up a Chinese- or Indonesian-language page, come here to check the sources for the HSA, PDPA and cross-border rules. Indonesia's medical advertising law is labelled Original text not obtained: verify it separately before launch, and do not use this table as the conclusion.
| Rule number | Original sentence | URL | Label | Used in |
|---|---|---|---|---|
| HSA · advertising for therapeutic products and health supplements | Must not claim to prevent, relieve or cure a regulated disease; labels and advertisements must not be false or misleading; the penalty for a false advertisement is a fine of up to S$5,000 or up to 2 years' imprisonment (our paraphrase; the HSA's original sentence was not obtained). On the point that this falls under HSA, the MOH FAQ's original wording: "Advertisements of health and medicinal products, including those issued by direct-to-consumer companies, are regulated by HSA under relevant legislation such as the MASA or the Health Products Act (HPA)." | hsa.gov.sg/therapeutic-products/advertisements; hsa.gov.sg/health-supplements/overview/; MOH FAQ | Statute text (falls under HSA); the ban on efficacy claims: Conservative line (not statute text); the penalty figure: Original text not obtained | 0.2, 5.15 |
| PDPA · the sensitivity of health data | Confirming in a public reply to a review that "this reviewer is our patient" and restating the treatment they received counts as disclosing personal health data without consent; the patient writing it in their own review does not mean the organisation has authorisation to confirm it publicly. No specific PDPA section number was obtained; this is a compliance judgement, not a verbatim quotation of a rule | pdpc.gov.sg (specific clause page to be verified) | Conservative line (not statute text) | 5.18, 6.5, B.2 |
| China's Advertising Law (2021), Article 9 | The original wording is "国家级、最高级、最佳等用语" (terms such as national-level, highest-level or best, and the like), banning absolute terms; the matching penalty is RMB 200,000–1,000,000 (paraphrased; the penalty clause's original sentence was not obtained) | chinalawtranslate.com/advertising-law-2021/ (English translation) | Statute text (the Article 9 wording); the penalty figure: Original text not obtained | 1.6, 5.3 |
| Whether Article 9 applies to overseas operators | For overseas operators targeting Chinese consumers, enforcement in practice runs through the platforms — this sentence is inferred (70% confidence), not a scope of application that the statute itself states | same as above | Conservative line (not statute text) | 5.3 |
| SAMR's Enforcement Guidelines on Absolute Terms in Advertising | Not every expression containing "最" (most) or "第一" (first / No.1) is unlawful: for wording that points to the operator itself rather than the product, that states a sequence in time or space, or that is limited to a specific scope and can be proven by the operator, there is room for it not to be treated as a violation | SAMR's official website (specific page to be verified) | Original text not obtained (not used as a basis for relaxing the rule) | 1.6, 5.3 |
| Local regulation does not relax because the buyer is overseas | The licensee is local and the service is provided locally, so a page aimed at foreign buyers is still governed by the full set of bans; a medical-tourism page must not add before-and-after photos on the grounds that "this page is for foreign readers" — inferred (85% confidence): no rule granting an exemption based on the audience's location was found, and under the regulator's own position, the internet (including social media and websites) all counts as a regulated medium | No separate rule; for the regulator's position on media, see the Reg 6 row in A.1 | Conservative line (not statute text) | 5.3 |
| Indonesia's medical advertising law | Current confidence: to be verified; what exists so far is only a directional judgement — enforcement targets entities within Indonesia, and the mechanism is revoking the local Indonesian licence — this is not a verified conclusion | to be verified | Original text not obtained | 5.3 |
