Draft — not yet published. This page is gated (noindex, not in sitemap.xml) until per-cell sourcing passes review. 14 of 40 cells are currently honestly marked "unverified" rather than guessed — see the notes in each cell.
| Question | Malaysia KKM/MOH (aesthetic) + MDC (dental) | Singapore MOH / HSA (Healthcare Services (Advertisement) Regulations 2021) | Australia AHPRA / TGA | Hong Kong UMAO (Undesirable Medical Advertisements Ordinance) + PDPO | Taiwan TFDA / Fair Trade Act / Consumer Protection Act |
|---|---|---|---|---|---|
| Can you use before/after photos in aesthetic clinic advertising? | Not allowed Restricted under KKM/MOH Aesthetic Medical Practice Guidelines — use educational/process visuals or practitioner credentials instead. Verified 2026-07-15 · source | Not allowed Prohibited under Regulation 5 of the Healthcare Services (Advertisement) Regulations 2021, with a narrow exception only for images shown privately during an actual consultation. Verified 2026-07-27 · source (opens in a new tab) | Restricted / conditional Allowed for higher-risk cosmetic procedures only under Ahpra's conditions: genuine, unedited, matched photos of the practitioner's own patient, the before image (or a combined image) first, the time since the procedure stated, a prominent warning that the outcome applies only to that patient, separate advertising consent, and never of anyone under 18. Predictive or AI-generated results are not allowed. Verified 2026-10-18 · source (opens in a new tab) | Restricted / conditional For doctors: the Medical Council of Hong Kong's Code of Professional Conduct (revised Oct 2022) bars information that is exaggerated or misleading or that generates unrealistic expectations (s 5.2.1), and allows no photographs in practice announcements in mass or social media (s 5.2.3.3). Before/after images that do this breach the Code. The source is the Code, not UMAO (Cap. 231). Dentists: Dental Council of Hong Kong code not checked. Verified 2026-10-18 · source (opens in a new tab) | Unverified No distinct before/after-imagery rule found in the sourced TFDA/Fair Trade Act/Consumer Protection Act rule set — the closest adjacent rule (improper-means-testimonial) covers testimonial framing, not photographic before/after comparisons specifically. Not answered rather than guessed. |
| Can you use patient testimonials in clinic advertising? | Not allowed Testimonials about clinical/aesthetic outcomes are restricted under KKM/MOH and MDC guidance — hard to verify and treated as an outcome claim. Verified 2026-07-15 · source | Not allowed Not allowed by default under Regulation 14; the narrow exception is a genuine, unpaid, unedited review appearing only on your own premises/website/social channels — never paid, influencer, solicited or reproduced testimonials. Verified 2026-07-27 · source (opens in a new tab) | Not allowed National Law s133 prohibits testimonials in health service advertising outright; AHPRA's Sept 2025 cosmetic-procedure guidelines extended this explicitly to re-shared patient stories and influencer testimonials. Verified 2026-07-27 · source (opens in a new tab) | Restricted / conditional For doctors: letters of gratitude or announcements of appreciation from patients must not be published in mass or social media (Medical Council of Hong Kong Code of Professional Conduct, revised Oct 2022, s 5.2.3.3), and information must not be exaggerated or misleading (s 5.2.1.2). The source is the Code, not UMAO (Cap. 231). Verified 2026-10-18 · source (opens in a new tab) | Restricted / conditional Pharmaceutical Affairs Act Article 68 prohibits publicising a medicament via an interview/news report or using another person's name to warrant efficacy; Article 70 treats such framing as an advertisement in its own right, needing the same prior approval as a direct ad. Verified 2026-07-31 · source (opens in a new tab) |
| Can you advertise a specific treatment price? | Not allowed Price-based inducements ("from RMx", limited-time discounts) for medical/aesthetic services are restricted — they can trivialise a clinical decision. Discuss pricing privately after assessment. Verified 2026-07-15 · source | Not allowed Regulation 5 requires exact, final prices — no "from", no crossed-out usual price, no percentage discounts, no time-limited pricing language. Payment plans may only be disclosed at point of payment. Verified 2026-07-27 · source | Restricted / conditional Not banned outright, but any discount/gift/inducement tied to a regulated health service must clearly state its terms and conditions in plain language — manufactured urgency around a clinical decision is separately discouraged. Verified 2026-07-27 · source | Unverified No distinct price-advertising rule found in the sourced UMAO rule set (which focuses on disease/treatment claims and testimonials) — not answered rather than guessed. | Unverified No distinct price-advertising rule found in the sourced TFDA/Fair Trade Act/Consumer Protection Act rule set — not answered rather than guessed. |
| Can you run discounts, gifts or package promotions for clinic treatments? | Not allowed Contests, gifts and manufactured urgency ("limited slots today") to drive medical bookings are restricted under KKM/MOH and MDC guidance. Verified 2026-07-15 · source | Not allowed Regulation 15 prohibits advertising any gift, freebie, lucky draw or voucher tied to purchasing a healthcare service; referral-reward programmes may only be disclosed at point of payment. Verified 2026-07-27 · source | Restricted / conditional Same rule as price advertising — a discount/gift/time-limited inducement must clearly state its terms, not be banned outright, but manufactured urgency around a clinical decision is discouraged. Verified 2026-07-27 · source | Unverified No distinct discount/package-promotion rule found in the sourced UMAO rule set — not answered rather than guessed. | Unverified No distinct discount/package-promotion rule found in the sourced rule set — not answered rather than guessed. |
| Can you use "specialist"/superlative claims ("best", "#1", "most advanced")? | Not allowed Unverifiable superlatives are discouraged under KKM/MOH guidance; MDC guidance additionally restricts a "specialist" title unless backed by the matching recognised qualification. Verified 2026-07-15 · source | Not allowed Regulation 5 bans laudatory/superlative terms even when truthful — the rule targets the promotional framing itself, not whether the claim is provable. Verified 2026-07-27 · source | Not allowed Since 1 July 2023, the title "surgeon" (incl. "cosmetic surgeon") is legally protected — only a practitioner with specialist registration in surgery, obstetrics/gynaecology or ophthalmology may use it; a cosmetic-surgery endorsement alone does not qualify. Verified 2026-07-27 · source (opens in a new tab) | Not allowed For doctors: information must not be exaggerated or misleading, compare with or claim superiority over other doctors, or claim uniqueness without proper justification (Medical Council of Hong Kong Code of Professional Conduct, revised Oct 2022, s 5.2.1.2). The source is the Code, not UMAO (Cap. 231). Verified 2026-10-18 · source (opens in a new tab) | Restricted / conditional Fair Trade Act Article 21 prohibits false or misleading representations able to affect a trading decision; the Fair Trade Commission's own guidelines give superlative terms ("No. 1", "champion") used without probative data as a typical violation example. Verified 2026-07-31 · source (opens in a new tab) |
| Can an influencer promote a clinic without disclosing it's paid? | Unverified The sourced KKM/MDC rule sets restrict patient testimonials generally but do not contain a distinct influencer-specific disclosure rule — not answered rather than guessed. | Not allowed Regulation 14's testimonial exception explicitly excludes paid reviews and influencer endorsements — an influencer testimonial for a healthcare service is restricted outright, disclosure or not. Verified 2026-07-27 · source | Not allowed AHPRA's Sept 2025 guidelines specifically strengthened the ban on influencer/social-media testimonials for cosmetic procedures — applies even when the practitioner didn't write the content and only re-shared or boosted it. Verified 2026-07-27 · source (opens in a new tab) | Unverified The sourced UMAO rule set bans testimonials generally but has no distinct influencer-disclosure rule — not answered rather than guessed. | Unverified The sourced rule set's testimonial rule (Article 68/70) covers interview/news-report framing but not influencer-disclosure specifically — not answered rather than guessed. |
| Can you name a specific prescription product (e.g. a Botox brand) in an ad? | Not allowed Advertising scheduled/prescription products to the public is restricted under the Medicines (Advertisement & Sale) Act 1956 — refer to the treatment category in general terms only. Verified 2026-07-15 · source | Not allowed Prescription-Only Medicines and Professional-Use-Only devices — explicitly including botulinum toxin (Botox) and hyaluronic-acid dermal fillers as named examples — may not be advertised to the public at all. Verified 2026-07-27 · source (opens in a new tab) | Not allowed The Therapeutic Goods Act 1989 prohibits advertising prescription-only medicines to the public, with very limited exceptions — this includes naming a specific prescription injectable or weight-loss medication brand. Verified 2026-07-27 · source (opens in a new tab) | Unverified No distinct prescription-product-naming rule found in the sourced UMAO rule set — not answered rather than guessed. | Restricted / conditional Not a naming-specific rule, but the closest sourced match: the TFDA has stated off-label promotion is not allowed (Letter No. 1101460212), upheld in a Taichung District Court case fining NT$200,000 for advertising a treatment beyond its approved indication under Pharmaceutical Affairs Act Article 68. Verified 2026-07-31 · source (opens in a new tab) |
| Does a clinic treatment purchase require a cooling-off period? | Unverified Not covered by the sourced KKM/MDC advertising-content rule sets — a cooling-off requirement (if any) would sit under general consumer-contract law, not clinic advertising rules, and was not researched for this page. Not answered rather than guessed. | Unverified Not covered by the sourced Healthcare Services (Advertisement) Regulations rule set, which governs ad content, not contract/consumer-protection cooling-off rights. Not answered rather than guessed. | Restricted / conditional For under-18 patients only: Ahpra's guidelines for practitioners who perform non-surgical cosmetic procedures require a cooling-off period of at least seven days between informed consent and the procedure, with no money payable before it ends (other than initial consultations). The non-surgical guidelines set no adult cooling-off rule. Verified 2026-10-18 · source (opens in a new tab) | Unverified Not covered by the sourced UMAO rule set. Not answered rather than guessed. | Unverified Not covered by the sourced TFDA/Fair Trade Act rule set — Consumer Protection Act cooling-off provisions (if applicable) govern direct-sales contracts generally and were not researched for this page. Not answered rather than guessed. |
Check your own ad copy
Every column above routes to a free self-check tool built against that market's own rule set:
- Malaysia: /tools/kkm-ad-checker (aesthetic clinics — dental clinics use /tools/mdc-ad-checker)
- Singapore: /tools/moh-ad-checker
- Australia: /tools/ahpra-ad-checker
- Hong Kong: /tools/hk-medical-ad-checker
- Taiwan: /tools/tfda-ad-checker
Sources
Every non-"unverified" cell above traces to one of the following, each already independently sourced and staged in our internal compliance-rules repo (a public mirror is pending — see the internal blockers list) or in this site's own checker tools:
- Malaysia — KKM/MOH Aesthetic Medical Practice Guidelines, the Medicines (Advertisement & Sale) Act 1956, and Malaysian Dental Council (MDC) guidance. Source: shakalakaa KKM Ad Checker / MDC Ad Checker rule sets.
- Singapore — Healthcare Services (Advertisement) Regulations 2021 under the Healthcare Services Act, HSA/MOH guidance for PHMCA/HCSA licensees. Regulation numbers (5, 13, 14, 15) cited via a secondary source after the primary regulation text blocked automated fetch — see the MOH rules dataset for the full per-rule disclosure.
- Australia — AHPRA's Cosmetic Procedure Advertising Guidelines (2 Sep 2025), the Therapeutic Goods Act 1989 (TGA), and National Law s133.
- Hong Kong — Undesirable Medical Advertisements Ordinance (UMAO) and the Personal Data (Privacy) Ordinance (PDPO). Sourced secondarily (schedule-summarized) after the primary ordinance text was not found at a stable, directly-fetchable URL this session — see the HK UMA rules dataset's own per-rule disclosure, including the Schedule 1/2 gap already flagged. Full section-by-section walkthrough with verification status per item is available in Traditional Chinese on our 香港醫療廣告與 PDPO 規則指南.
- Taiwan — Pharmaceutical Affairs Act (TFDA), Fair Trade Act, and Consumer Protection Act — all three fetched and read directly this session (verified, primary).
This page recombines rule sets already sourced and cited elsewhere on this site — see each rule's own source_url/source_note in the raw JSON for the exact citation, session-verified vs. secondary-sourced status, and last-verified date per cell, not per page.
What "unverified" means here
14 of 40 cells (8 questions × 5 markets) are marked unverified — most concentrated in the cooling-off-requirements row (5/5, since that's a consumer-contract question outside every sourced rule set's scope, not an advertising-content rule) and in Hong Kong/Taiwan's pricing and discount rows, where the sourced rule sets don't contain a distinct rule on that specific question.
An unverified cell means exactly that — not researched to a confirmed answer — never a guess dressed up as one.
- Cite this
- shakalakaa (Plixitt Solutions). “Medical Advertising Rules Compared: MY/SG/AU/HK/TW.”
- https://shakalakaa.my/resources/medical-advertising-rules-compared
- Licensed under CC BY 4.0.
- See the benchmarks