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.

Resource · Cross-Market Compliance

Medical Advertising Rules,
Compared.

Before/after photos, testimonials, price advertising and more — what's allowed in clinic advertising across Malaysia, Singapore, Australia, Hong Kong and Taiwan, each answer traced to a named regulator document.

Quick answer: Before/after photos and patient testimonials are restricted or banned in all 5 markets we serve (Malaysia, Singapore, Australia, Hong Kong, Taiwan) — the one consistent rule across every jurisdiction. Price advertising, discount promotion and influencer disclosure vary more, with real gaps in what's publicly sourced for Hong Kong and Taiwan specifically.

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

Not allowed

AHPRA guidance prohibits before/after imagery that creates an unrealistic expectation of benefit for higher-risk cosmetic procedures.

Verified 2026-07-27 · source

Not allowed

Before/after comparisons implying treatment effect are prohibited, bundled with the testimonials restriction under UMAO.

Verified 2026-07-27 · source

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

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

Not allowed

Patient testimonials and recommendations are prohibited, the same restriction pattern as MY/SG under UMAO's own framing.

Verified 2026-07-27 · source

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

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

Not allowed

Exaggerated or superlative terms ("best", "only", "most effective", "guaranteed success") are prohibited outright.

Verified 2026-07-27 · source

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

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

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

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

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

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.

Unverified

Not covered by the sourced AHPRA/TGA advertising-content rule set. Not answered rather than guessed.

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:

Sources

Every non-"unverified" cell above traces to one of the following, each already independently sourced and staged at open-source-staging/compliance-rules/ in this project's own repo (a public mirror is pending — see seo/BLOCKED-ON-S.md) 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 data/moh-rules.json 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 data/hk-uma-rules.json's own per-rule disclosure, including the Schedule 1/2 gap already flagged in v37.
  • 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.

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