Last checked against the official texts on 26 October 2026. This is general information, not legal advice; see the note at the end.
AI assistants answer health questions by quoting and summarising web pages. Anything a hospital or clinic publishes can reach patients without the page around it, and most of what a provider says about its own services counts as advertising under the rules below. In Singapore, the agency that writes the content can be held liable along with the provider.
This guide sets out the rules in Indonesia, Malaysia and Singapore, with the article or section behind each point and links to the official texts. The last section describes how GTMLab reviews every piece of healthcare content it works on.
The rules side by side
| Topic | Indonesia | Malaysia | Singapore |
|---|---|---|---|
| Main rules | Minister of Health Regulation 1787/2010 | Medicine Advertisements Board (MAB) guidelines, plus the Malaysian Medical Council (MMC) guideline for doctors | Healthcare Services (Advertisement) Regulations 2021 |
| Approval before publishing | No approval step. A Ministry of Health team reviews ads, and the ministry can order changes | MAB approval for anything that promotes a medical skill or service, unless exempt | No approval step. The provider and its agency are responsible |
| "Best", "only", "leading" | Banned | Website copy must avoid laudatory remarks, and the MMC calls claims to be the best or the only one unethical | Banned |
| Comparisons with other providers | Banned | Banned | Banned |
| Before-and-after images | Not named. We treat them as creating false expectations, which is banned | Banned | Banned, and after-only images too |
| Patient testimonials | Banned in ads and mass-media publications | Only about the premises (cleanliness, hospitality, surroundings), never about treatment or a doctor's skill | Only unpaid, unedited reviews given directly to the provider, shown on its own premises, website or social accounts |
| Discounts, gifts, services at no charge | All sales promotions banned, discounts included | Packages and discounts allowed. Services at no charge, gifts and price comparisons banned | Gifts or benefits tied to what a patient buys are banned |
| Cross-border advertising | Advertising health services at facilities located outside Indonesia is banned | Foreign providers cannot apply for approval. A Malaysian facility's ads abroad must also meet Malaysian rules if people in Malaysia can see them | Covers any ad a person in Singapore can see, including a provider's website aimed at foreign patients |
| Penalties | Order to fix within 7 working days, then licence suspension of up to one year, or revocation | Offence under the Medicines (Advertisement and Sale) Act 1956, and MMC discipline for doctors | Fine of up to S$20,000, jail of up to 12 months, or both, plus up to S$1,000 a day while the offence continues |
Indonesia
The rule and its status
The rule is Peraturan Menteri Kesehatan No. 1787/MENKES/PER/XII/2010 tentang Iklan dan Publikasi Pelayanan Kesehatan, published in Berita Negara 2010 No. 673. It covers advertising (iklan) and publication (publikasi) of health services, including traditional and complementary-alternative medicine (Pasal 2). Publication includes news, banners, running text, articles and features (Pasal 7(2)), so the rules reach well beyond paid ads. Ads must also follow the Indonesian hospital code of ethics, each health profession's code of ethics, and the advertising industry's code (kode etik pariwara) (Pasal 3(2)).
The 2023 Health Law (UU 17/2023) revoked the 2009 Health Law and the 2009 Hospital Law that this regulation was made under. Regulations made under the revoked laws stay in force where they do not conflict with the new law, and we found no instrument revoking Permenkes 1787/2010 as of 26 October 2026. The advertising articles we found in the 2024 implementing regulation (PP 28/2024, Articles 424 and 425) deal with medicines, medical devices and household health products. Check the Ministry of Health's legal database (JDIH) for anything newer before you rely on this regulation.
What every ad must include
Ads and publications must carry accurate data or facts, be evidence-based, and be informative, educational and responsible (Pasal 4(1)). Ads in print, electronic or outdoor media must give the facility's name and address and the publication date (Pasal 4(2)). We treat websites and social media as electronic media.
What is banned
Under Pasal 5, an ad or publication must not:
- be offensive or tasteless, or lower the standing of the health professions (a)
- give untrue, false, deceptive or misleading information (b)
- imply that the facility offers benefits other facilities cannot, or create unrealistic expectations of its services (c)
- compare its service quality with another facility's, or disparage another facility (d)
- praise itself excessively, including superlatives and claims to be the only one (satu-satunya) in quality, uniqueness or technology (e)
- promote new or unconventional methods, drugs, devices or technology whose benefit or safety the medical community has not accepted (f)
- advertise health services or health workers at facilities located outside Indonesia (g)
- advertise unlicensed health workers or facilities (h)
- advertise drugs, supplements or medical devices that lack a marketing authorisation or fail quality and safety standards (i)
- advertise formula milk or addictive substances (j)
- advertise prescription drugs, psychotropics or narcotics, except in medical magazines or scientific forums (k)
- present information in a way that encourages people to use the facility's health workers (l)
- advertise sales promotions of any kind, including discounts, rewards for using a service, and multi-level marketing (m)
- carry testimonials in ads or mass-media publications (n)
- use academic titles or health-profession designations (o)
Health workers and online channels
Doctors and other health workers must not advertise, or appear as models in ads, for drugs, medical devices, health supplies or health facilities, except in public service ads (Pasal 8(1)). They may publish about health services and research in health magazines or professional scientific forums (Pasal 8(2)). Public service ads must not show brands, devices, supplies or facilities (Pasal 9(3)).
A facility's internet ads and publications must not be used as a channel for remote medical consultation (Pasal 10).
Enforcement
The Minister of Health can set up a team that reviews ads before and after they run, advises on draft material, investigates complaints, and refers facilities and health workers to the professional ethics and discipline councils. Provincial health offices do the same in their regions (Pasal 11 and 12).
The Minister or the provincial health office can order an ad changed, withdrawn, removed or stopped within 7 working days. If the order is ignored, the sanction is suspension of the facility's operating permit or the health worker's licence for up to one year, or permanent revocation (Pasal 14). Ethics and discipline councils can add their own sanctions.
Malaysia
The rules
- The Medicines (Advertisement and Sale) Act 1956 and the Medicine Advertisements Board Regulations 1976.
- The MAB's Advertising Guidelines for Healthcare Facilities and Services (private hospitals, clinics, radiological clinics and medical laboratories), amended by MAB 3/2023 and in force since 5 July 2023.
- The MAB's Policy and Decision (Services), in the version dated 15 May 2025.
- The MMC guideline The Dissemination of Information by Medical Professionals Including on Social Media (V2/2025), endorsed by the Council on 19 August 2025, and the MMC notice of 25 November 2025 on doctors' photos.
- The private healthcare facilities law (the Private Healthcare Facilities and Services Act 1998 and its regulations, as quoted in both the MAB and MMC guidelines), which bars advertising that misleads the public about the type or nature of a facility's services, or that breaks a direction from the Director-General of Health.
Approval comes first
Unless an exemption applies, an ad may run only after the MAB approves it (guideline 1.3). Only private hospitals, clinics, radiological laboratories and medical laboratories may advertise their services (MAB 1/2004). An application needs the annual practising certificate issued by the MMC, so the MAB does not accept applications from other countries (MAB 7/2004).
The MAB's working rules:
- one ad format, or one social media post, per application (MAB 4/2016)
- a social media logo or link may appear in an ad only if the application quotes the approval serial number (KKLIU) of the post it points to (MAB 2/2017, amended by MAB 1/2023)
- an ad in any language other than Bahasa Malaysia or English needs a translation into one of them, vetted by the MAB secretariat and certified by an embassy or high commission, the Malaysian Institute of Translation and Books (ITBM) or the Malaysian Translators Association (MAB 2/2016)
- an approved ad can be amended once, within two months of approval, and changes to prices, hours, validity period, company details, layout or the approved web address need only a written notice (MAB 7/2006)
- statistical claims should be supported by Malaysian data unless none exists (MAB 5/2011)
- aesthetic medicine ads must list the doctors involved with their qualifications and aesthetic training (MAB 7/2007)
- appeals go to the Minister, whose decision is final (MAB 3/2013)
What needs no approval
Under section 3 of the guideline, these can run without MAB approval:
- ads that mention no skill or service for treating, preventing or diagnosing a condition, such as room rates, or a general line like "you are in safe hands"
- directional road signs
- seminar and public talk announcements limited to the topic, date, venue, speaker's name and place of practice, a photo no larger than a third of the format, and a contact
- educational articles, as long as they do not steer readers to the author's practice: only the doctor's name, registered field of practice and place of practice may appear, and photos of doctors performing procedures on patients are prohibited
- announcements of recognised certification (ISO, hospital accreditation, national or international quality awards) and congratulatory messages on a new wing, branch or facility, limited to the name, the date and a picture
What an approved ad may say
Section 4 allows the facility's name, location, phone number, hours, accommodation, facilities and charges; photos of doctors no larger than a third of the format; the professional services offered; and doctors' names, qualifications and specialties, for information only. Promoting an individual doctor's skill, knowledge or experience is not allowed.
Testimonials and endorsements
Patients may speak about the premises (cleanliness, staff hospitality, surroundings), never about treatment or a doctor's skill (4.5). Celebrity endorsements follow the same limit, and the guideline counts athletes, models, influencers, healthcare professionals and patients receiving treatment as celebrities (4.6). Actors or models may play doctors and patients if the ad carries the MAB's set statement that the image is for illustration only (MAB 12/2007, amended by MAB 1/2025).
What is not allowed
- direct or implied comparisons between facilities (5.1)
- before-and-after pictures (MAB 2/2019)
- price comparisons for the same service, such as the same package from a medical officer and from a specialist (7.1.2)
- offering services or treatments at no charge (7.1.3), and gifts of any kind (7.2)
- promoting CSR or charity programmes for marketing. Government aid schemes such as PEKA B40 may be advertised with a set statement (MAB 3/2023, amended by MAB 1/2025)
- photos of tissue specimens, or of patients with diseases, displayed as posters on a clinic's outside walls (5.5)
Packages, discounts and price reductions are allowed (7.1.1).
Websites, media and advertising abroad
Websites must present the facility, its services and its doctors (names, photos no larger than a third of the format, qualifications, specialties) in an informative and simple way, without laudatory remarks (6.8). Approved ads can run in any media based, registered, published or circulated in Malaysia (6.1). Directories may list a facility's name, address, specialty, contact details and hours (6.4). Brochures, pamphlets and leaflets must show their publication date (6.5).
A Malaysian facility advertising in another country must follow that country's rules, and if the ad can also be seen in Malaysia, online for example, it must meet the Malaysian guideline as well (9.1).
Doctors
The MMC guideline and the Code of Professional Conduct bind every registered doctor:
- Claiming to be the best or the only one in a field is unethical, and claims of "firsts" or "breakthroughs" are contentious (2.6).
- Doctors must not advertise to obtain patients or for professional advantage, sanction notices that promote their own skills or run down colleagues, or use agents or canvassers to obtain patients (3.2, citing the Code of Professional Conduct 2019).
- Articles by a doctor for the public may give the author's name, a brief note of qualifications and place of practice, without emphasis, and must not carry laudatory references to the author's status or experience (4.14).
- Doctors in active practice should give press interviews on diseases and treatment through an association or institution, and they are responsible for what the interview says (5.7).
- On social media, direct or indirect advertising for personal gain, including patient solicitation and self-promotion, is not appropriate, and shared health information must be accurate and evidence-based (6.5 and 6.7).
- Photos or images of doctors in ads, banners or billboards outside hospital premises are not permitted, whether the facility or the doctor puts them up, and breaches can lead to disciplinary action (MMC notice, 25 November 2025).
Penalties
Publishing an unapproved ad for a medical skill or service is an offence under the 1956 Act (sections 4A and 5), and doctors involved face MMC discipline.
Singapore
The rules
Section 31 of the Healthcare Services Act 2020 (HCSA) and the Healthcare Services (Advertisement) Regulations 2021, in force since 3 January 2022 and last amended with effect from 26 June 2023. The Ministry of Health (MOH) explains how it reads them in published answers on ask.gov.sg.
Who may advertise, and where the rules reach
Only a licensee, or a person acting on a licensee's authority, may advertise a licensable healthcare service (HCSA s.31(1)), and both must make sure the ad meets the rules (s.31(2)). MOH confirms that third parties acting for a licensee, agencies included, can be held liable. A publisher that only places an ad, without preparing or influencing its content, is an "authorised publisher" and falls outside most of the regulations (reg 2 and 3(4)).
The rules cover any ad that a person physically in Singapore can access, or that is aimed at people the advertiser knows are there (reg 3). MOH says a provider's website is covered even when it targets foreign patients.
Content
An ad must be factually accurate and capable of being substantiated, and must not be exaggerated, false, misleading or deceptive (reg 5(1)(a)). It must not:
- be offensive, ostentatious or in bad taste, or undermine the honour and dignity of a healthcare profession
- imply results other providers cannot achieve, create unjustified expectations, compare service quality with another provider, or disparage another provider
- show a person's appearance before and after, or only after, treatment (these may still be shown to a patient during a consultation, reg 5(2))
- contain laudatory statements, including claims of prominence or uniqueness, or superlatives
- contain reviews, testimonials or endorsements, except as regulation 14 allows
- present information in a way that amounts to soliciting or encouraging use of the service
Media
Outside the provider's premises, ads may appear only in newspapers, directories, medical journals, magazines, brochures, leaflets, flyers, pamphlets and on the internet, including apps. Sending ads by push technology, or handing out advertising material at no charge, needs the person's prior written consent. Brochures, leaflets, flyers and pamphlets must carry a publication date (reg 6).
Reviews
A provider may show a review only if a patient, next of kin or carer gave it directly to the provider, was not paid or rewarded for it, and the provider did not substantively edit it. The review may appear only on the provider's premises, website or social media accounts, and must not be reproduced (reg 14). Reviews of assisted reproduction services may not be shown in those places either (reg 14(2A)).
MOH says paid reviews are banned even when the sponsorship is disclosed, and that unpaid reviews patients post on third-party sites on their own initiative are not advertising.
Awards
A provider may mention an accreditation, award or other honour only on its premises, website or social media, and only when the honour recognises technical standards in its services. An authorised person, such as an agency, must not publish a provider's honours in any medium (reg 13).
MOH treats a third party's list of licensees that received honours as advertising, so an organisation that is neither a licensee nor acting for one breaches s.31(1) by publishing it.
Interviews and promotions
A provider may agree to interviews that media organisations request, but must not solicit an interview or have anyone solicit one for it. Anything said in an interview to promote the service must meet the content rules (reg 9).
No programme may offer patients a gift or benefit based on the value or type of service they buy. Payment plans may be advertised only at the point of payment. CSR programmes may be advertised if every ad says it is a CSR programme, the provider and its partners draw no direct financial benefit from the ads (agency fees are allowed), and the programme is not used to find new patients (reg 15).
Links, corrections and other rules
- Joint promotions with another business must still meet the content rules (reg 7).
- A public thank-you for a donation or sponsorship may name only the provider's business name (reg 10).
- Providers must not solicit filming on their premises, and film credits may show only the business name (reg 11).
- A provider's website must not link to a site that breaks the content rules, and such a link must be removed immediately once the provider or its agency knows about it (reg 16).
- When a provider learns of a non-compliant ad, it must take reasonable steps to fix or withdraw it and prevent a repeat, and tell the agency involved, which must act and report back (reg 17).
Exemptions and penalties
MOH lists these as exempt: pure directory listings with factual contact details only, directional signs, publicity for public-good causes such as blood and organ donation, and materials on national health programmes. They must still be accurate and not misleading.
Breaches are offences punishable by a fine of up to S$20,000, jail of up to 12 months, or both, plus up to S$1,000 a day for a continuing offence (HCSA s.31(3) and reg 18). The Director-General of Health can order an ad altered, withdrawn or discontinued (reg 17(8)).
Doctors are also bound by the Singapore Medical Council's Ethical Code and Ethical Guidelines. MOH cites its section G2(7), under which doctors must not use testimonials in advertising they control, or ask patients to write positive ones.
What this means for content written for AI search
Generative engine optimisation (GEO) aims to get a provider named and cited in AI answers. Several of its usual tactics run straight into the rules above.
Replace adjectives with facts
A page titled "best hospital for knee surgery" breaks the superlative ban in Indonesia and Singapore, and Malaysia's rule against laudatory website copy. Write what the claim stands in for: the procedures offered, the team's registered specialties, accreditations held where the country allows them to be named, opening hours and, where allowed, prices.
Educational pages are still covered
Indonesia's rules cover articles and features as well as ads. Malaysia exempts educational articles from approval only while they stay educational, and treats features with promotional elements as ads (guideline 2.6 and 3.4.3). In Singapore, an ad is any information that promotes a licensed service, directly or indirectly (reg 2). Keep condition and treatment explainers clear of prices, offers and booking prompts, and run them through the same content checks as service pages.
Markup and metadata count
Schema markup, page titles, meta descriptions, image alt text and FAQ answers are published text, and search engines and AI tools read them along with the page. Keep superlatives out of them. Leave review and rating markup off provider pages: Indonesia bans testimonials in publications, Malaysia bans treatment testimonials, and Singapore bans reproduced reviews. In Singapore, name honours in markup only where reg 13 allows them on the page.
Earned mentions need a playbook per country
In Singapore, rule out paid reviews (disclosed or not), rewards for reviews, pitching journalists to interview a provider's doctors, and publishing the provider's awards on its behalf. Reviews that patients post elsewhere on their own initiative are fine. In Malaysia, interview content must stay educational, the doctor answers for it, and doctors' photos stay off ads, banners and billboards outside the hospital. In Indonesia, testimonials stay out of publications, and health workers cannot front ads.
Audit links in Singapore
A provider's website must not link to a page that breaks the content rules, such as a news story that calls the provider the best (reg 16). Check "as featured in" sections and press pages before launch and on a schedule.
Award sites need legal advice in Singapore
MOH treats a third party's list of licensees that received an award as advertising, which only a licensee or someone acting for one may publish. Award sites, and "best of" lists that work like awards, should get legal advice before they cover Singapore providers.
Medical travel content has to satisfy two countries
Indonesia's regulation bans advertising health services at facilities located outside Indonesia (Pasal 5(g)), which is what a campaign by a Malaysian or Singaporean hospital aimed at Indonesian patients does. The hospital's home rules still apply wherever the content can be seen at home (Malaysia guideline 9.1; Singapore reg 3 and MOH's answer on foreign patients). How Indonesia enforces its ban against foreign hospitals and their local partners is a question for an Indonesian lawyer, and it should be answered before a campaign runs.
Translations need certification in Malaysia
An ad in Chinese, Tamil, Indonesian, Arabic or any language other than Bahasa Malaysia or English needs a translation into one of them, vetted by the MAB and certified, as part of the approval (MAB 2/2016).
How GTMLab reviews healthcare content
This process covers every piece of healthcare content GTMLab writes, edits or publishes for a client: web pages, articles, social posts, ads, video scripts, outreach emails, schema markup, and AI-facing text such as FAQ pages and llms.txt files. It applies whenever the content can be seen in Indonesia, Malaysia or Singapore.
- We fix the countries before we write. Every brief records where the client is licensed, which countries the content targets, and which countries can see it. Where more than one country applies, we follow the strictest rule on each point. Content aimed at patients in another country needs written sign-off from the client's legal adviser in that country before it runs.
- We log every claim in a claims register. Each factual statement, such as a number, an outcome, a piece of equipment, an accreditation or a doctor's qualification, goes in with the document that supports it. If the client cannot produce a source, the claim does not go out. Statistics for Malaysian clients use Malaysian data where it exists.
- We check every line against our banned-content list. The list covers superlatives and uniqueness claims in English, Bahasa Indonesia and Bahasa Malaysia (best, leading, number one, only, first, most advanced, terbaik, satu-satunya, pertama, tercanggih); comparisons with other providers, including price comparisons; promised or implied results; before-and-after and after-only images; testimonials and endorsements beyond what each country allows; discounts, gifts and services offered at no charge where the country bans them; calls to action that push people to use a service; academic titles and professional designations in Indonesian ads; and doctors' photos in Malaysian ads, banners or billboards outside the hospital. The same check confirms that required details are present, such as the facility's name, address and publication date on Indonesian ads, and the publication date on brochures and leaflets in Malaysia and Singapore.
- Education stays apart from promotion. Condition and treatment explainers carry no prices, offers or booking prompts, and they name the author with their registered field of practice. Pages and ads that promote a service get the full check, and for Malaysian clients they go to the MAB.
- Malaysian ads run only after MAB approval. We prepare the submission, and the client, as the licensed facility, applies. We publish the approved version word for word and log its approval number. Any later change goes back to the client for a new approval, or for the written notice the MAB requires. We have translations certified before the client submits them.
- Markup follows the page. Schema markup repeats only approved text that is visible on the page. We don't add review or rating markup to provider pages, don't mark up honours that the country's rules keep off the page, and keep superlatives out of titles, meta descriptions and alt text.
- We don't manufacture third-party signals. We don't write, buy or edit reviews, or offer patients anything for one. We don't use influencer or celebrity content that endorses a treatment. For Singapore clients, we don't run review-request campaigns, pitch journalists to interview the client's doctors, or publish the client's awards ourselves. When a journalist asks for an interview, we help the client respond.
- We audit outbound links. Before launch and every quarter after, we crawl the client's site for outbound links and remove any that point to pages breaking the content rules.
- Two people at GTMLab and one at the client sign off. A second GTMLab reviewer, who did not write the piece, checks it against the claims register and the banned-content list. The client's medical or compliance lead then approves it before it goes live. We keep a record of who approved which version and when, for as long as the content is live and for two years after it comes down.
- We fix problems within one working day. If we or the client find something that breaks these rules, we take it down or correct it within one working day, tell the client in writing what changed, and log it. The same applies when a regulator orders a change.
- We re-check the rules every six months. We review the sources behind this guide every six months and whenever a regulator issues new rules, and we update the date at the top of this page.
Sources
All links were checked on 26 October 2026.
Indonesia
- Peraturan Menteri Kesehatan No. 1787/MENKES/PER/XII/2010 tentang Iklan dan Publikasi Pelayanan Kesehatan, Berita Negara 2010 No. 673
- UU No. 44 Tahun 2009 tentang Rumah Sakit, status page in the BPK legal database, showing it revoked by UU No. 17 Tahun 2023
- Hukumonline: the 11 laws revoked by the 2023 Health Law, including which implementing regulations remain in force
Malaysia
- MAB, Advertising Guidelines for Healthcare Facilities and Services, amendment MAB 3/2023
- MAB, Policy and Decision (Services), 15 May 2025
- MMC, The Dissemination of Information by Medical Professionals Including on Social Media, V2/2025
- MMC, notification on pictures of registered medical practitioners outside hospital premises or on billboards, 25 November 2025
- Medicines (Advertisement and Sale) Act 1956 (Revised 1983)
The Ministry of Health's pharmacy site did not respond from our location on 26 October 2026, so we read the two MAB documents from Internet Archive copies of the same files, captured on 28 June 2025 and 13 May 2026. We could not open the 1956 Act itself. The section numbers cited for it come from search-indexed text of the ministry's published copy and should be checked against the Act.
Singapore
- Healthcare Services (Advertisement) Regulations 2021, current version as at 26 October 2026
- Healthcare Services Act 2020, section 31
Ministry of Health answers on ask.gov.sg:
- Can third parties be held liable?
- Why are paid reviews prohibited?
- What to do about existing paid reviews
- Are paid reviews allowed if the sponsorship is disclosed?
- Unpaid reviews on third-party sites
- Testimonials in annual reports and programme booklets
- Third-party lists of licensees that received awards
- Ads targeted at foreigners outside Singapore
- Advertising in other jurisdictions for medical tourism
- Advertisements exempted from the regulations
A note on this guide
This guide summarises published rules. It is general information, not legal advice, and it does not cover every rule that may apply, such as data protection law or the advertising policies of Google and Meta. Rules change, and how they apply depends on the facts. Before you publish, check the current text with the regulator, or ask a lawyer qualified in the country concerned.
Last checked: 26 October 2026. Next scheduled check: April 2027.












