Last updated 1 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Rules are taken from the Healthcare Services Act 2020, the Traditional Chinese Medicine Practitioners Act 2000 and its regulations, the TCM Practitioners Board’s Ethical Code and Ethical Guidelines and Ministry of Health and HSA guidance as published in September 2026.
Traditional Chinese medicine is one of the most searched healthcare categories in Singapore. People look for acupuncture near their office, a physician for a child’s eczema, herbal support after a diagnosis. For a TCM clinic, digital marketing should be an easy win. In practice it is one of the most tightly restricted categories we deal with, and most of the restrictions are not where marketers expect to find them.
Many assume TCM clinics sit under the same advertising regulations as medical and dental clinics. They do not. The Ministry of Health has said TCM is not a licensable service under the Healthcare Services Act, so the Healthcare Services (Advertisement) Regulations that govern GP and dental clinic ads do not apply. But that does not leave TCM clinics freer. Since June 2023 a separate provision of the same Act has made it a criminal offence for a TCM clinic to advertise that it treats a condition. And the TCM Practitioners Board’s own code restricts testimonials, before-and-after photos, comparative claims and even where a clinic’s service information may appear.
This guide sets out the three layers of rules, how they apply to websites, search ads, social media and signage, and a checklist for clinics and the agencies that market them.
TCM in Singapore: who is regulated
According to the TCM Practitioners Board’s (TCMPB) annual report for 2025, Singapore had 3,615 registered TCM practitioners at the end of 2025: 3,349 TCM physicians and 266 acupuncturists. Physicians may practise general TCM, which includes acupuncture, diagnosis and treatment and herbal prescription. Acupuncturists are registered for acupuncture only.
The regulator for practitioners is the TCMPB, under the Traditional Chinese Medicine Practitioners Act 2000 (TCMPA). The products a clinic dispenses or sells, such as Chinese proprietary medicines, are regulated separately by the Health Sciences Authority (HSA). And the Ministry of Health (MOH) enforces the Healthcare Services Act provision on treatment claims. A single clinic Facebook post can touch all three.
Layer one: the ban on treatment claims
Section 31A of the Healthcare Services Act 2020 came into force on 26 June 2023. It says a person must not advertise “any skill or service relating to the treatment of any ailment, disease, injury, infirmity or condition” in a way that would induce anyone to seek advice or treatment from the advertiser. The only exemption is for licensees advertising their licensable services. Because TCM is not a licensable service, a TCM clinic cannot use it.
The penalty is a fine of up to $20,000, up to 12 months’ imprisonment, or both, plus up to $1,000 a day for a continuing offence. Section 31A(5) presumes that the person whose service is advertised is the advertiser, so a clinic cannot shift responsibility to the agency or freelancer who wrote the post. Under section 31C the Director-General of Health can order an advertisement to be rectified or withdrawn, and refusing is a further offence.
MOH has explained what this means in practice for TCM. In its answers on AskGov, it says advertisements by businesses that are not Healthcare Services Act licensees should not contain claims that their service can treat a condition, and that using TCM terminology for the condition does not change the position. A clinic may state factually which services it provides. It may not say those services treat a named condition. In a December 2023 reply, MOH put it plainly: only licensed entities can purport to treat or cure diseases, and offenders face warnings, composition or prosecution.
This provision replaced section 4 of the Medicines (Advertisement and Sale) Act, which was repealed on the same date. Older guides, and some official answers that predate the change, still cite section 4. The current rule is section 31A.
What that looks like in copy
| Risky | Safer |
|---|---|
| “We treat insomnia with acupuncture” | “Acupuncture consultations by registered acupuncturists” |
| “Cure your eczema naturally” | “TCM physician consultations, including herbal prescription” |
| “Our fertility programme helps you conceive” | “Consultations with a registered TCM physician. Appointments available on weekdays and Saturdays.” |
| “Relieve back pain in three sessions, guaranteed” | “Acupuncture and tuina services. Fees listed on our website.” |
The safer versions feel flat to a performance marketer, and that is the point. The law allows a TCM clinic to tell people what it offers, who provides it and how to book. It does not allow the clinic to sell an outcome for a condition.
Layer one, continued: who may advertise TCM at all
Section 24(1)(b) of the TCMPA makes it an offence to “advertise or otherwise hold himself or herself out to be qualified” to carry out a prescribed TCM practice unless the person is registered, holds a practising certificate and practises within the conditions of registration. Section 24(2) bars a clinic from employing unqualified people to carry out prescribed practice. The penalty is a fine of up to $25,000, up to six months’ imprisonment, or both, rising to $50,000 and 12 months for a repeat conviction. Under section 25, fees for work done in breach of section 24 cannot be recovered in court.
This is the provision that catches wellness centres, spas and beauty businesses that advertise “acupuncture” or “TCM therapy” performed by staff who are not registered. It is closely linked to the massage licensing rules, which exempt massage given by a registered TCM practitioner. Our guide to massage establishment advertising in Singapore covers that boundary.
Layer two: the TCM Board’s professional rules
The TCM Practitioners (Practice, Conduct and Ethics) Regulations set the frame. Regulation 5 says a registered practitioner shall not advertise their skills or practice, or endorse any TCM product, except in accordance with guidelines determined by the Board. Regulation 6 limits the qualifications that may appear on any card, stationery, nameplate, signboard, circular, handbill or notice to those on the Register or approved by the Board, and limits titles and designations to those the Board approves. Regulation 2(2) requires practitioners to comply with all Board standards.
The guidelines are in the Board’s Ethical Code and Ethical Guidelines (ECEG). The version on the TCMPB website is dated January 2006, and it remains the current edition. Its advertising rules are in section 4.4, with related rules elsewhere.
What information may say (4.4.1 and 4.4.2)
Practitioners may state their qualifications, areas of practice, practice arrangements and contact details. That information must be factual, accurate and verifiable. It must not be misleading, sensational, persuasive, laudatory, comparative or disparaging, and it must not make extravagant claims. It must not exploit patients’ vulnerability, ill-founded fears or lack of medical knowledge, and giving information must not become “blatant advertising in the commercial sense”. Section 4.3.2 separately bars canvassing or touting for patients and running down other practitioners, and section 4.1.1(e) bars offering treatment packages as a “guarantee of a cure”.
Websites (4.4.5)
The same standards apply to a practice website and to anything it links to. Websites may not carry testimonials from patients or other practitioners. They may not show photographs or videos of treatment results or procedures involving identifiable practitioners or patients, which rules out before-and-after galleries. General illustrations are allowed, but animation may not be used to promote the practice. Websites may not be sponsored by pharmaceutical or commercial companies.
Where service information may appear (4.4.3)
The code allows service information in professional and healthcare listings such as clinic directories and telephone directories. It does not allow service information to be listed in newspapers, commercial magazines, public displays or exhibits, radio or television. Practitioners must not advertise, personally or through proxies, by unsolicited visits or calls, public displays or active distribution of literature. Pamphlets may be placed in clinic or hospital lobbies only. When practitioners give media interviews or public talks, the content must stay on the health topic, only their name, registered area of practice and place of practice may be mentioned, and they are responsible for making sure journalists keep to these standards.
Responsibility for others’ publicity (4.4.4)
A practitioner associated with a TCM or medical organisation is responsible for that organisation’s publicity about them, and the code says lack of awareness is not a defence. For clinic owners and agencies this is the key rule. A marketing agency’s ad about Physician X is Physician X’s disciplinary problem.
Name cards, openings and signboards (4.4.6 to 4.4.8)
Name cards may be given only personally and on request. Practice openings or moves may be announced to people with a connection to the practice and on the practice’s own website, but not on other kinds of websites. Signboards may show only the clinic’s English and Chinese names and logo, with no reference to equipment, specialities or organs, a maximum of 6 m² at the front and rear entrances, and no luminous paint or flashing lights. The practice name itself needs Board approval.
Titles
The Board’s approved titles, listed in an annex to the code, are “Acupuncturist” or “Registered Acupuncturist” for acupuncturists, and “TCM Physician”, “Registered TCM Physician” or “Registered Chinese Medicine Physician” for physicians. “Specialist” and a bare “physician” are not on the list. The Healthcare Services Act separately regulates use of the title “Doctor” in advertising, and MOH has said registered TCM practitioners with a valid practising certificate are covered by that framework only where the qualification or title they use is one the Board has approved. The practical rule for marketers is to use the approved titles and to check any other title or qualification against the Register before it goes into copy.
How the Board enforces
Breaches of the regulations, professional misconduct and improper conduct are grounds for discipline under section 19 of the TCMPA. The Board can censure, issue a letter of advice, impose conditions for up to three years, suspend registration for up to three years or remove a practitioner from the Register. The financial penalty is up to $50,000 for conduct on or after 1 April 2020.
The Board’s published case studies include two advertising matters from 2017. In one, a practitioner promoted a clinic at an event, including handing out promotional treatment vouchers, and received a one-month suspension, a $2,000 penalty and a censure for the promotional breach. In the other, a practitioner used the title “Professor” after an earlier warning and received a $1,000 penalty and a censure. We found no advertising-related disciplinary decisions published for 2023 to 2026, which suggests most issues are resolved before they reach an inquiry. It does not mean the rules are dormant.
Layer three: herbal products and proprietary medicines
If a clinic sells products as well as consultations, a third rulebook applies. Section 3 of the Medicines (Advertisement and Sale) Act 1955 bars anyone from taking part in publishing an advertisement for an article as a medicine or remedy for 19 scheduled conditions, including cancer, diabetes, hypertension, kidney diseases, infertility, impotency and menstrual disorders. HSA also requires a permit before any medical advertisement or sales promotion for Chinese proprietary medicines is directed to the general public, and the definition of sales promotion in the regulations includes price discounts. Our guide to health product advertising in Singapore covers the permit regime in detail.
HSA’s enforcement shows why this matters. In March 2026 it warned about four products, including two with Chinese names, sold at makeshift stalls and on online marketplaces for knee pain and weight loss with “no side effects” claims. Testing found undeclared steroids and other banned ingredients, and three people had suffered adverse effects. “No side effects” and “natural” are exactly the claims clinic marketers are tempted to make about herbal products.
Applying the rules channel by channel
The Board’s code was written in 2006, before social media and paid search. It does not name them. The analysis below applies the code’s website rules and general standards, together with the statutory provisions, which apply to every channel.
Website and SEO
A clinic website is the safest and most important channel. Build it around factual service pages: what acupuncture, tuina or herbal consultation involves, who the practitioners are with their approved titles and registration, fees, hours and location. Educational content about TCM concepts is fine if it stays general and does not become a claim that the clinic treats a condition. Our guides to SEO for clinics and content marketing for clinics cover the medical-clinic side of the same problem.
The SEO challenge is obvious: people search by condition. An article explaining how TCM understands sleep is educational. A landing page titled “Insomnia treatment in Tampines” that pushes bookings is an advertisement for a treatment service under section 31A. Condition keywords belong in general education, not in commercial pages.
Google Business Profile and reviews
A Business Profile is a directory-style listing, which the code allows. Keep the category, description and services factual. Reviews that patients post themselves are not testimonials the practitioner publishes, but quoting them on the website, embedding them or reposting them is. Do not ask patients to mention conditions or results.
Paid search and social ads
Paid ads are where the code is least clear and the statutory risk is highest. Ad text is short and outcome-led by habit, which is exactly what section 31A prohibits. If a clinic runs paid ads at all, keep them to the factual pattern: service, practitioner type, location, booking. Avoid condition keywords in ad copy and headlines, never promise results, and do not run discount-led campaigns for consultations that the Board could view as commercial touting.
Social media and influencers
Treat social accounts like the website: no testimonials, no before-and-after images of identifiable patients, no comparisons with other clinics and no treatment claims. Paid influencer visits are the highest-risk format, because an influencer describing how a treatment fixed their condition is a testimonial published on the clinic’s behalf, and section 4.4.4 makes the practitioner responsible for it. See our guide to influencer marketing in Singapore for disclosure rules generally.
Promotions and packages
The Board’s 2017 case involving promotional treatment vouchers at an event shows that discount-led promotion of consultations is a disciplinary risk. Treatment packages must never be framed as a guarantee of a cure. For product promotions, HSA’s permit requirement covers price discounts on Chinese proprietary medicines.
Worked examples
A neighbourhood clinic’s new website
A two-physician clinic wants a site that ranks. The service pages describe consultations, acupuncture and herbal dispensing factually. Each physician’s profile shows their approved title, registration and languages spoken. A general education section explains TCM concepts without linking them to bookings for named conditions. There are no testimonials, no patient photos and no animated promotion. The site is lean, but it is compliant and it can still rank on service and location terms.
A wellness centre adding acupuncture
A wellness centre wants to add “acupuncture” to its menu and promote it on Instagram. Before any copy is written, the question is who performs it. If the practitioner is not a registered acupuncturist or TCM physician with a practising certificate, advertising the service is a section 24 offence. If they are registered, the post must follow the Board’s standards, and the practitioner is responsible for how the centre promotes them.
A clinic selling a herbal product online
A clinic wants to sell its own-label herbal tea on its website with the line “supports healthy blood sugar”. Blood sugar points to diabetes, one of the 19 scheduled conditions, and the product advertisement falls under HSA’s rules. The copy should be rewritten, and the clinic should check with HSA whether the product needs a permit before any promotion.
A checklist for TCM clinic marketing
| Check | What good looks like |
|---|---|
| Treatment claims | No copy says a service treats, cures or relieves a named condition |
| Registration | Every practitioner named in marketing is registered with a practising certificate |
| Titles | Only Board-approved titles; no “specialist”, no unapproved “Dr” or “Professor” |
| Testimonials | None on the website, social accounts or linked pages, including influencer content |
| Images | No treatment result or procedure photos of identifiable patients or practitioners |
| Tone | Factual and verifiable; not comparative, laudatory or sensational |
| Channels | No service listings in newspapers, magazines, broadcast or public displays; no flyer drops |
| Promotions | No cure guarantees; care with discounts on consultations |
| Products | No remedy claims for scheduled conditions; HSA permit checked before promotion |
| Third parties | Agencies and influencers briefed in writing, with practitioner sign-off on every asset |
Frequently asked questions
Do the Healthcare Services (Advertisement) Regulations apply to TCM clinics?
No. MOH has said TCM is not a licensable healthcare service under the Healthcare Services Act, so those regulations do not apply. But section 31A of the same Act, in force since 26 June 2023, bars any business that is not a licensee from advertising that its service treats an ailment or condition, and that does apply to TCM clinics.
Can a TCM clinic say it treats a specific condition in an ad?
No. A TCM clinic may state factually which services it provides, but MOH has said it may not claim those services treat a condition, even using TCM terms. Breaching section 31A carries a fine of up to $20,000, up to 12 months’ jail, or both.
Can TCM clinics use patient testimonials?
No. The TCM Practitioners Board’s code bars testimonials from patients or other practitioners on practice websites and linked pages, and bars photos or videos of treatment results involving identifiable patients. The same standards are the safest guide for social media.
Can a TCM physician call themselves “Dr” in Singapore?
Only where the title or qualification is one the TCM Practitioners Board has approved. The Board’s approved designations include “TCM Physician” and “Registered TCM Physician”, and the Board has disciplined a practitioner for using the title “Professor”.
Can a wellness centre advertise acupuncture?
Only if the acupuncture is performed by a registered acupuncturist or TCM physician with a practising certificate. Advertising or holding out as qualified without registration is an offence under section 24 of the TCM Practitioners Act, with a fine of up to $25,000, six months’ jail, or both.
Who is responsible if an agency writes a non-compliant TCM ad?
The clinic and its practitioners. The Healthcare Services Act presumes the person whose service is advertised is the advertiser, and the Board’s code makes practitioners responsible for publicity about them by organisations they are associated with, with lack of awareness no defence.
The takeaway
TCM clinics in Singapore sit outside the medical advertising regulations and inside a stricter mix of rules. Section 31A of the Healthcare Services Act bans treatment claims outright. The TCM Practitioners Act makes advertising by unregistered practitioners a crime. The Board’s code rules out testimonials, before-and-after images, comparisons and much of traditional advertising, and it makes practitioners answer for what their agencies publish. HSA governs the products on the shelf. The clinics that grow online are the ones that treat these limits as the brief: factual service pages, strong practitioner profiles, useful general education and search visibility built on services and location rather than conditions.
Our performance marketing team builds healthcare campaigns with compliance review built in, and you can see how we report results in our client case studies. For the wider picture, start with our complete guide to performance marketing in Singapore, our guide to digital marketing for healthcare in Singapore, the rules for optical and contact lens advertising, and our checklist of legal requirements for business websites.
