Insights · Regulation · UK, EU, US, Turkey

What a clinic may say in public: the advertising rules by market in 2026, and what they leave open

Clinic owners often believe the rules stop them saying anything. They stop clinics advertising in certain ways; they do not stop clinics informing. This guide sets out the main constraints market by market, as we understand them in August 2026, and then the set of assets that is permitted everywhere and happens to be what engines and careful patients reward. It is a statement of our practice, not legal advice; where your regulator or counsel is stricter, that rule applies.

Woman leaving a glass office building onto a London street, laughing with a colleague
POMPrescription-only medicines, botulinum toxin included, cannot be advertised to the public in the UK and EU
§11 HWGGermany prohibits before-and-after imagery for cosmetic surgical procedures; extended to injectables and avatars by courts in 2024–25
Nov 2025Turkey's new regulation: no testimonials, no influencers, no comparison claims, consent and disclaimers on imagery

The rules we apply everywhere

Before the differences, the constants. Silvengate's own copy and everything we write for clinics follows nine rules regardless of jurisdiction: no outcome claims about treatments; no pressure tactics (no countdowns, no scarcity, no discount urgency on procedures); no advertising of prescription-only medicines to the public in the UK and EU; before-and-after material only with written consent, where permitted, and never implying a typical result; reviews and testimonials only with consent and where permitted, never incentivised or edited; clinician sign-off on every clinical statement; our own commercial claims stated with baseline, timeframe and consent; no patient data in our analytics; and patient language in anything a patient could read. The strictest applicable rule wins.

United Kingdom

The CAP Code, enforced by the ASA, governs advertising; botulinum toxin is a prescription-only medicine and naming it, or a brand of it, in advertising to the public is a breach. Copy refers to a consultation for the concern ("lines", "wrinkles"), not to the product. The ASA also expects before-and-after material to be realistic and representative and restricts targeting of under-18s for cosmetic procedures. In August 2025 the Department of Health and Social Care confirmed a licensing scheme for non-surgical cosmetic procedures in England, with CQC-registered premises for higher-risk procedures and age restrictions, consulted on in early 2026; practitioner licensing status is becoming a trust signal worth publishing. The GMC and GDC set expectations for doctors' and dentists' claims, and the CMA has acted on fake and incentivised reviews.

European Union

Directive 2001/83 prohibits advertising prescription-only medicines to the public across the EU. National rules then vary. Germany's Heilmittelwerbegesetz (§11(1)) prohibits before-and-after images for cosmetic surgical procedures; the OLG Koblenz extended this to avatars in April 2024 and the BGH confirmed its application to cosmetic treatments including injectables in 2025. France's Code de la santé publique (L.6322-1) prohibits advertising for aesthetic-surgery establishments, although doctors may publish factual information since the 2020 reform, and the influencer law of 9 June 2023 bans influencers from promoting cosmetic procedures. Italy limits health advertising to informational content under its 2019 Budget Law. Spain permits health advertising with regional pre-authorisation for some categories.

United States

The FTC's truth-in-advertising standard applies, and its rule on fake reviews and testimonials took effect in October 2024, with penalties for purchased, incentivised or suppressed reviews. HIPAA requires written authorisation for patient photographs and testimonials. State medical boards regulate claims such as "board-certified" and medical-director arrangements. Platform policy bites as hard as law: Google forbids personalised and remarketing targeting for "invasive medical procedures, including cosmetic surgery, surgical procedures, or injections", and Meta's health and wellness data-source category restricts lower-funnel pixel events and custom audiences from January 2025.

Turkey

The Regulation on Advertising and Information Activities in Health Services (Official Gazette 33075, 12 November 2025) is among the strictest: no patient testimonials, no superiority or comparison claims, no influencers, before-and-after only with written consent, a capture date and a variance disclaimer, no intra-operative images, comments disabled on visuals, and paid social promotion largely prohibited domestically. International health-tourism promotion remains permitted when targeted abroad, in foreign languages, carrying the HealthTürkiye mark. For Istanbul and Antalya clinics, English, German and French trust content aimed at patients abroad is the channel the regulation leaves open.

What every market permits

Information. A page that explains what a procedure involves, who performs it and with what qualifications, what the risks are, how pricing works and what a consultation is like is informational in all seven jurisdictions above, provided it is accurate, signed off by the clinician and free of outcome promises. Clinician credential pages, consistent with the professional registers, are permitted everywhere. A consented review programme with answered reviews is permitted everywhere, provided nothing is bought or edited. These are also, not by coincidence, the sources an AI engine cites and the content a careful patient reads before booking. The constraint on advertising is an advantage in visibility for the clinic that publishes like a clinician.

What we do when a clinic asks for something over the line

We say what we can do instead and why the line exists. A request for "only 3 slots left" becomes a clear statement of how booking works and how long the wait is. A request to name the toxin brand becomes a consultation page for the concern. A request for a gallery in Germany becomes text-first proof: credentials, method, what to expect. The answer is rarely no; it is usually a different asset that does the same job and survives a regulator's look.

Questions this raises

Can a UK clinic mention Botox on its website?
Not in advertising to the public, and most of a website is advertising. Copy refers to a consultation for the concern. Prices for a consultation, and factual information about what happens in it, are permitted.
Are before-and-after photos allowed anywhere?
In the UK and US with written consent and representative framing; in Turkey with consent, a capture date and a variance disclaimer; not for cosmetic procedures in Germany; restricted in France. We default to the strictest rule that applies to the clinic's patients.
Do these rules apply to what an AI engine says about us?
No, and that is the point. Engines summarise what is published about you. Informational assets that are permitted everywhere are what they read.
Sources
  1. CAP Code and ASA rulings on prescription-only medicines and cosmetic procedures.
  2. UK Department of Health and Social Care, licensing scheme announcement, August 2025.
  3. Directive 2001/83/EC; German HWG §11(1); OLG Koblenz (April 2024); BGH (2025) via Library of Congress Global Legal Monitor, September 2025 (single-source).
  4. Code de la santé publique L.6322-1; French influencer law of 9 June 2023.
  5. FTC rule on fake reviews and testimonials, effective October 2024; HIPAA; Google Ads and Meta advertising policies, 2025.
  6. Republic of Türkiye, Official Gazette 33075, 12 November 2025.
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