Aesthetic medical clinics frequently publish testimonials written by laypersons or KOLs on their official websites or social media pages, often accompanied by before-and-after photos and a one-click booking option. Such content is approachable and persuasive, readily capturing the attention of poten
Aesthetic medical clinics frequently publish testimonials written by laypersons or KOLs on their official websites or social media pages, often accompanied by before-and-after photos and a one-click booking option. Such content is approachable and persuasive, readily capturing the attention of potential consumers. From a regulatory perspective, however, most of these testimonials are likely to be classified as “medical advertising” and must comply with stringent legal requirements. This article summarizes the relevant regulations for the reference of clinics and marketing teams.
I. What Constitutes “Medical Advertising”? Substantive Solicitation Is the Key, Not the Label.
Under the Medical Care Act and interpretive rulings issued by the Ministry of Health and Welfare, any use of media to “promote medical services” or “solicit patients” constitutes medical advertising. This applies even if the content is presented under the guise of “sharing,” “columns,” “unboxing,” interviews, or reader submissions. In other words, the legal characterization depends on the function and substance of the content, not on how it is labeled.
II. What May Be Published and What May Not Be Stated
Compared to print advertisements, online medical advertising is subject to relatively fewer restrictions and may include information about the institution and personnel, descriptions of services, and general medical or health knowledge. Nevertheless, once any of the following “red lines” is crossed, the content enters a high-risk zone of non-compliance: 1. Superlative or “guarantee” language: such as “the only one,” “first of its kind,” “most professional,” “guaranteed cure,” “results in one session,” or “no recurrence.” 2. Price promotions: such as “limited time,” “early-bird discounts,” “raffles,” “free treatments,” “group buys,” or “zero-interest installments,” which use financial incentives to attract patients.
3. Before-and-after (BA) images used as a traffic-generation tool, particularly where such images are placed alongside “book now” buttons or promotional codes to stimulate immediate booking. 4. Insufficient risk disclosure: showcasing results without adequately explaining indications, contraindications, side effects, or variations in outcomes. 5. Unverifiable or unapproved claims: asserting the use of technologies or medical devices not yet approved, or using phrases such as “first in the country” to inflate expectations.
III. Compliance Considerations for “User Testimonials”
From a marketing standpoint, testimonials remain highly persuasive. To mitigate legal risk, a “three-step” approach is recommended: Step One: Change of perspective — promotion vs. patient education: replace exaggerated promotional language with an educational, patient-centered narrative.
Step Two: Supplemental information — clearly explain the risks: explicitly list contraindications (e.g., pregnancy, coagulation disorders, etc.), common side effects (e.g., redness, swelling, bruising, pain, pigmentation risks, etc.), and variability in outcomes (affected by age, skin condition, and lifestyle). Step Three: Removal — eliminate high-risk language: delete phrases such as “limited-time discounts” or “free treatments.” If before-and-after images are used, do not display them with booking links. Written patient consent must be obtained, and the scope of use should be clearly specified.
IV. Establishing “Compliance-Oriented Marketing”: Marketing cannot be avoided in aesthetic medicine, but persuasion must be grounded in verifiable facts and full risk disclosure. The best practice is to establish a standardized marketing SOP. For example, implement dual controls for keywords and ad placements: Google and Meta ad copy should not include discount or guarantee language, and all content should be screened against a prohibited-terms list prior to publication.
When the content genuinely places patient interests at its core, regulatory compliance will follow as a natural consequence.
