Healthcare advertising: what your clinic can and cannot say

A clinic can run healthcare advertising on its website, on Google and on social media, but within 3 layers of rules. The law requires it to display its healthcare registration number and to advertise only what it is authorised to do, and it prohibits promising a cure. Each profession’s code of conduct limits prices, testimonials and case studies, and Google adds its own policies. Below you will find each limit with its rule, a table to review your website piece by piece and the list of mandatory details.

3 layers of rules that do not bind the same people

Before reviewing your texts sentence by sentence, it helps to know where each rule comes from. They do not bind the same people, and breaches are not penalised in the same way.

1. The law binds the clinic, whether it belongs to an individual professional or to a company. The key rules are the General Health Law (Ley General de Sanidad), Royal Decree 1907/1996 (Real Decreto 1907/1996) on advertising with health purposes and Royal Decree 1277/2003 (Real Decreto 1277/2003) on the authorisation of centres. In the Valencian Community, add Law 10/2014 on Health (Ley 10/2014 de Salud) and Decree 157/2014 (Decreto 157/2014). As for any business, the General Advertising Law (Ley General de Publicidad), the Unfair Competition Law (Ley de Competencia Desleal), the Consumer Protection Law (Ley de Consumidores), the Information Society Services Law (LSSI) and the GDPR (RGPD) also apply to you.
2. Professional ethics bind each registered professional (colegiado). Doctors, dentists, physiotherapists and psychologists each have their own code. The medical code binds all doctors, whatever the form in which they practise, and breaching it can be a disciplinary offence (art. 1 of the Code of Medical Ethics (Código de Deontología Médica)). If your clinic is a company, the code does not bind the company itself. It does bind the professionals who sign off the treatments and appear on the website.
3. Google’s policies are not law. But they decide whether your ad is published and whether a review stays up.

When something is our interpretation and not the text of a rule, we label it as a cautious approach.

What the law requires of any clinic, and what it prohibits

Advertise only what you are authorised to do, with your registration number

Every healthcare centre needs prior administrative authorisation to operate (art. 29.1 of the General Health Law). Only authorised centres may use terms in their advertising that suggest healthcare activity. That advertising must be limited to the authorised services and state the regional registration number (art. 6.2 of Royal Decree 1277/2003).

On the website, that translates into 3 tasks:

• The registration number, visible. The rule requires it to appear in your advertising and does not distinguish between formats. The cautious approach is to put it in the footer of every page: that way it also appears on the contact page and on your ads’ landing pages.
• A list of treatments that matches your authorisation. Royal Decree 1907/1996 says the same: a centre’s advertising must stay within its authorisation, and any other advertising needs prior and express authorisation (art. 6).
• Review that list this year. From 1 July 2026, Royal Decree 239/2026 updated several units, such as nutrition and dietetics or pain treatment. It now requires a person in charge with a specific qualification or specialty. The autonomous communities have one year to adapt centres’ range of services to those changes (second additional provision).

Any patient can check your authorisation in the national register of healthcare centres (REGCESS).

Aesthetics: the line between a healthcare centre and a beauty centre

Aesthetic medicine is a healthcare activity. Royal Decree 1277/2003 defines it as the unit in which a doctor carries out non-surgical treatments for aesthetic purposes (annex II, U.48).

A beauty centre without healthcare authorisation cannot use terms in its advertising that suggest healthcare activity (art. 6.2 of Royal Decree 1277/2003). Nor can it give the appearance of being a healthcare provider: the prohibitions of Royal Decree 1907/1996 extend to anyone who gives that appearance without being one (art. 5.3). That decree also lists beauty, slimming and aesthetic treatment centres among those that must keep their advertising within what has been authorised (art. 6.1).

Royal Decree 1907/1996 prohibits 16 types of healthcare advertising

Its article 4 prohibits advertising with alleged health purposes in 16 situations. These are the ones that affect a clinic most:

• Giving assurances of certain relief or cure (art. 4.4). “Guaranteed results” or “goodbye to pain for ever” are ruled out.
• Suggesting specific slimming properties (art. 4.2).
• Using authorisations or checks by health authorities as an endorsement (art. 4.5). Your registration number is a mandatory detail, not a quality seal.
• Presenting something as a substitute for a professional consultation (art. 4.15).
• Attributing preventive or therapeutic effects without sufficient and recognised evidence (art. 4.16).
• Using testimonials from professionals, celebrities or patients to encourage consumption (art. 4.7). We look at this separately, because its scope is the most disputed point.

In addition, all information must be transparent, accurate and truthful (art. 7.1). And no healthcare professional may lend their name or their profession to support prohibited advertising (art. 5.1).

A note on scope. Article 4 refers to “products, materials, substances, energies or methods” with alleged health purposes. Whether it covers all the treatments of an authorised centre is a matter of interpretation, although the title of the decree also mentions “activities or services”. The cautious approach is to treat its 16 situations as limits on all your advertising. The Unfair Competition Law reaches the same point by another route: falsely claiming that something cures is misleading in all cases (art. 23.3).

Medicines and medical devices: the case of Botox

Only medicines that do not require a prescription and are not publicly funded may be advertised to the public (art. 80.1 of the Medicines Guarantees Law (Ley de garantías de los medicamentos)). Botulinum toxin for aesthetic use is a prescription medicine, according to its entry in the AEMPS’s CIMA database. That is why “Botox” or the brand name of the medicine cannot be the selling point of a page, an ad or a post.

Google enforces this independently. Outside the United States, Canada and New Zealand, it does not accept prescription drug terms in ads or on landing pages (restricted terms policy). A treatment page with “Botox” in the title can block your campaigns.

Medical devices have a different rule. Advertising to the public is prohibited for devices that professionals apply directly (art. 38.9 of Royal Decree 1591/2009). Royal Decree 192/2023 repealed almost all of that decree, but kept its advertising rules until there is a specific regulation. Think of implants or fillers. The cautious approach: explain what material you use if it helps the patient decide, but do not turn the brand into the selling point.

Breaking the rules can cost you a fine of €3,005 or more

The health authority can require you to correct an advert. If you breach articles 4, 5 or 6 of Royal Decree 1907/1996 and do not comply with that requirement, it is a serious infringement (art. 8.2). The General Health Law punishes it with a fine of €3,005.07 to €15,025.30, which can be increased up to five times the value of the services concerned (art. 36.1.b).

The Valencian Law 10/2014 refers to those amounts (art. 103.1) and adds 2 situations that directly affect your website:

• Operating without authorisation, or changing the authorised conditions without permission, is a serious infringement (art. 101.1).
• Presenting healthcare staff falsely as regards their merits, experience or technical ability is a very serious infringement (art. 102.1). Very serious infringements carry fines of €15,025.31 to €601,012.10 (art. 36.1.c of the General Health Law).

The civil route is separate. The General Advertising Law considers advertising unlawful if it breaches the specific rules for a service (art. 3.d). The actions of the Unfair Competition Law can be brought against it, such as an injunction to stop it (art. 6.1). And if you are a registered professional, your professional association (colegio) can open proceedings against you.

The Valencian Community has no advertising pre-approval, but it does supervise advertising

The Generalitat (the Valencian regional government) has the power to regulate and supervise healthcare advertising, in line with the basic national legislation (art. 5.10 of Law 10/2014). Promotion and advertising that may pose a risk to health are subject to the intervention measures laid down by regulation (art. 83.2).

There is no longer any pre-approval (visado) of healthcare advertising, and the Valencian Regional Ministry of Health (Conselleria de Sanidad) does not list any register or procedure of its own for advertising:

• Decree 157/2014 repealed the decree that regulated the committees for pre-approving medical and healthcare advertising (sole repealing provision, point 2).
• The Conselleria’s list of official healthcare registers does not include any for advertising. Its catalogue of authorisation procedures does not include an advertising authorisation either.
• Supervision is carried out by the Service for the Authorisation and Registration of Centres (Servicio de Autorización y Registro de Centros). Its functions include supervising the healthcare advertising of authorised centres (function k).

It is not clear how, in this region, you apply for the prior authorisation that Royal Decree 1907/1996 requires for advertising that goes beyond your authorisation (art. 6.2). If this is your case, ask that Service first.

There are 3 recent documents worth knowing about:

• A new decree on centres. On 30 September 2026, the Conselleria opened the prior public consultation on a decree that will replace Decree 157/2014. It accepts contributions until 14 October 2026.
• An order for aesthetic medicine. In April 2026, the Conselleria put out to consultation an order on technical and healthcare requirements for centres that offer aesthetic medicine. The consultation summary refers to authorisation, equipment, staff and patients’ rights. It does not mention advertising.
• Instruction 4/2026 for dental clinics. It requires a sign at reception with the name of the person in charge of healthcare and of the other professionals. The sign goes next to the certificate of entry in the register (Instruction 4/2026). It refers to the premises, not the website. We apply it to the website in the guide to a dental clinic website. The cautious approach is for your team page to say the same as that sign.

Your code of conduct: prices, testimonials and case studies

This is where the rules change depending on the profession. This table summarises what each code says on the 3 points that raise the most questions.

There is a caveat on prices. The decisions of professional associations must respect the Competition Law (Ley de Defensa de la Competencia) (art. 2.4 of the Professional Associations Law (Ley de Colegios Profesionales)). That is why, in 2011, the Dentists’ Council considered several advertising rules in its code to be repealed, according to the notes in the text itself. The doctors’ and physiotherapists’ rules on prices are still in their codes. The cautious approach: if your code keeps them, consult your professional association before publishing rates.

If you publish prices, give the final price including taxes (art. 20.1.c of the Consumer Protection Law; art. 10.1.f of the LSSI). Aesthetic treatments have a catch. The VAT exemption for healthcare covers the diagnosis, prevention and treatment of illnesses (art. 20.Uno.3.º of the VAT Law (Ley del IVA)). If a treatment is subject to VAT, the advertised price must include it. Confirm this with your tax adviser.

In a clinic with several professions, each professional answers to their own code. The physiotherapy code says so expressly: its advertising rules also extend to clinics and companies (arts. 76.4 and 77.2 of the national code).

Testimonials and Google reviews: where the line is

The law and the codes limit patient testimonials in advertising. Google reviews are something else, until you turn them into advertising.

What the law says. Royal Decree 1907/1996 prohibits using testimonials from real or supposed patients as a means of encouraging consumption (art. 4.7). We have already seen that its scope as regards the services of an authorised centre is disputed. We have not found any guidance from the Conselleria that clarifies it.

What the codes say. There is less doubt here. Doctors must not use real patients to encourage consumption (art. 89.3). Dentists must not exploit a clinical success for advertising purposes (art. 87.3). And the Valencian physiotherapists’ code leaves claims about successes out of advertising (art. 52).

What reviews are. A review on your profile is written by the patient on a Google platform. It is not your advertising. Asking for reviews is allowed, within limits: Google prohibits offering incentives, discouraging negative reviews and asking only people who are happy (Google Maps policy). The Unfair Competition Law also prohibits publishing or commissioning fake reviews (art. 27.8).

Reviews carry weight in Maps. Google explains that their number is part of prominence, one of the factors in its local rankings (Business Profile Help). That is why a system for asking for them is part of any local SEO work for a clinic.

Where the line shifts. When you copy reviews onto your website, quote them in an ad or share them on social media, they become part of your advertising. The cautious approach:

• In ads and on social media, do not use quotes from patients.
• On the website, a link to your profile is better than a selection of compliments.
• If you show reviews, explain whether you check that they come from real patients and how you process them. They must also refer to services purchased or used in the previous 30 calendar days (art. 20.4 of the Consumer Protection Law). There is a model notice in how to get Google reviews.
• Never with a full name, a photo or health data.

When you reply, no health data at all. Patients have the right to the confidentiality of their health data (art. 7.1 of Law 41/2002). The Spanish Data Protection Agency (AEPD) fined an ophthalmology institute €7,000 for replying to a review with data about the person who wrote it, including health data (PS/00122/2023). A safe reply thanks the person for their opinion, does not confirm that they are a patient and offers a private channel.

Yes, no and with care, part by part of your website

This table is for reviewing your website, your ads and your profiles. Abbreviations: RD 1907 is Royal Decree 1907/1996 and RD 1277, Royal Decree 1277/2003. LSCV is the Valencian Law 10/2014 on Health; LGM, the Medicines Guarantees Law; LCD, the Unfair Competition Law; LGDCU, the Consumer Protection Law. CDM is the medical code; CED, the dental code; EOE, the dentists’ Statutes. CDF is the national physiotherapy code; CFCV, the Valencian association’s code; CDP, the psychologists’ code. “Cautious” marks our own approach, not a rule.

Checklist: mandatory details on a clinic’s website

All of them are required by law, except the doctor’s specialty, which their code requires. In practice, it is best to bring them together in the footer, the legal notice and the team page.

1. The regional healthcare registration number in your advertising (Royal Decree 1277/2003, art. 6.2). Cautious approach: in the footer of every page.
2. Name or company name, address and email, and another means of direct contact (LSSI, art. 10.1.a).
3. The tax ID number (NIF) (LSSI, art. 10.1.e) and, if you are a company, your details in the Commercial Register (Registro Mercantil) (art. 10.1.b).
4. The details of your healthcare authorisation and of the body that supervises it, the Conselleria de Sanidad (LSSI, art. 10.1.c).
5. For each professional, their qualification, their professional association and their membership number (LSSI, art. 10.1.d). If they are a doctor, also the specialty registered with their association (CDM, art. 90).
6. Where each qualification was issued and its official recognition, if it is foreign (LSSI, art. 10.1.d.3.º).
7. The professional rules that apply to you and how to consult them. A link to each profession’s code in the legal notice covers this point (LSSI, art. 10.1.d.4.º).
8. If you publish prices, whether they include taxes (LSSI, art. 10.1.f). For patients, the full final price (Consumer Protection Law, art. 20.1.c).
9. If you show reviews, whether and how you verify them, and that they refer to the previous 30 days (Consumer Protection Law, art. 20.4).
10. Privacy information on every appointment form, because you collect data that may be health data (GDPR, arts. 9 and 13).
11. A list of treatments that matches your authorised range of services (Royal Decree 1277/2003, art. 6.2; Royal Decree 1907/1996, art. 6).

Recommended, though not mandatory: a link to REGCESS so that patients can check your authorisation.

Google Ads and social media: the same rules, and a few more

An ad or a post that promotes a treatment is healthcare advertising. Everything above applies to it, and Google and the social networks add layers of their own.

In Google Ads for clinics, 3 points account for most rejections:

• Prescription medicines. Out of the ads and also out of the landing pages, as we saw with Botox.
• Audiences. Google treats invasive procedures, such as cosmetic surgery and injections, mental health and fertility as a sensitive health category. In those campaigns you cannot use your own audiences, such as remarketing or patient lists (Health in personalised advertising).
• Experimental treatments. Google does not allow the promotion of speculative or experimental medical treatments (healthcare policy).

On social media, the risk is concentrated in 3 practices:

• Paid collaborations without a label. If you pay a creator, it must be clear that it is advertising (art. 26.1 of the Unfair Competition Law; art. 20.1 of the LSSI). The medical code also requires sponsorships and conflicts of interest to be declared (arts. 84.2 and 91.1).
• Giveaways. The medical code considers it contrary to ethics for a doctor to offer their services as a competition prize (art. 89.2). In other professions, if you give something away, the terms and conditions must be clear and accessible (art. 20.2 of the LSSI).
• Patients on video. An image showing someone receiving a treatment may reveal health data (GDPR, arts. 4.15 and 9). You need their explicit consent. Using their image for advertising purposes without express consent is an unlawful intrusion (Organic Law 1/1982, arts. 2.2 and 7.6). If you are a doctor, your code only allows patient information on social media for care, teaching or research purposes, and anonymised (art. 28.5).

What to do on Monday

1. Go to your website’s footer. Check the healthcare registration number, company name, tax ID number and the link to each profession’s code.
2. Put your authorisation decision next to your list of treatments. Remove anything that is not authorised. If you advertise nutrition or pain treatment, check who must be in charge under Royal Decree 239/2026.
3. Search your website, ads and social media for these words: “guaranteed”, “permanent”, “pain-free”, “100%”, “the best”, “Botox”, “kilos”. Rewrite every sentence that promises a result.
4. Review the team page. Membership number and qualification of each professional, and registered specialty if they are a doctor. Remove any merit you cannot prove. Since Royal Decree 239/2026, the centre must keep the information on all its healthcare staff up to date (art. 7.2 of Royal Decree 1277/2003): make sure the website matches it.
5. Go through before-and-after photos, testimonials and videos. If you do not have explicit written consent, take them down. If you are a doctor or a dentist, stop using them as a selling point even if you have it.
6. Read your last 20 replies to reviews. Edit the ones that mention a treatment or a patient’s data.
7. Before publishing prices, reread your code and, if in doubt, ask your professional association.
8. Give this table to whoever handles your marketing. Royal Decree 1907/1996 requires agencies and media to reject advertising that breaches it (art. 7.2). But the advertiser is your clinic.

If we work together at NOR studio, we prepare every text with these rules in front of us, and your clinic approves it before it is published. On our page for clinics and healthcare centres we explain how we approach a website that wins patients within these rules.