Your hospital's advertising now needs a compliance owner

The National Medical Commission's public notice of 6 October 2026 brings a detailed advertising and public-communication framework to hospitals, medical institutions and registered medical practitioners. The signed notice says it takes effect immediately. Its reach includes websites, social platforms, search advertising, influencers and promotional material created with AI.

For hospital management, the immediate task is to identify the communications already carrying the institution's name. The main website may be only one part of that inventory. A consultant's campaign, an agency landing page or a partner's video can require the same attention.

Separate institutional information from a doctor's promotion

Clauses 8.3 and 9.1 permit factual, verifiable institutional information, including facilities, services, accreditation and charges. A hospital website's factual directory of doctors, qualifications, registration details and availability is distinguished from promotional advertising. The definition of hospital or medical institution includes outpatient establishments.

That permission has limits. Institutional communication must avoid patient solicitation, inducements, exaggerated claims and promotional portrayal of an individual doctor. Individual RMPs face their own restrictions on self-promotion, while defined educational communication and formal announcements remain permitted. Calling a campaign educational does not settle what its content and distribution actually do.

The institution's legal route also matters. Clauses 4.3, 10 and 11.5 refer hospital enforcement and appeals to the applicable Clinical Establishments legislation or other State law. RMP misconduct is addressed through the professional regulatory framework, with due process. The document's graded RMP sanctions should not be presented as an automatic nationwide hospital fine schedule.

Review the claim, the patient material and the payment arrangement

The guidelines address misleading claims, manipulated engagement, fake or paid reviews and patient material used for promotion. Patient consent alone cannot make an otherwise prohibited testimonial, success story or before-and-after depiction permissible. The RMP restrictions expressly cover requesting or sharing patient testimonials for professional promotion on social media.

Do not reduce the exercise to deleting a few adjectives. Clause 8.1(ix) qualifies comparative claims by verifiability, methodology and applicable law, while clause 8.3(ii) says institutional communication must not contain comparative superiority claims. An award certificate is therefore not a general clearance for a superiority campaign. Have disputed rankings and outcome claims reviewed against the whole document.

Similarly, the restriction on offers and discounts concerns inducements likely to encourage unnecessary care or amounting to patient solicitation; lawful fee disclosure must remain factual and transparent. Agency arrangements linked to procuring or referring individual patients are expressly addressed. Under clause 4.4, commissioning communication through an intermediary does not by itself remove responsibility for it.

AI disclosure is only one part of the review

Clause 7.2 prohibits AI-generated promotional campaigns furthering commercial interests. It also requires a source mark on AI-generated promotional content that otherwise conforms to the framework, and addresses deceptive representations, fabricated patient material and disclosure of materially artificial content. A label cannot cure a prohibited campaign.

The operational question is what the asset depicts and how it will be used. An invented patient endorsement, altered treatment result or synthetic clinician claiming qualifications requires more than a production-quality check. Patient information entered into an AI system is separately subject to applicable privacy and professional requirements.

Give the review an owner and a recoverable record

The following is Lifeline's operating recommendation. Assign a senior owner to bring marketing, the medical director and the institution's legal adviser into one review. Start with active paid campaigns and material promising outcomes, then work through service pages, directories, social accounts, messaging templates, brochures and partner content. Record the channel, commissioning party and person able to change or withdraw each item.

For each service description, keep the evidence marketing should use: the actual location, available service, responsible clinician, current credentials and scope of accreditation. Add the RMP identification and registration disclosures specified for electronic posts in clause 3.2. Check the wording against the current service approval file, especially where a treatment's permissible use and its advertising already need close scrutiny.

Before renewing an agency or platform arrangement, examine how payment is calculated, who approves copy and who can stop a campaign. Require delivery of the final published version, including captions, thumbnails and landing pages. Preserve the approval and correction history so a disputed statement can be traced without searching personal messages.

Finally, give the patient-facing teams the corrected information. A revised webpage achieves little if an enquiry script still promises the old result. Our growth and communication services can help organise that workflow; the hospital's clinical and legal reviewers should decide the permissibility of individual claims under the relevant professional and State framework.