What are Dubai's social media advertising rules for clinics?
Every clinic and healthcare professional licensed by the Dubai Health Authority (DHA) has to follow DHA's Standards for Medical Advertisement Content on Social Media, code DHA/HRS/HPSD/ST-21, whenever they promote a service online. The version in force is 1.1, effective since 3 October 2022, and DHA sent it again to every private health facility in Dubai by circular CIR-2026-00000144 on 17 August 2026. It bans 21 named words, from "the best" to "immediate results", and says that list is not complete. It requires written consent for every patient photo, video and statement, a fixed sentence on every before and after image, the clinic's MOHAP advertising licence number on its official account, and the Medical Director's approval for posts that name the clinic. WhatsApp counts as social media. BTR Consult read the standard clause by clause and checked 17 Dubai clinic websites against it on 6 October 2026. Here is what each rule means for the person posting.
Which words can't a Dubai clinic use in its posts?
Clause 6.11 bans "absolute statements, exaggerated claims and alarming expressions such as, but not limited to" these 21: unique, one of a kind, the best, exclusive, safest, the only, incomparable, unprecedented, best product, magic, miraculous, assured success, very limited quantity, has no side effects, get money back, 100%, absolutely certain, distinguished, famous, pioneer and immediate results.
"Not limited to" matters. A word that is not on the list can still break the rule if it makes the same kind of claim. Appendix 1 adds more examples of what is not acceptable: calling a treatment "infallible, unfailing, magical, miraculous or a certain, guaranteed or sure cure", claiming "exclusive or unique skill", and pressure phrases such as "don't delay", "achieve the look you want" and "looking better and feeling more confident".
What works instead is a fact a patient can check: the clinician's licensed title, the treatments you offer, how long a procedure takes, what recovery involves, and the risks. The standard asks for exactly that. Content has to show "all risks and benefits; advantages and disadvantages" (7.1.3).
What did BTR Consult find on 17 Dubai clinic websites?
On 6 October 2026 BTR Consult read the websites of the dental practices and aesthetic clinics that came up first on Google Maps for "dentist Dubai Marina" and "aesthetic clinic Jumeirah" in our September study. That gave 17 distinct websites. We read each homepage and one linked treatments, gallery or about page, as text. Words inside images were not read. A website is not social media, so these figures show how clinics market themselves, not whether any of them broke ST-21.
| What we looked for | Clinic websites |
|---|---|
| Used at least one word from the 6.11 list about themselves | 12 of 17 |
| Called themselves "best" (7 of them in the page title) | 9 of 17 |
| Used "exclusive" | 5 of 17 |
| Showed patient reviews or testimonials | 16 of 17 |
| Showed before and after images | 10 of 17 |
| Of those 10, carried a "results may vary" statement | 1 of 10 |
| Of those 10, used the exact 9.6 wording | 0 of 10 |
| Showed any licence number | 12 of 17 |
The pattern is the point. The habits clinics carry on their own websites, "best" in the page title and before and after galleries without the required sentence, are the ones the standard rules out the moment the same content goes onto Instagram, TikTok or a WhatsApp status.
Do you need patient consent for testimonials and photos?
Yes, in writing. Clause 9.1 says "written consent shall be obtained and documented" from anyone whose pictures, images, videos or statements appear in a social media advertisement. Consent covers only the subject and the period it was given for (6.10.1), and has to follow DHA's patient consent standard (9.2). For anyone under 18 you need verifiable consent from a parent (8.1.12). Appendix 2 lists "patient testimonials without written patient consent" as prohibited. Sixteen of the 17 clinic websites we read showed reviews or testimonials. Nobody can tell from a public page whether the consent forms exist, so the practical question for an owner is simple: for every patient face, voice or quote you have posted, can you produce the signed form?
How must before and after photos be shown?
- Both photos show the same person.
- Both are taken with the same lens.
- No editing software, filters or retouching.
- The post carries this sentence: "there is no guarantee that the result will be the same, as it might vary from one individual to another".
- The post also states the risks.
- The sentence and the risks are in the same font size as the rest of the post.
Those six points are clause 9.6. Appendix 2 adds that the images may only show patients who had the treatment advertised. Of the 10 clinic websites with before and after images, one carried a "results may vary" line and none used the 9.6 sentence.
Does the standard cover WhatsApp?
Yes. The definition of social media in ST-21 names Facebook, Instagram, Twitter, Reddit, Pinterest, Flickr, WhatsApp, YouTube, Snapchat and LinkedIn, and says it is not limited to them. A promotional broadcast, a status update or a message in a patient group sits inside the same rules as an Instagram post. That matters in Dubai: when BTR Consult checked on 6 October 2026, 14 of the 16 Dubai clinic homepages we could read linked straight to WhatsApp.
What has to be on the clinic's own accounts?
- The MOHAP advertising licence number on the clinic's official account (5.2). On their websites, 9 of the 17 clinics showed an MOH or MOHAP number, 3 a DHA-labelled number and 5 no number at all.
- The Medical Director's approval for any post that promotes a service or outcome and names the clinic or its location, whoever posts it: doctors, influencers or front-desk staff (5.3).
- Responsibility for anything filmed on your premises, including on staff phones and by influencers (5.5).
- Separate professional and personal accounts for clinicians, with no contact with current or past patients on personal accounts (7.1.2).
- Only the title on the DHA licence. Titles such as "Aesthetic Specialist" or "Cosmetologist" are out unless that is the licensed title (6.1), and "Dr" is for physicians, dentists and recognised doctorate holders (6.2).
What about prices and offers?
The standard does not ban prices. Appendix 1 rules out price information that is inaccurate, that fails "to specify any conditions or variables to an advertised price", or that offers time-limited discounts that cannot be met. Eight of the 17 clinic websites showed prices, a price list or offers, and seven used discount or promotion wording. If a post shows a price, say what it includes and any conditions.
What happens if a clinic breaks the rules?
Version 1.1 names no fine. It tells each Medical Director to "communicate the potential penalties for social media violations with all employees" (7.1.11), asks clinics to archive posts with their edits for audit, and says DHA "may conduct SMA audit" (7.1.13). Press reports in early September 2026 said clinics that break the rules face disciplinary action. Those reports describe enforcement, they do not add rules beyond the published standard.
The BTR 10-point check before a clinic posts
- No word from the 6.11 list, and nothing that makes the same kind of claim.
- No promise of results, recovery time or "no side effects".
- Risks stated alongside benefits.
- Signed, dated consent on file for every patient face, voice or quote.
- Before and after: same person, same lens, no editing, the 9.6 sentence and the risks, same font size.
- No comparison with another clinic or clinician.
- Prices with their conditions, and no offer you cannot honour.
- The clinician's licensed title only.
- Medical Director approval if the post names the clinic or its location.
- The post archived with its edits.
Where BTR Consult fits
BTR Consult sets up a clinic's Google profile, pages and WhatsApp assistant around these rules on its UAE plans, and flags anything we see that may need attention. The clinic stays responsible for its own compliance. See what we run for dental practices in the UAE and aesthetic clinics in the UAE, or start with the free BTR Signal Score to see what patients see when they search for a clinic like yours.
This is a plain-language summary of DHA/HRS/HPSD/ST-21 version 1.1, read on 6 October 2026. It is not legal advice. DHA's current published standard always applies.
Frequently asked questions
Do the DHA social media rules apply to WhatsApp?
Yes. The standard defines social media as including Facebook, Instagram, WhatsApp, YouTube, Snapchat and LinkedIn, among others. Broadcast messages, status updates and group posts that promote a clinic are covered.
Can a Dubai clinic call itself the best?
Not in a social media advertisement. Clause 6.11 of the DHA standard lists "the best" among 21 absolute and exaggerated terms that must not be used, and says the list is not complete.
What must a before and after photo say?
Clause 9.6 requires the statement "there is no guarantee that the result will be the same, as it might vary from one individual to another", plus the risks, in the same font size as the rest of the post. The photos must show the same person, taken with the same lens, with no editing software.
What is the penalty for breaking the DHA social media rules?
Version 1.1 of the standard names no fine. It tells Medical Directors to communicate the potential penalties to staff, and says DHA may audit social media advertisements. Press reports in September 2026 said clinics that break the rules face disciplinary action.