ASA Rules for Healthcare Websites: What Clinics Need to Know

Why the CAP Code covers your website

The UK Code of Non-broadcast Advertising and Direct and Promotional Marketing, usually called the CAP Code, applies to marketing communications, including those on a business's own website. Treatment pages, fee pages, home page claims and social media posts all fall within it. The ASA can rule against a clinic whose website breaks the Code and can ask for changes.

The ASA's healthcare overview says that section 12 of the CAP Code sets out the rules for marketing communications for health-related products and services, and points to separate guidance for claims that need clinical evidence and for avoiding claims that discourage essential medical treatment^[1].

The rules in section 12 that matter most

The rule wording above is quoted from section 12 of the CAP Code^[2].

Objective claims and evidence

An objective claim is one that can be tested: "reduces pain", "results in two weeks", "the most advanced scanner in the region". Rule 12.1 requires evidence for objective claims, and for health claims that usually means trials on people^[2]. The ASA's healthcare advice links to separate guidance on substantiating health, beauty and slimming claims^[1].

For a clinic website, the practical approach is to describe what a treatment involves and what it is designed to do, rather than to promise outcomes. "Physiotherapy sessions focus on restoring movement after knee surgery" describes. "Get back to full fitness in six weeks" promises. If you want to make an outcome claim, check first that you hold evidence that would satisfy the ASA, not just clinical experience.

The same care applies to page titles, image text and social posts that link to treatment pages, because patients read them as part of the same message as the page itself.

Not discouraging essential treatment

Rule 12.2 matters for clinics that offer services overlapping with NHS care, such as private GP appointments, physiotherapy or diagnostic tests^[2]. A page should not suggest that a patient can skip medical advice by using your service. It helps to include a short section on when to contact NHS 111, a GP or emergency services, and to avoid phrases that imply your service replaces a diagnosis.

Prescription-only medicines

Rule 12.12 is easy to break without realising. It covers botulinum toxin products, weight management medicines and any other prescription-only medicine^[2]. The ASA's advice on Botox reaches beyond headline claims to small details such as price lists and testimonials^[3]. Our separate guide on prescription-only medicines and aesthetic clinic websites covers this in depth.

Titles, qualifications and specialist claims

Patients rely on titles to judge who is treating them. The ASA's guidance on marketing cosmetic procedures sets out when doctors may describe themselves as surgeons or cosmetic surgeons and addresses terms such as "qualified", "skilled", "consultant" and "specialist"^[4]. The full CAP and BCAP advertising guidance on cosmetic interventions sets out how each of those words is read^[5]. Professional regulators add their own rules: the HCPC explains that using a protected title without entitlement, with intent to deceive, is a criminal offence under the Health Professions Order 2001^[6].

A safe habit is to tie every title on your website to something checkable, usually the public register. See our guide on showing GMC, NMC and HCPC registration.

Testimonials and before and after images

Rule 3.47 of the CAP Code says marketers must hold documentary evidence that a testimonial or endorsement is genuine^[7]. A testimonial that describes a result is still read as a claim about the treatment. A patient saying "my back pain disappeared" is an efficacy claim, and rule 12.1 asks for evidence behind objective claims whoever makes them on your site^[2].

For before and after photos, the ASA advises holding "signed and dated proof that the photos are genuine and have not been manipulated", keeping records of any retouching, and making sure images are representative of the effect consumers could likely expect^[8]. The ASA's cosmetic procedures guidance also warns against trivialising treatments and against exaggerated claims made through before and after images^[4]. Our reviews and testimonials guide covers consumer law as well.

Doctors' own professional standards

Doctors have obligations beyond the CAP Code. The General Medical Council's updated Good medical practice came into effect on 30 January 2024^[9]. Medical Protection's summary of the GMC's position on advertising is that information must be accurate and not false or misleading, must be verifiable, must not put pressure on patients, and, for cosmetic interventions, must not minimise risks or imply that results are guaranteed^[10]. A clinic website that names its doctors should be consistent with those standards.

A wording checklist

• Replace outcome promises with descriptions of what the treatment involves.
• Remove "clinically proven", "guaranteed", "permanent", "pain-free" and "risk-free" unless you hold evidence that supports them, and even then use them sparingly.
• Add a short section on when to seek NHS or urgent care.
• Remove any promotion of prescription-only medicines, including prices and product names.
• Tie every title and qualification to the register or a certificate you hold.
• Keep signed, dated proof for every testimonial and before and after photo, or remove them.