What you may legally publish, and what your agency probably has not read.
Compliance is not a line on our services page. It is the reason this agency exists, and it is the only part of the offer we charge for before any advertising runs. Here is the whole position, with the instruments named, so you can check it yourself.
Two rule sets, pointing in opposite directions
Layer one, the platform
Meta's live Health and Wellness policy expressly permits before and after imagery for cosmetic procedures. The old prohibition is gone and both legacy policy URLs now return 404. The current policy names dermal fillers, skin rejuvenation, injectable treatments, chemical peels, micro needling, non ablative laser, laser and light treatments, and hair restoration surgery as permitted categories for 18 and over targeting.
Layer two, the profession
The operative Indian instrument is the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations 2002, adopted by the NMC with effect from 23 August 2023. Clause 6.1.1 states that a physician shall not boast of cases, operations, cures or remedies or permit the publication of report thereof through any mode.
Plan for this
The position is unstable, so we build for that
The NMC 2023 Regulations, which contained an explicit ban on images of healed patients, were held in abeyance by the NMC itself twenty one days after notification. They were not struck down by a court. They can be revived by a single gazette notification, with no judicial process and no transition period. The planning rule that follows is simple and almost nobody applies it: any transformation or testimonial layer in your account must be separable, so your performance does not collapse if it has to be pulled in a week. We build the compliant core to carry the result.
Copy, not creative
The rule that prevents most rejections
Meta's Personal Attributes policy treats copy that asserts or implies the reader's condition as a violation, and it is the single most common cause of disapproval in this category. The fix is grammatical, not editorial. Write about the treatment, never about the reader's face, body or condition. Even the word other is treated as implying the reader shares the attribute.
Fails
Struggling with acne?
Passes
Acne treatment now available in Bangalore.
Fails
Tired of unwanted hair?
Passes
Laser hair reduction, six session course, Indiranagar.
Fails
Are your dark spots getting worse?
Passes
Pigmentation consultations with a qualified dermatologist.
Fails
Join other women who fixed their hair fall.
Passes
Hair restoration consultations, by appointment.
Same idea, different grammar. This one rule removes most of the rejections we see on an aesthetics account, and it costs the clinic nothing in reach.
What we will never run on your account
- Any identifiable patient face.
- Any before and after pair, consented or not, cropped or not.
- Patient testimonials.
- Guaranteed results, permanent, painless, or no side effects.
- Skin whitening or fairness in any form. Schedule J entry 18.
- Timebound outcome promises.
- Superiority claims such as number 1 clinic, and professional endorsement claims. These two drew a ₹10 lakh CCPA penalty against a toothpaste brand in 2022.
- Any health question inside a Meta lead form. Banned outright.
- Results may vary, or any disclaimer used to repair a claim.
What we run instead
- Factual service availability, written in the third person.
- Your real and verifiable qualifications and medical council registration number.
- Condition education written about the treatment rather than about the reader.
- Process footage showing what happens rather than what results.
- Illustrated condition explainers and skin diagrams, which clause 6.1.2 expressly permits.
- Doctor led informational video with the qualification superimposed upfront, per ASCI Addendum II dated 6 March 2025.
- Treatment framed as a consultation service, not a promised outcome.
Uncomfortable but relevant
Who carries the liability, stated plainly
We say this out loud because it changes how carefully the work gets done, and because no other agency selling to you will raise it. Clause 12 of the CCPA's 2022 Guidelines is headed Duties of manufacturer, service provider, advertiser and advertising agency, and it imposes a positive duty on us, with a ₹10 lakh hook under section 21(4) against a party to the publication. The criminal provisions and the higher penalties reach the service provider, which is you. So the criminal risk sits with the clinic and the fine risk touches us both.
And the calibration, because fear selling is how an agency loses a doctor's trust. Total CCPA penalties across every sector over three years come to roughly ₹1.08 crore. The realistic downside is takedown and reputational damage, not ruin. Anyone telling you otherwise is selling you something.
What we hold ourselves to
- One pixel and one dataset per clinic. No shared custom audiences, no cross client lookalike pools.
- You hold the ad account and the Google payments profile and complete your own advertiser verification. We take manager access only.
- We do not register as a telemarketer, and click to WhatsApp keeps the campaign out of SMS entirely.
- We assume joint Data Fiduciary status rather than processor, and a written contract between clinic and agency is a statutory requirement under DPDP section 8(2), not merely good practice.
- We keep an evidence file per claim, because ASCI clause 1.1 requires every claim to be capable of substantiation.
- We check your state medical council's own advertising guidance before onboarding, because a state council can be stricter than the national position and it is your state council that holds your registration.
The instruments we audit against
- Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations 2002, clauses 6.1.1, 6.1.2 and 7.17
- Drugs and Magic Remedies (Objectionable Advertisements) Act 1954, including Schedule J
- Consumer Protection Act 2019 and the CCPA Guidelines 2022
- ASCI Code clause 1.1 and clause 1.5(d), the Disclaimer Guidelines, and Addendum II dated 6 March 2025
- Meta Health and Wellness policy, and the Personal Attributes policy
- Google healthcare and medicines advertising policy for India
- Digital Personal Data Protection Act 2023, and the SPDI Rules in force today
Want to know which of these your current advertising is on the wrong side of?
Send us your clinic and we will come back with one specific observation about what you are running right now. No charge and no pitch attached.