ASCI Compliance for Doctor Reviews — the Chapter III Working Guide for Indian Clinics
Why ASCI applies to review workflows, not just paid ads
Practitioners often assume ASCI is a paid-media regime — the poster on the flyover, the Meta ad, the Google Search ad, the newspaper insertion. That is only part of what the Code covers. ASCI's own scope statement makes clear that "any advertisement, communication, or promotion" in the public domain is inside the tent. A Google Business Profile response, published by the advertiser and visible to the public, meets that test. A review request that includes suggested wording (a scripted testimonial) meets that test. A patient story lifted from a review and re-posted on Instagram meets that test.
Chapter III narrows the focus for cosmetic products and treatments, which for our purposes means aesthetic clinics, dermatology practices, hair-restoration practices, dental smile-design work, weight-management clinics and the cosmetic-adjacent parts of plastic surgery. The rest of clinical medicine sits under the general Code plus NMC Section 6.
The four ASCI standards that touch review work
| ASCI standard | Applies to review work how |
|---|---|
| Truthful and honest (Chapter I.1) | Any claim in a review response — treatment outcome, patient volume, credential — must be substantiable. |
| Not misleading by implication (Chapter I.4) | Even a technically true statement that misleads the reader by implication is a violation. "Board-certified in the US" implies India-relevant certification unless clarified. |
| Substantiation (Chapter III specific) | Cosmetic-treatment claims — smoother skin, hair regrowth, weight loss — must have documented substantiation on file. Reviews that make these claims and clinic responses that endorse them both attract the test. |
| Testimonial governance (Chapter I.1.4) | Testimonials the advertiser controls must be genuine, current and representative. A curated wall of five-star reviews on the clinic website falls inside this standard. |
Language ASCI will treat as advertising
The response library inside ReputationShield strips or rewrites four language patterns because they consistently attract ASCI attention:
Pattern 1 · Superlative claims
"Best", "leading", "number one", "India's finest", "most trusted". Each of these requires substantiation ASCI will accept — a market-share study, an independent ranking, a defensible cohort measurement. Almost no clinic in India carries such substantiation across every cohort a reader might infer. The safer rewrite is descriptive: "an experienced clinic", "an established practice", "a specialised team".
Pattern 2 · Outcome guarantees
"Guaranteed results", "100 per cent scar-free", "painless every time", "no side effects". Cosmetic outcomes vary by patient physiology and no clinic can honestly promise a universal result. Chapter III's substantiation standard treats these as prima facie non-compliant. Rewrite to process: "the protocol is designed to minimise scarring" is defensible; "100 per cent scar-free" is not.
Pattern 3 · Comparative claims
"Better than", "advanced compared to older methods", "the only clinic in Delhi with this laser". Comparative claims require both parties to be identifiable and the comparison to be substantiable. Even a factually true "we are the only clinic in Gurgaon with a Q-switched Nd:YAG at 1064 nm" invites a challenge from another clinic with a similar device. Rewrite to capability without comparison: "we operate a Q-switched Nd:YAG at 1064 nm" — the reader can draw their own conclusion.
Pattern 4 · Efficacy percentages
"96 per cent success rate", "8 out of 10 patients see visible improvement in 4 weeks". These are substantiation claims and ASCI has taken action against clinics that publish them without documented internal study protocols. If the number cannot be defended to a Consumer Complaints Council panel, it should not appear in a review response.
Review acquisition — where the ASCI test bites earliest
Most clinics fall foul of ASCI not in review responses but in review acquisition — how they ask patients to write a review in the first place.
- Scripted testimonials. A WhatsApp template that says "please mention Dr X and the [procedure]" is a scripted testimonial. It fails ASCI's testimonial governance standard and NMC Section 6 simultaneously. ReputationShield uses only neutral solicitation: "If you found the service helpful, please leave an honest review."
- Incentivised reviews. "Get a ₹500 credit for a Google review" fails both ASCI and Google's own review policy. Incentivisation is banned end-to-end. This is why the ReputationShield workflow triggers a review request only at a service moment (discharge, follow-up, closure) and never with an incentive.
- Before-and-after amplification. ASCI has issued specific guidance on cosmetic-treatment before-and-after claims. When a patient voluntarily posts one inside a Google review, the clinic can neither edit it nor lift it into paid media without a proper substantiation pack on file. Leaving the review as-is and not amplifying is the safer route.
The Chapter III substantiation pack
For clinics that do want to run cosmetic-outcome content — before-and-afters on the website, patient stories in ads, video testimonials on YouTube — Chapter III requires a substantiation pack held on file for each claim. The ICG-recommended pack contains:
- Patient written consent (DPDP-clean) for public use of images, story or clinical detail.
- Documented pre-treatment condition — dated, photographed, medically recorded.
- Documented post-treatment condition — dated, photographed, medically recorded, matched lighting and pose.
- Treatment protocol notes — what was done, over what period, by whom.
- Practitioner sign-off — that the case is representative and not cherry-picked.
- Cohort context — how many patients had comparable results, how many did not, over what time window.
Any before-and-after or outcome claim published without all six elements is exposed to challenge. Clinics that run the pack consistently can publish confidently. Clinics that do not should keep review responses to process language, not outcome.
Enforcement — what actually happens if ASCI investigates
ASCI's Consumer Complaints Council reviews reported advertisements against the Code. If the complaint is upheld, the advertiser is asked to withdraw or modify the advertisement. Non-compliance is publicly listed, escalated to the Ministry of Information and Broadcasting, and referred to the specialty regulator — for medical clinics, that means the National Medical Commission or the state medical council. Recent public orders have named aesthetic clinics, dermatology practices and dental smile-design clinics for outcome and superlative claims in Meta ads, Google Search ads and Instagram content. The route is the same for a review response.
How ReputationShield keeps clinics inside ASCI
Every response frame inside the ReputationShield library is written first for NMC Section 6 compliance and second for ASCI Chapter III compliance. The library carries an ASCI-specific overlay for aesthetics, dermatology, hair restoration, dental cosmetic and weight-management specialties — variants that strip superlative, comparative and outcome language even when the underlying frame is otherwise safe. Bulk detail on the broader response method sits inside how to respond to negative Google reviews. Companion piece on banned phrases is at what NOT to say in a negative review response.
The productised subscription — ReputationShield — bundles the library, the review acquisition workflow and the ASCI-clean response layer into one monthly fee. Starter at ₹9,999, Growth at ₹34,999, Scale at ₹99,999.
Audit your review workflow against ASCI
Free 45-minute Discovery call. We review your last 30 days of Google review responses, your review request template and any patient testimonial appearing on your marketing surfaces. Deliverable: a phrase-level risk map.
💬 WhatsApp ICG See ReputationShield tiersFAQ
Does ASCI apply to Google reviews and their responses?
Yes. Any advertising communication in the public domain is inside ASCI's scope, and a Google Business Profile response counts.
Can a review response say "best clinic in Delhi"?
No. Superlative claims require substantiation ASCI accepts, and no clinic carries that substantiation across every cohort a reader might infer.
Can a clinic ask a happy patient to write a review that names the doctor?
The patient can voluntarily write whatever they wish. The clinic cannot script it, incentivise it or edit it for publication.
Are before-and-after photos in reviews an ASCI issue?
For cosmetic treatments they can be, especially when the clinic amplifies them in paid media without a substantiation pack.
What ASCI penalties can hit a doctor practice?
Withdrawal orders, public listing of non-compliance, escalation to the Ministry of Information and Broadcasting, referral to the specialty regulator.
