NMC Compliance for Plastic Surgeons in India: A Clause-by-Clause Checklist (2026)
Updated 8 October 2026 to the National Medical Commission's Guidelines on Ethical Advertising and Public Communication by Hospitals/Medical Institutions and Registered Medical Practitioners (public notice No. R-13014/01/2024-Ethics, dated 6 October 2026, in force immediately). Paragraph numbers in this article refer to those guidelines. General information, not legal advice.
On 6 October 2026 the National Medical Commission issued its Guidelines on Ethical Advertising and Public Communication by Hospitals/Medical Institutions and Registered Medical Practitioners, in force immediately. They are read with the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations 2002, whose Chapter 6 covers unethical acts including advertising, and with the NMC Act 2019. For plastic and aesthetic surgeons, they answer most of the questions that used to be argued case by case. This page is the checklist: each clause that matters for the specialty, what it means in practice, and a plastic-surgery example. For the growth side (how a practice builds enquiries inside these rules), read our plastic surgery marketing playbook. For imagery, see the before-and-after photo rules.
- The guidelines cover digital, social, sponsored, influencer, search and AI-generated promotional communication (para 3.2). Instagram, WhatsApp, Google Business Profile and ads run by an agency all count.
- An individual surgeon may not self-promote, solicit or engage a third party to market medical services (para 8.1(ii)). The hospital or clinic may publish factual, verifiable information about itself (para 8.3) and a doctor directory (para 9.1).
- Promotional before-and-after photos, success stories and patient testimonials are out, and patient consent does not change that (paras 8.1(v), 8.1(xi), 6.2; para 3.2, Explanation V).
- No "best", "No.1", "painless", "100% success" or result-implying claims; no offers or free procedures as inducements; no fake engagement (paras 8.1(iii), 8.1(ix), 8.1(x), 8.1(xii)).
- Educational talks and content in the surgeon's own name and designation remain open, without promoting the employer (para 8.2(iii)).
Three layers, one of them tied to your registration
Public-facing content from a plastic surgery practice is tested against three separate rulebooks. They overlap, but clearing one does not clear the others.
The NMC guidelines (October 2026)
These bind registered medical practitioners (RMPs) and hospitals or medical institutions. A State Medical Council may act on a breach by a doctor (para 10.1); hospitals are dealt with under the Clinical Establishments Act or the relevant State Act. Publishing through a marketing agency, platform or influencer does not shift responsibility: the doctor or institution remains answerable for content it authorised, commissioned, sponsored, adopted or knowingly permitted (para 4.4).
The ASCI Code (the advertising standards layer)
The Advertising Standards Council of India is a self-regulatory body whose code covers truthfulness, harm and decency in advertising, including healthcare and cosmetic services. It handles complaints from consumers, competitors and its own monitoring. Its decisions are not court orders, but they are public.
Meta's advertising policies (the platform layer)
Meta applies its own health and Personal Attributes policies, which restrict ad copy that implies knowledge of a viewer's body, health or perceived flaws. "Transform your nose" or "get the body you want" will typically be rejected. Platform approval says nothing about NMC compliance, and the reverse is also true.
The checklist, clause by clause
Run every Reel, caption, ad, landing page, Google Business Profile field and WhatsApp broadcast through these checks before it goes live.
| # | Check | Clause | Plastic-surgery example |
|---|---|---|---|
| 1 | Is it promotional? Information given in the normal course, without promotional intent or commercial benefit, is not advertising. | 3.2, Expl. I | A recovery-timeline explainer is education; "Book your rhinoplasty this month" is promotion. |
| 2 | Who is the publisher? An RMP may not self-promote, solicit or engage a third party to market medical services. The institution may publish factual, verifiable information. | 8.1(ii), 8.3, 4.4 | Marketing runs through the clinic's or hospital's channels, not a surgeon's personal ad account. |
| 3 | Is every named surgeon disclosed properly? Name, qualifications, registration status and SMR/NMR registration number. | 3.2, Expl. III and IV | Add the registration line to Reels captions, the website directory and YouTube descriptions. |
| 4 | Any superiority or ranking claim? "Best", "No.1", "leading", "most trusted", "top" or "unmatched" only if objectively verifiable with a disclosed methodology. | 8.1(ix), 8.1(iii) | "Delhi's top cosmetic surgeon" goes. So does "India's leading rhinoplasty centre". |
| 5 | Any outcome promise or hidden risk? No "100% success" or "painless" claims, no unrealistic expectations, no hidden risks. | 8.1(iii), 8.1(vi) | "Scarless", "painless lipo" and "natural-looking results" go. Every procedure page states risks and recovery. |
| 6 | Any before-and-after image, celebrity patient or success story? Not for promotion; scientific or educational use only, with anonymised consent. | 8.1(v), 6.2, 6.4 | No transformation Reels or galleries, with or without consent. Conference teaching material is a different context. |
| 7 | Any testimonial, endorsement or review used as promotion? An RMP may not request or share testimonials for promotion on social media. | 3.2, Expl. V; 8.1(xi) | No "patient speaks" videos, no reposting a patient's story, no review screenshots on Instagram. |
| 8 | Any manufactured engagement? No fake followers, likes, reviews, ratings, comments or views; no ranking manipulation. | 8.1(xii) | No bought followers before a launch, no review-gating. |
| 9 | Any offer? No discounts, coupons, cashback or free procedures as inducements; price disclosure must be factual. | 8.1(x) | "Festive offer on liposuction" and "free filler with every consult" go. A factual price page can stay. |
| 10 | Any fear or insecurity framing? No fear-based or unnecessary-demand marketing. | 8.1(i) | "Embarrassed by your chest?" copy for gynaecomastia goes. |
| 11 | Any AI? AI-generated promotional campaigns are prohibited; permitted AI content carries a source mark; no synthetic patients or AI-altered outcomes. | 7.2 | No AI-generated "patients" or simulated results in ads. Label AI-assisted explainer graphics. |
| 12 | Any identifiable patient data? No names, faces or anomalies; identifying features blurred or cropped where images are lawfully used. | 7.4, 6.1, 6.4, 7.6 | No tattoos, birthmarks or backgrounds that identify a patient; DPDP Act rules apply to enquiry data. |
| 13 | Is the surgeon's photograph self-advertisement? Not permitted where it constitutes self-advertisement. | 9.2 | A directory photo on the hospital website is different from a billboard of the surgeon. |
| 14 | Is it genuinely educational? Public-health talks on TV, radio and electronic media in the surgeon's own name and designation, without promoting the employer. | 8.2(iii), 5.1 | A YouTube explainer on implant types is fine; ending it with "visit our clinic for the best results" is not. |
| 15 | Live surgery? Broadcasts follow the NMC's separate framework. | 7.5 | Do not stream procedures on Instagram Live. |
Instagram Reels: applying the checklist
Reels are the highest-volume content format in aesthetic surgery, and the rules are the same as for any other advertisement. What changes is the pace: a Reel is made and posted quickly, so the checks need to be built into the production routine.
A compliant Reel
- The surgeon on camera explaining a technique, candidacy, risks or recovery, with name, qualifications and registration details in the caption (check 3).
- Third-person framing: "Patients considering primary rhinoplasty often ask about..." rather than "If you hate your nose...".
- No patients on camera, no before-and-after visuals and no simulations (checks 6, 11 and 12).
- Captions that describe and do not rank or promise (checks 4 and 5).
- Posted from the clinic's or hospital's account, or, if from the surgeon's own account, kept educational and free of employer promotion (checks 2 and 14).
- A "Learn more" call to action, not "Book your surgery" or a price offer (checks 1 and 9).
Reel patterns to avoid
- Split-screen or sequential "transformation" edits, including simulations.
- Countdown captions such as "Day 3 after surgery" that imply a result timeline for viewers.
- Second-person captions addressing a body feature ("your tummy", "your nose").
- Comparative captions ("unlike traditional rhinoplasty", "we do it differently from others").
- Reposting a patient's own post about their surgery. Sharing it is still sharing a testimonial (check 7).
Google Ads and landing pages
Search ads on educational and service queries (technique names, recovery, candidacy) are the most predictable paid channel. Ads should run for the clinic or hospital and point to factual procedure pages. "Learn about rhinoplasty consultation" is safer than "Book rhinoplasty surgery". Prices may appear if they are factual and accurate, with the terms on the landing page; anything framed as a discount, limited-time offer or free add-on is an inducement under para 8.1(x). Display and Performance Max campaigns need the same creative checks as Reels, because image assets are where before-and-after material tends to slip in.
Consent and patient images
Patient information or images may be used only where the law permits and with the patient's consent (para 6.1). But consent is a minimum, not a permission slip: it does not make a prohibited testimonial or before-and-after lawful (para 6.2). In practice, plastic surgery practices need patient images for two legitimate purposes only: the clinical record, and scientific or educational use such as a conference presentation or journal article, with anonymised consent (para 8.1(v)).
For those uses, keep the consent separate from surgical consent and signed at a different time, specific about purpose and audience, time-limited, and withdrawable. Store it in the clinical record, not on an agency's drive, and handle the data under the DPDP Act 2023 (para 7.6). Blur or crop identifying features (para 6.4).
Procedure-specific examples
Rhinoplasty
Compliant: an explainer on open versus closed technique, what a consultation covers and typical recovery, with the surgeon on camera and the clinic's registration details in the caption. Not compliant: "See how we transform noses", a split-screen simulation, or urgency-framed booking language.
Liposuction
Compliant: an article on tumescent, VASER and laser-assisted approaches, candidacy and recovery, with risks stated. Not compliant: "Get rid of stubborn belly fat with our advanced liposuction", which addresses the viewer's body and implies a result.
Breast augmentation
Compliant: implant-category education (saline or silicone, round or anatomical), incision approaches and recovery expectations, without imagery of the procedure area. Not compliant: second-person body-feature copy, any patient imagery used for promotion, or celebrity references.
Gynaecomastia
Compliant: grade-based education, surgical versus non-surgical management and compression-garment guidance. Not compliant: copy built on embarrassment about the chest (para 8.1(i)), before-and-after images or "best gynaecomastia surgeon" claims.
What happens after a complaint
For an individual doctor, the State Medical Council issues a show-cause notice first and decides by a reasoned order (paras 10.2-10.3). Para 10.1 sets out graded action that may be contemplated: a warning with mandatory ethics training for a first violation; censure with a monetary penalty for a second; suspension of 3-6 months for a third; suspension of 6-12 months for serious violations such as misleading cure claims, inducements or digital mass solicitation; and removal from the register for 1-3 years for repeated violations. Appeals go to the NMC's Ethics and Medical Registration Board within 60 days, with a further appeal available (para 11). Hospitals are dealt with under the Clinical Establishments Act or the State Act. ASCI's code, consumer protection law and platform policies run alongside, so one problematic Reel can create exposure on several fronts at once.
Run the 15 checks above on every Reel, article, ad creative, GBP edit and broadcast before it publishes, and keep a dated record of who approved it. Keep patient consent records in the clinical system, separate from surgical consent. Re-check legacy content too: old highlights, pinned posts and image-ad assets are often where before-and-after material survives.
How ICG applies this to plastic surgery
Plastic surgery engagements at ICG start with an audit of existing content against these checks, then a pre-publication review of everything new, run for the clinic or hospital. Our plastic surgery marketing agency page describes the engagement, and the procedure pages for rhinoplasty, breast augmentation and liposuction apply the same checks at procedure level.
Frequently asked questions
Can a plastic surgeon share a patient's post-op review on Instagram if the patient consents?
No. The NMC guidelines of 6 October 2026 say a registered medical practitioner shall not request or share patient testimonials, recommendations, endorsements or reviews for professional promotion on social media (para 3.2, Explanation V), and patient testimonials may not be used in promotion (para 8.1(xi)). Consent does not make a prohibited testimonial lawful (para 6.2). Educational content about the procedure is the alternative.
Can 3D simulation images be published in ads or on social media?
Treat them as off-limits for promotion. A simulated after image functions as an outcome image, and the guidelines bar promotional before-and-after content (para 8.1(v)), communication that creates unrealistic expectations (para 8.1(vi)) and misleading or synthetic AI-generated content (para 7.2). A simulation used inside a consultation to explain options, with its limits stated, is a clinical tool rather than an advertisement.
Can I say "natural-looking results" in captions or ads?
Avoid it. It is a result-implying phrase, and the guidelines bar communication that creates unrealistic expectations or hides risks (para 8.1(vi)) as well as guarantee-style claims (para 8.1(iii)). Describe the process instead: what the procedure involves, who is a suitable candidate, the risks and the recovery. Individual results depend on the patient, and the copy should say so plainly.
Are procedure or body-part landing pages a violation?
Not in themselves. A hospital or clinic may publish factual information about the services it offers (para 8.3), and educational procedure content is permitted. A page becomes a problem when it solicits, addresses the reader's insecurity about their body (fear-based or unnecessary-demand marketing, para 8.1(i)), promises a result, uses before-and-after images, or claims superiority (paras 8.1(v) and 8.1(ix)).
What penalties apply to a plastic surgeon who breaches the guidelines?
Para 10.1 sets out graded action the State Medical Council may contemplate: a warning with mandatory ethics training for a first violation, censure with a monetary penalty for a second, suspension of 3-6 months for a third, suspension of 6-12 months for serious violations such as misleading cure claims or inducements, and removal from the register for 1-3 years for repeated violations. A show-cause notice and a reasoned order come first.
Who enforces these rules: the NMC, the State Medical Council or someone else?
For an individual doctor, the State Medical Council acts under the guidelines, after a show-cause notice and with a reasoned order (paras 10.2-10.3). Appeals go to the NMC's Ethics and Medical Registration Board within 60 days, with a further appeal available (para 11). Hospitals are dealt with under the Clinical Establishments Act or the relevant State Act. Separately, ASCI's code, consumer protection law and platform policies apply to advertising generally.
Compliance-first plastic surgery marketing, built for the October 2026 guidelines
Every piece of public-facing content on an ICG plastic surgery engagement is checked against the NMC's October 2026 guidelines, ASCI and Meta ad policy before it publishes. Retainers from Rs 20,000/month, custom-scoped per engagement.
Chat with Co-founder WhatsApp ICGHow ICG works within these guidelines
ICG is a healthcare marketing agency. Our clients are hospitals, clinics and medical institutions, which may publish factual, objective and verifiable information about themselves (paras 8.3 and 9.1). For individual doctors, ICG supports only genuinely educational content in the doctor's own name and designation (para 8.2(iii)). For doctors and their practices, we run patient-education-driven campaigns: awareness content that helps patients understand their condition and their options, published in the doctor's own name and designation (para 8.2(iii)) and kept free of the self-promotion that para 8.1(ii) bars.
The work is education-first and runs across six channels:
- Awareness content on YouTube. Doctor-led educational videos on public health and disease awareness, in the doctor's own name and designation, without promoting the employer organisation (para 8.2(iii)). See YODA and YouTube marketing for healthcare.
- Research articles and blogs that help patients understand their options: information shared in the normal course, not promotion (para 3.2, Explanation I). See healthcare content marketing, ICG research reports and healthcare SEO.
- Expert answers on Reddit and Quora from named, disclosed accounts. No anonymous or fake posts, no undisclosed commercial relationships and no manufactured engagement (paras 8.1(xi) and 8.1(xii)). See Reddit and Quora programmes.
- Awareness campaigns on Meta, run from the hospital's or clinic's own page, with no discounts, offers, free procedures or other inducements (paras 8.1(x) and 8.3). See Meta advertising for hospitals and clinics.
- NMC-compliant Google Ads landing pages: factual departments, services and facilities, with no "best", "No.1", "100% success", "painless" or "guaranteed" claims (paras 8.1(iii) and 8.1(ix)). See Google Ads for hospitals and clinics.
- "Learn More" instead of "Book Now" on patient-facing pages, so that a page informs rather than solicits (paras 8.1(ii) and 8.3(ii)).
All six rest on three kinds of content: scientific (evidence-based, checked by a qualified clinician), persona-based (written for the questions a specific patient group asks) and consumer-based (built from how people search, compare and decide). AI-assisted drafts go through human medical review, and AI-generated content that is published carries an AI source mark (para 7.2). We do not publish patient testimonials, before-and-after images or superiority claims, and we never buy, incentivise or gate reviews.
Free NMC compliance check. We review a hospital's or clinic's website, Google Business Profile and social channels against the October 2026 guidelines and send back a written list of fixes.
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General information, not legal advice. Source: NMC public notice No. R-13014/01/2024-Ethics, 6 October 2026.