A clinic's website needs to do two things at once: help patients choose and comply with the profession's advertising rules. Without a clear reference, it's easy to go wrong in both directions. Some clinics copy what they see on other clinics' profiles without knowing whether it is allowed. Others get scared and publish an empty website, with no prices, no team and no explanation of the service.
This guide summarizes, based on the official text, what Resolution CFM No. 2,336/2023 (medicine) and the rules of the Federal Council of Dentistry (CFO) say about what can and cannot appear on the website.
Disclaimer
This article summarizes public standards for informational purposes. It is not legal advice and is not a substitute for reading the full rules, consulting an attorney, or consulting your regional council's advertising committee.
Medicine: a website also counts as an “owned social network”
Resolution CFM No. 2,336/2023 was published in September 2023 and came into force 180 days later, in March 2024, replacing Resolution CFM No. 1,974/20111. It expressly lists websites and blogs, alongside Instagram, WhatsApp and other channels, as the "owned social networks" of doctors and facilities (art. 8, § 1)1. In other words: everything that applies to the clinic’s profile applies to the website.
The resolution also defines who is accountable. For advertising by a facility, such as a clinic, the Technical-Medical Director is responsible (art. 3, II)1.
What needs to appear
- For each doctor featured: name, CRM registration number followed by the word MÉDICO (doctor) and, if applicable, the specialty or practice area registered with the CRM along with the RQE number (art. 4)1.
- For the clinic: establishment name with its CRM registration number, and the name of the Technical-Medical Director with their CRM registration and, when required, specialty with RQE (art. 5)1.
- Where: on websites, each doctor's details must be on the home page or equivalent (art. 6), and the clinic's must appear in all promotional material (art. 5, sole paragraph)1. A practical way is to keep them visible on the home page, for example in the footer.
What the resolution allows
Article 9 lists what is permitted. The explanatory memorandum notes that some of these points, such as publishing consultation fees, were previously considered controversial. The permitted practices include:
- show the work environment, one's own image and the team;
- present devices and resources with information approved by Anvisa;
- explain how to make an appointment, opening hours, parking, location, accepted plans and insurance;
- state consultation fees and payment methods;
- state that the price of private-pay procedures can be agreed before the appointment;
- announce discounts in campaigns, without tie-in sales or prizes;
- disclose verifiable treatment results, provided patients are not identified1.
The explanatory memorandum of the resolution clarifies that the price of procedures and exams can be announced when they do not depend on prior diagnosis and evaluation1.
What the resolution prohibits
Article 11 lists the prohibitions. The ones most relevant to a website's content:
- guarantee, promise or imply good results (section XII);
- attribute "privileged capacity" to devices or techniques, even if the clinic is the only one to offer them (items II and IX);
- advertise, without being a specialist, that one treats specific organs or diseases (section I);
- disclose a method or technique not recognized by CFM (item VII);
- allow the name to be included in award lists such as "best doctor" or "doctor of the year" (section XIII);
- advertise free consultations in the private practice, which the resolution classifies as unfair competition (§ 4, c);
- sensationalism, self-promotion and untrue content, including "revolutionary or miraculous practices" and visual representations that induce the perception of guaranteed results (section XVI and §§ 2 to 5)1.
Before and after, and testimonials
Patient images are permitted for educational purposes (art. 14), under detailed conditions:
- every image must come with educational text about indications, factors that influence the outcome and complications described in the literature;
- the before and after must be presented as a set, showing satisfactory and unsatisfactory outcomes as well as complications;
- when applicable, show different body types, age groups and results over different time frames;
- the patient cannot be identified, even if they have given consent;
- no editing, manipulation or enhancement of images;
- third-party stock images must cite their source1.
Reposted patient testimonials and selfies must be sober, with no superlative adjectives or promises of results (art. 14, II, g). And note: patient posts shared by the doctor are considered the doctor's own posts (art. 8, § 3)1.
In practice
Before publishing a results gallery, build each case from four parts: indication, the full set of images (including less favorable results), factors that influence the outcome and possible complications. If a case can't support all four, it stays out.
Dentistry: two rules and a review in progress
In dentistry, the reference is the Dental Code of Ethics (Resolution CFO No. 118/2012)2, the chapter on "Announcements, Advertising and Publicity", supplemented by Resolution CFO No. 196/20193.
What needs to appear
The Code requires the name and registration number of the individual or legal entity and the name of the profession. For clinics, it also requires the name and registration of the technical manager (art. 43). The listing may include registered specialties, academic titles stricto sensu, address, phone number, hours, accepted insurance plans and logo. If the clinic lists specialties, it must have a professional registered in each specialty and tell the public who those professionals are (art. 43, § 2)2.
Images: what changed in 2019
The Code treats the use of before, during and after images to attract customers as an infraction (art. 44, XII)2. Resolution CFO No. 196/2019 created exceptions:
- self-portraits (selfies) of the dentist, with or without a patient, with the patient's prior authorization through a Free and Informed Consent Form (ICF), without showing equipment, instruments, materials or biological tissues;
- images of diagnosis and treatment completion, published by the dentist who performed the procedure, also with informed consent3.
The same resolution kept prohibiting expressions that suggest sensationalism, self-promotion, unfair competition, commercialization or promises of results. It also banned videos and images of procedures in progress or being performed, except in scientific publications, as well as clinical cases from other professionals. Every image or video post must include the professional's name and registration number3.
Prices are still prohibited
The Code lists among its infractions advertising that includes prices, free services and payment terms (art. 44, I)2. Resolution CFO No. 271/2025 changed the Code to comply with a Cade decision and removed restrictions on discount cards, but did not change this section4.
There is a review underway. In February 2025, Decision CFO No. 5/2025 created a special group to propose updating the entire advertising chapter of the Code5. Among the resolutions published in the CFO's standards system up to September 29, 2026, none introduced new text for this chapter6. Check before each change to the website.
Medicine and dentistry compared
| Topic | Medicine (CFM 2,336/2023) | Dentistry (Code of Ethics and CFO 196/2019) |
|---|---|---|
| Consultation price | Allowed | Prohibited (art. 44, I) |
| Payment methods | Allowed | Prohibited (art. 44, I) |
| Before and after | Educational only, as a set, no identification | Diagnosis and completion, with consent form, by the treating dentist |
| Procedure video | Live streaming and public display of the procedure are prohibited (art. 11, VIII and § 2, d) | Prohibited, except in scientific publications |
| Testimonials | Sober, without superlatives (art. 14, II, g) | No specific rule in the texts reviewed; the general prohibitions of art. 44 apply |
| Required information | CRM, RQE and Technical-Medical Director | Registration in the CRO and technical manager |
Rules that apply to everyone
Consumer Protection Code. Misleading advertising is prohibited, including by omission of essential information (art. 37)7.
LGPD. A patient's photo is personal data, and health information is sensitive personal data (art. 5, II). Processing sensitive data based on consent requires specific, prominent consent (art. 11, I)8. Keep the authorizations.
Other professions. Aesthetic clinics with biomedical professionals, nurses or physical therapists also follow the rules of their respective councils, which were not analyzed here.
Clinic website checklist
- Name, council registration and, if applicable, RQE of each professional featured.
- Name and registration of the clinic and technical manager on the main page.
- No phrase that promises, guarantees or implies results.
- No superlatives about devices, techniques or the clinic itself.
- Specialties listed only when a professional is registered in them.
- Price: published only if the rules of your profession allow it.
- Before and after: only under the conditions of your profession, with consent on file and an unidentifiable patient.
- Reviewed testimonials, without superlative adjectives.
- Privacy policy covering images and patient data.
- Date of the last review of the regulations recorded.
Clarity is also part of compliance
Much of what the council allows is exactly what patients are looking for: who sees them, where, how to book and what a consultation costs when that's allowed. A website that complies with the rules can also be clear and useful. If you want to know where your clinic's digital presence stands today, Flowt's free diagnosis measures it against fixed criteria and shows, point by point, where it is losing patients. It does not replace consulting your regional council.
