Note: this is a practical summary to help you write compliant ads, not legal advice. For specific cases, read the ERS good practice manual on health advertising (in Portuguese) or ask a lawyer.
The short answer
In 30 seconds
You can advertise, but every ad and the page it leads to must identify who provides the service (entity, ERS registration, professional licence number), and you cannot promise results, guarantee cures or use misleading testimonials. On Google there is an extra layer: no ads targeted at people based on their health conditions.
Which rules apply
Health advertising in Portugal is governed by Decreto-Lei n.º 238/2015, supervised by the ERS (Entidade Reguladora da Saúde). It covers any advertising about services to protect or maintain health or to prevent or treat disease, in any medium: Google Ads, Instagram posts, your website, your Google Business Profile, leaflets, and influencer content about your clinic. It applies to public and private providers, and to everyone involved in creating and spreading the ad, agencies included.
Non-conventional therapies such as osteopathy, acupuncture and naturopathy are explicitly covered. Medicines, medical devices and food supplements have their own separate rules.
What you must include
Identification required by the ERS
- The entity: name, tax number (NIF), ERS registration number, licence number where applicable, and the address of the establishment.
- The professional: professional name, cédula profissional (licence) number and qualifications, including any specialty.
- On every medium: website, each social profile, leaflets. On social media it can sit in the bio, as long as each post lets people find it easily. A QR code alone is not enough on print.
A Google search ad has no room for all of this, and does not need to. The page it leads to does. The most common breach we see is an ad pointing to a page with no identification at all.
What you cannot say
- Guaranteed results or cures: "pain-free in three sessions", "guaranteed results".
- No side effects, unless that is true.
- Misleading testimonials. Testimonials are not banned, but they must be real, personal, attributable and must not create dangerous expectations. Anonymous "experts" in white coats are out.
- Misleading before-and-after images, or ones that suggest the result came from your service alone.
- "Free" with hidden costs, or a price that only applies if the patient buys something else. Advertised prices must be final, and promotions must state when they end.
- Treatments as prizes in contests or giveaways.
- Qualifications, specialties or agreements you do not have.
Examples side by side
| Do not write | Write instead |
|---|---|
| Say goodbye to back pain for good | Physiotherapy for lower back pain · Assessment at first visit |
| Guaranteed results in 3 sessions | Treatment plan agreed after assessment |
| The best dentist in Lisbon | English-speaking dentist in Lisbon · Online booking |
| Free consultation* (*assessment fee applies) | First consultation €60 · Includes full assessment |
| Win a free treatment: like and share! | Book online in one minute |
The rule of thumb: describe the service, not the outcome. What you do, where, in which languages, and how to book.
Google's own rules
On top of Portuguese law, Google has its healthcare and medicines policy. Two points matter most for clinics:
- Misleading health claims get ads disapproved, and repeated problems can limit the account.
- No personalised advertising based on health. You cannot build remarketing lists like "visited the sciatica page" and target those people with sciatica ads. General remarketing to site visitors is fine; using the health condition as the targeting criterion is not.
Search campaigns avoid most of these problems: the ad appears because the person searched, not because Google guessed their condition.
Fines and enforcement
Negligence is also punishable, and there are additional sanctions such as seizure of materials or a temporary ban on advertising. The ERS can check online content remotely, including social media. Most problems are fixed with ads that describe the service and a landing page with full identification; it is just worth getting right from the start.
Running a clinic in Portugal? We build Google Ads campaigns for health practices that bring patients and stay inside the rules, and we explain everything in English. Talk to us →