Building a Clinic Website in Japan — Why You Can’t Publish Patient Reviews (Medical Advertising Rules Explained)

If you build websites for clinics and dental practices in Japan, you will hit one wall every time: you cannot publish patient reviews.

Reviews are the most persuasive thing a website can carry. No amount of polished copy beats a single line like “I was terrified at first, but it didn’t hurt at all.” So the question always comes: “Surely it’s fine if the patient consents?”

The short answer is no — consent does not make it legal. But there are legitimate ways to build trust, and they are not workarounds. This article maps out where the line actually sits.

1. In 2018, websites became “advertising”

Clinic websites in Japan were originally outside advertising regulation. Advertising meant newspapers, flyers, signage — things a clinic pushes toward patients. A website was something patients seek out themselves.

That distinction collapsed with the June 2018 amendment to the Medical Care Act. The scope widened from “advertising” to “advertising and other displays used as a means of attracting people to receive medical care,” and websites came inside the fence.

The trigger was consumer harm in cosmetic medicine. Clinics were posting “100% success” and “no side effects” on their sites while patients experienced otherwise, and the regulatory blind spot became impossible to ignore.

2. But there is a relief mechanism: gentei kaijo

Treating every website as advertising creates a problem. Advertising may only carry a fixed list of items, and applying that list literally would stop a clinic from even explaining its self-pay treatments — which hurts the very patient who came looking for information.

Hence 限定解除 (gentei kaijo), the lifting of the item limitation. On media patients seek out themselves — websites, in-clinic brochures — the limitation lifts if four conditions are met.

• ① The information must be something patients actively seek out — websites, in-clinic brochures. Banner ads and paid search do not qualify
• ② A contact point must be shown — a phone number or enquiry form the reader can easily use
• ③ Treatment details and costs for self-pay care must be stated — what is normally involved, duration, number of visits, price
• ④ Main risks and side effects of self-pay care must be stated

Critically, all four must be satisfied on the same page. Costs on a pricing page and risks on a separate page does not count.

3. Testimonials remain off-limits

Here is the crux. Gentei kaijo is not a master key. Testimonials are excluded from it entirely.

体験談は、個々の患者の状態等で感想は異なり、誤認を与えるおそれがあるため、広告可能な範囲であっても認められない
(Testimonials are not permitted even within the scope of what may otherwise be advertised, because impressions differ according to each patient’s condition and may cause misunderstanding.)

The reasoning is simple. The same treatment produces different outcomes in different people. If eight out of ten patients were satisfied and you publish only those eight, readers conclude “that will be me too.” And as long as the clinic does the choosing, unfavourable accounts will never appear.

Strictly, what is banned is “testimonials concerning the content or effect of treatment.” Comments unrelated to clinical outcome — waiting times, reception staff, parking — are not blanket-prohibited, but the boundary is blurry enough to be dangerous in practice.

4. Three common misconceptions

“We have the patient’s consent”

Consent resolves the privacy question only. Advertising rules do not ask whether the patient minds; they ask whether the reader will be misled. No consent form, however thorough, lifts the restriction.

“We only reproduced comments from our survey forms”

Substance governs, not format. A survey response, a photographed handwritten note, a social media post copied across — if a patient wrote it about treatment outcomes, it is the same thing.

“We merely replied to something the patient posted voluntarily”

A patient’s own social post is not advertising, provided the clinic neither paid for it nor requested it. However, quoting that post — where it describes treatment content or effect — and replying to it is treated as a violation. The moment the clinic pulls that content forward and displays it, its character changes.

5. What happens if you breach the rules

Fines are not the first step. There is a sequence.

• Stage 1 — administrative guidance; an order to stop or correct the advertising
• Stage 2 — ignoring that order: up to 6 months’ imprisonment or a fine of up to ¥300,000
• Egregious cases — revocation of the licence to operate, or a closure order

Most cases end at stage one. But once flagged, you take the page down in a hurry, and search ranking and credibility fall with it. Never building it is far cheaper.

6. So what can you publish?

Item	Allowed?	Conditions
Patient testimonials, survey comments	No	Excluded from gentei kaijo. No condition makes it permissible
Case photos (before/after)	Yes	Each case must carry treatment details, cost, duration/visits, risks
Google reviews and other third-party platforms	Yes	Voluntary posts the clinic neither solicited nor paid for. Copying them onto your site makes them advertising
Case commentary written by clinicians	Yes	The author is the clinician, not the patient
Facilities and equipment	Yes	So long as clinical efficacy is not implied
FAQ	Yes	The practical substitute for testimonials

One principle runs through the whole table: move the speaker from the patient to the clinician.

“Our patient said it didn’t hurt” is out. “We treated this case, by this method, at this cost, carrying these risks” is fine. The first is personal impression; the second is a clinical record.

7. Case photos — the practical alternative

This is the strongest card you can play instead of testimonials. But a photo on its own is also a violation. Each case must carry four things.

• Treatment details — what was done and how
• Cost — for self-pay care, the actual total paid
• Duration and number of visits — how many months, how many appointments
• Main risks and side effects — pain, swelling, relapse, and so on

A single disclaimer block at the bottom of a “case gallery” page does not satisfy the requirement. It must sit with each individual photo.

When building the site, make those four fields mandatory in the case-entry screen itself. A system that refuses to save is more reliable than a person remembering. Breaches almost always start with “we forgot to write the risks that one time.”

8. How to use Google reviews properly

If you want to show genuine patient voices, this is the safest route.

• Fine — a rating badge and a “read reviews” link that sends visitors out to Google
• Not fine — copying review text into your own site
• Absolutely not — offering discounts or gifts in exchange for reviews. That destroys voluntariness, making it advertising, and breaches Google’s policies besides

The difference is pointing at something outside versus bringing it inside. Cross that line and it becomes something the clinic selected.

9. Pre-launch checklist

• No patient-written impressions of treatment remain (surveys, letters, reposted social content included)
• Every case photo carries treatment details, cost, duration/visits and risks in the same place
• Self-pay pages show a contact point
• No absolutes — “always”, “100%”, “completely cured”
• No superiority claims — “best in Japan”, “finest technique”
• Before/after images are not laid out to emphasise results alone

Closing

The rules look fussy, but inverted they point one way: speak about what you do, not about what someone said.

Look across Japanese dental websites and you will find almost none carrying testimonials. Instead they walk you through treatment step by step, answer worries pre-emptively in an FAQ, and let the director explain the practice’s philosophy in his or her own words. That earns deeper trust over time — a review is ultimately someone else’s words, while a treatment philosophy is the clinic’s own.

At THEVOS we enforce these rules at the system level when building medical websites. The case-entry screen will not accept blank mandatory fields, and risky phrasing is caught at the point of entry. The aim is that nothing breaks when the person managing the site changes.

If you are planning a medical website in Japan, we would be glad to hear from you.

---

References

• MHLW — Casebook on Website Regulation under the Medical Advertising Rules (5th ed., March 2025) — the official casebook
• GemMed — Patient testimonials and before/after photos are in principle not permitted on websites (MHLW) — the basis for testimonials being outside gentei kaijo
• Medee — Medical advertising guidelines dental clinics must follow (2026) — dental cases, penalties, third-party reviews
• MMC — The 2018 medical advertising guidelines and gentei kaijo — background to the 2018 amendment and the four conditions
• Dental Practice Topics — Advertising regulation and gentei kaijo for dental clinics
• M-hand — Prohibited wording on dental clinic websites — list of banned expressions

※ This article summarises publicly available material and is not legal advice. Borderline cases are handled differently by different local authorities, so please confirm with your local public health centre before publishing.