The waiting room TV of a medical aesthetic clinic in Brazil is medical advertising: article 1 of CFM Resolution 2,336/2023 defines advertising as communication to the public "by any means of disclosure". Before-and-after is allowed for educational purposes, but under cumulative conditions that all but eliminate the commercial piece — the set must show unsatisfactory outcomes and complications, any editing that improves the result is forbidden, and patient anonymity is mandatory even with a signed release. Testimonials on a loop collide with the official cap of two displays per semester. Pricing, under the CFM regime, is allowed — tied promotions are not. And the person who signs off on the playlist is the Medical Technical Director.
Method note: where each rule was read
Read on 30 September 2026, in the official sources. The provisions cited here come from the official PDF of CFM Resolution 2,336/2023 (published in Brazil's Official Gazette on 13 September 2023, issue 175, section 1, page 312), from the official answers and the Practical Application chapters published in the CFM Medical Advertising Manual, and from the statutory texts on the Brazilian government's Planalto site. Quoted passages are literal translations of the original Portuguese.
What this article does not do: it does not cite CFM Resolution 1,974/2011, which has been superseded and still populates the internet; it does not attribute content to biomedicine, nursing or physiotherapy rules, which were not read here; it does not deal with health surveillance requirements (Anvisa RDCs, sanitary inspection), which are a different rulebook and a different piece of research; and it does not replace a formal enquiry to your regional council's Codame about a specific piece.
The waiting room screen is advertising, not decoration
Before arguing about what goes into the playlist, one prior question has to be settled — and almost every piece of industry material skips it: is the waiting room screen covered by the medical advertising rule? The answer is in the definition itself.
Article 1 — medical advertising or publicity means "communication to the public, by any means of disclosure of the professional activity, with the physician's initiative, participation and/or consent, in the public, private and philanthropic segments". Paragraph 1 adds that medical advertising is "the act of promoting physical structures, services and qualifications of the physician or of medical establishments (physical or virtual)".
"Any means of disclosure" leaves no room: a television running in the waiting room, showing the clinic's services and premises to the people sitting there, is a means of disclosure. And the CFM Manual does not leave this to interpretation — it mentions the reception desk expressly when answering about mandatory identification of establishments:
"This information must also be kept visible at the reception of these establishments, which must also keep internal signage plates updated, with the name and CRM of the physicians on the clinical staff."
Article 5, II of the Resolution covers those "internal signage plates" when they identify the clinical staff, and the sole paragraph of the same article closes the loop: "All material used in disclosure, physical and virtual, must carry the items presented above". Article 6, §1 extends the rule to "temporary content" — which, in a playlist that rotates every couple of weeks, is most of what runs.
There is a single operational consequence: article 3, II states that "the Medical Technical Director is liable for the disclosure of material from hospitalisation and medical assistance establishments of any nature, public and private (in a physical or virtual environment)". The waiting room playlist has an owner with a medical licence. The receptionist does not decide what goes up, nor does the agency, nor the screen vendor. It is a signed checklist item.
Medical aesthetics vs. aesthetician services: who falls under CFM
"Aesthetic clinic" is not a legal regime — it is a commercial name. The regime follows the council of the professional responsible for the procedure, and that sentence is the first thing to get right before building any schedule. The statutory chain that draws the line is short and written down:
- Law 13,643/2018, which regulates the Aesthetician and Aesthetics Technician professions, states in the sole paragraph of article 1 that it "does not cover activities in medical aesthetics, as defined in article 4 of Law 12,842 of 10 July 2013".
- Law 12,842/2013 (the Medical Practice Act), in article 4, III, reserves to physicians "the indication and performance of invasive procedures, whether diagnostic, therapeutic or aesthetic, including deep vascular access, biopsies and endoscopies".
Translated to the screen:
| Clinic situation | What applies to the playlist |
|---|---|
| Advertises an invasive procedure (medical aesthetics) | The screen falls under the whole of CFM Resolution 2,336/2023, with the Medical Technical Director liable for disclosure (article 3, II). |
| Non-invasive aesthetician service | CFM does not reach it. That does not mean there are no limits: the piece remains subject to general advertising rules, and no health surveillance rule was examined here. |
| Procedure performed by a biomedical scientist, nurse or physiotherapist | Each has its own council and advertising rule. This article covers none of them — check the council of the responsible professional before the piece goes up. |
And here is the costliest mistake in playlist building: the patient's consent, on its own, does not remove the council's ethical restriction. They are two independent layers. The patient may have signed everything — image rights, data consent, advertising release — and the piece may still be forbidden, because the prohibition is not hers to waive: it belongs to the rule that governs the professional.
The mandatory footer: CRM, the word MÉDICO and the RQE
This is an art requirement, not a subject-matter one — it changes the template before the first video enters the playlist. Article 4 requires pieces to carry, "mandatorily":
- I — "name, registration number(s) with the regional council(s) where the physician practises medicine, accompanied by the word MÉDICO";
- II — "specialty and/or area of practice, when registered with the council, followed by the Specialist Qualification Registration (RQE) number, where applicable".
When the piece belongs to the establishment, article 5 adds the clinic name with its council registration and the name of the Medical Technical Director with their registration — "in a physical or virtual environment". And there is a typography detail the Manual answers directly: "The font, the size and the colour must be the same, with no size changes and no use of bold." In other words, you cannot feature the physician's name and shrink the licence number.
For professionals without a registered title the official answer is equally specific: "A physician without an RQE may now state that they completed a postgraduate course in a given area, but must add the term NÃO ESPECIALISTA [not a specialist] on the line below." In practice, the team introduction card has one more field than the designer expects.
Watch out for a reference that is not about screens. The Manual recommends that identification have "a proportion equivalent to at least 35% of the largest type size used in the piece", on a neutral background, and — if the background hampers reading — "set inside a white rectangle framed by an inner rule, with black lettering". That is a rule for street furniture, not for TV. Use it as a legibility reference, knowing it came from another medium; not as a screen requirement.
The identification card: TV regime or internet regime?
This is the question nobody on Google's first page raises, and it comes from reading two passages of the Manual against each other.
For a TV advert, the Codame answers that identification does not need to be present throughout the piece:
"In TV adverts, must the CRM of the physician or of the establishment's medical technical director appear on every screen? No. It is enough for the information to be on the last card, which must stay on air for at least two seconds."
And Chapter V of the Practical Application section specifies that card with a level of detail rarely seen in a content rule:
"After the end of the advertising message broadcast on TV, the mandatory identification of the physician's details (if an office) or of the medical technical director (if an establishment/health service) must be displayed on a single-colour card, with centred text, perfectly legible and visible, held still in the video for a period allowing it to be read. Fonts from the Humanist typeface family must be used. The CRM number and the RQE number (where applicable) are mandatory…"
In the same chapter, however, the rule for pieces displayed over the internet is different: identification must appear "on every frame, legibly" — and the chapter's example adds "and horizontally".
And there is the honest problem: a cloud-based indoor TV is a television set displaying a piece delivered over the internet. It is literally both at once. The Manual does not say which of the two regimes applies — and that is exactly the doubt of whoever is about to build the playlist.
Our recommendation, and why: take the conservative route and keep identification legible on every frame. It satisfies both regimes at once, and it has an operational benefit of its own — in a waiting room, patients walk in halfway through the loop and almost never see a piece from the start. If identification only exists on the final card, much of the real audience never sees it. For a specific piece, a formal enquiry to the Codame settles it (see the FAQ).
A tempting, wrong reading: the Questions and Answers page summarises the TV rule by saying the name and CRM must be read "in a cadenced and audible manner", which suggests a TV piece needs audio. Chapter V shows it does not — the "cadenced, paused and perfectly audible" voice-over is the radio spot specification. On TV the requirement is visual. In other words: an indoor TV running with no sound does not conflict with the rule — what it does demand is that the card actually be legible on screen, which is the subject of that article.
Before-and-after, sub-item by sub-item
Here is the core. The claim that circulates — "the CFM bans before-and-after" — is wrong. Article 14, II allows the use of patient images for educational purposes to demonstrate "the results of techniques and procedures". What the rule does is attach conditions, and the conditions are cumulative. The table below translates each sub-item into a production obligation.
| Requirement (article 14, II) | What it forces on the TV piece |
|---|---|
| "a" — image use must be accompanied by "educational text containing the therapeutic indications, factors that influence possible outcomes and a description of the complications described in the scientific literature" | The piece stops being a photo carousel and gains a text block on screen, with reading time. On a muted medium seen from a distance, that means large type and more seconds of display. |
| "b" — demonstrations must be presented as "a set of images containing indications and satisfactory, unsatisfactory and complicated outcomes arising from the intervention" | This is the sub-item that kills the commercial piece. There is no "before-and-after" of one beautiful case: the set must also show what did not work and what went wrong. |
| "c" — "where applicable, present outcomes for different body types and age ranges, as well as immediate, intermediate and late outcomes" | Requires an archive. A piece built from two cases of the month does not comply. |
| "e" — "the use of procedure images that identify the patient is forbidden" | No recognisable faces, distinctive tattoos, name badges, on-screen names or framing that allows identification. |
| "f" — "any editing, manipulation or enhancement of the images is forbidden" | See the next section: the Manual clarifies the scope of this, and the difference is practical. |
| "g" — reposted patient selfies and "testimonials about the physician's work must be sober, without adjectives denoting superiority or implying a promise of results" | Rules out the enthusiastic testimonial, which is the industry's default format. And there is still the numeric cap — see the testimonial section. |
| "i" — when images come from the service's own archive: obtain authorisation, respect modesty and "guarantee the anonymity of the patient who provided the images, even if authorisation for disclosure was granted" | Anonymity is mandatory even with a signed release. The signature does not free the face. |
Chapter XII of the Practical Application section also closes a door many try to open and adds a very concrete content ban for the aesthetics sector:
"Posts of procedure results or of before-and-after in isolation are not allowed." … "Images of female breasts, the gluteal region or intimate areas may not be used" — both for modesty and privacy and because "it is also a policy of the social networks themselves".
The honest reading: a "before-and-after" that fits on a medical aesthetics waiting room screen is essentially not a sales piece. It is educational material with result images inside it. Anyone who puts up a sequence of beautiful cases, with the patient's face and an enthusiastic testimonial, is in breach — from inside a permission.
The four-scene storyboard the CFM itself describes
This is the most useful part of the rule for whoever produces the piece, and it is published. Chapter XII and the Questions and Answers page describe the before-and-after piece in four mandatory stages. Turned into a screen script:
| Scene | What the rule requires | May be |
|---|---|---|
| 1 | Presentation of the condition or the aesthetic appearance that bothers the patient, stating that the physician is the professional best qualified to diagnose the problem and point out the appropriate courses of action, and indicating the best treatment | Text, video, illustration or stock imagery |
| 2 | The "before": photos or videos of patients prior to treatment, "using at least four different patients" | Real photographs |
| 3 | The "after": photos or videos following the intervention, "using images of at least four different patients" and, where possible, outcomes for different body types and age ranges | Real photographs |
| 4 | Description of possible unsatisfactory outcomes and complications | "Illustrations, photographs or text" |
The chapter records that "items 2 and 3 are real photographs; 1 and 4 may be illustrations, third-party images or images from the medical literature (respecting copyright and data protection law)". And — directly relevant to the playlist — it authorises the video format with an editing specification:
"The images may be compiled into a video, or on a website…" … "If the images are compiled into a video, the exposure time must be the same for all cards, with at least 2 (two) seconds for each frame."
Notice what that editing rule prevents. A sales piece would leave the "after" on screen for six seconds and flash the complications frame for one. The rule demands equal time for every frame, with a two-second floor each. Scene 4 is not a footnote: it occupies the same screen time as the beautiful result. That, combined with the educational text from sub-item "a", gives the real dimensions of the piece — and explains why it hardly fits in a 15-second slot.
Image editing: the two competing wordings
There are two wordings on the same subject, and publishing only one of them misleads in both directions.
| Source | Text | In practice |
|---|---|---|
| CFM Resolution 2,336/2023, article 14, II, "f" | "Any editing, manipulation or enhancement of the images is forbidden." | Read in isolation, it suggests you cannot even crop the photo. |
| Manual, Practical Application, Chapter XII | Images "may not undergo enhancements that distort the outcome portrayed through the use of software such as Photoshop, Movavi, Lightroom, Canva and similar. It is permitted, however, to use such tools in order to crop, adjust light and sharpness or add privacy bars (for the purpose of preserving the patient's identity or modesty), provided such editing does not distort the outcome" | Technical adjustment yes; dressing up the outcome no. Cropping, light, sharpness and privacy bars are cleared — and the privacy bar is in fact the route to complying with anonymity. |
The difference is operational: the very tool that would be "forbidden" under the blunt reading of sub-item "f" is the one the clinic uses to comply with sub-item "e" (not identifying the patient). The test is not the tool — it is the effect. If the editing changes how the outcome is perceived, it is forbidden; if it crops, brightens or protects identity without altering the outcome, it is allowed.
Patient testimonials: the cap is "twice per semester"
The testimonial is the piece aesthetics marketing asks for most and the hardest to defend on a looping screen — and the reason is a published number. The Manual's Questions and Answers page states:
"May a physician repost patient praise? Yes, provided it is not sensationalist and does not occur repeatedly. Repeatedly means a frequency greater than twice per semester."
That cap was written with social media in mind, where a post is a dated event. An indoor TV is a different format: the piece enters the loop and plays dozens of times a day, throughout opening hours. Two displays per semester is a limit the medium blows through on the first morning. The format is repetitive by construction, not by editorial choice.
Add the content requirements: article 14, II, "g" demands testimonials be "sober, without adjectives denoting superiority or implying a promise of results", and article 11, XII forbids "guaranteeing, promising or implying good treatment outcomes". A testimonial that passes both filters is usually no longer the testimonial the clinic wanted to air.
Honest conclusion: a patient testimonial in a TV playlist is the hardest item in the whole schedule to sustain. Not because a provision says "banned on TV", but because sober content plus a frequency cap does not survive a loop. If the clinic wants social proof on screen, the path with least friction is institutional — years in business, the team's training within registered titles, the premises — rather than the patient's words.
Pricing on screen: under CFM the official answer is yes
Here the medical regime surprises anyone coming from the dental world. The Codame answers, in the Manual:
"May a physician advertise consultation prices and offer promotions? Yes. What they may not do is run tied promotions, of the sort that offer a given procedure if the patient pays for another service."
So a price list on screen is, under the CFM regime, an allowed piece — with the specific ban on tied promotions and, of course, without tripping the general prohibitions of article 11 (no promise of results baked into the offer).
Do not generalise this to "clinics". Under the dental regime the situation differs: the written provision is restrictive and there is declared divergence about the reach of the competition authority decision that prompted CFO Resolution 271/2025 — which is why our recommendation there is explicitly conservative, keeping prices and instalments off the screen. The contrast is detailed in the sibling article on what you can air on a dental office waiting room TV under Brazil's dental council rules — there, unlike here, the legal entity's before-and-after does not go on at all. Same environment, different councils, opposite answers.
Five pieces marketing asks for and the rule blocks
All anchored in article 11, which lists the prohibitions:
- "Our equipment is the best." Item II forbids "attributing privileged capability to equipment" and item IX forbids "advertising the use of techniques in a way that attributes privileged capability to them, even if the physician is the only one performing it". Genuine exclusivity does not license the piece.
- Unregistered equipment. Item III forbids "advertising equipment and/or medicines without Anvisa registration, or that of its successor agency". In an equipment piece, the script has to state approved indications and properties — the Codame answers that advertising devices and treatments is allowed provided the "indications and properties approved by Anvisa" or its successor, and authorised by the CFM, are stated.
- Promise of results. Item XII forbids "guaranteeing, promising or implying good treatment outcomes". "Implying" is the word that catches most of the sector's advertising output.
- Sensationalism and self-promotion. Item XVI forbids "behaving in a sensationalist or self-promotional manner", and §2 defines the term — including sub-item "a" ("advertising a procedure with the aim of extolling and prioritising one's practice as a physician or the place where one works"), sub-item "d" ("presenting in public a technique, approach or scientific method that should be limited to the medical environment") and, above all, sub-item "f": "using visual representations and information in an abusive, misleading or seductive manner that induces the perception of guaranteed results". That sub-item is literally a description of a well-produced before-and-after video.
- Advertising material from a company the physician invests in. Item XIV forbids "running any advertising or keeping advertising material on the premises of one's office" or of the legal entity one belongs to, for companies in the pharmaceutical, optical, orthotics and prosthetics or medical supplies sectors, "when an investor in any of them". On the waiting room screen, that means a conflict-of-interest check before accepting any third-party advertising slot.
Friction with another of our articles, stated openly: we publish a piece on sales triggers on indoor TV. It applies to retail. In a healthcare establishment, every trigger goes through the article 11 filter first — urgency, scarcity and social proof are exactly the constructs items XII and XVI reach. It is not the same playbook, and this article is the filter that belongs before that one.
Live procedures on screen: forbidden
Article 11, VIII forbids "displaying images of consultations and procedures transmitted in real time, with techniques or approach methods, even with the patient's express authorisation", except for the cases in article 13, IV and article 14, II, "d" (which covers external filming crews at births).
This provision deserves attention because the capability exists and is sold: going live on every screen in the establishment is a legitimate, useful use case — a retail launch, a message from the chain's owner, an event. In a medical clinic, that same capability has a forbidden use: streaming a consultation or procedure in real time to the waiting room is out, and the patient's authorisation does not change it, because the provision already anticipated that scenario.
The data protection layer, in three articles
The council rule is one layer; data protection is another, and they converge. Three provisions of Law 13,709/2018 (Brazil's LGPD) are enough for the screen case:
- Article 5, II — "data concerning health" is sensitive personal data when linked to a natural person. A patient's photo tied to a procedure is exactly that.
- Article 11, I — processing sensitive data may only occur "when the data subject or their legal representative consents, in a specific and highlighted manner, for specific purposes". A generic "image use" release does not cover display on the waiting room TV: those are different purposes, and the law asks for specificity.
- Article 5, III — anonymised data is data "relating to a subject who cannot be identified, considering the reasonable technical means available at the time of processing".
The convergence is convenient: the route the CFM already imposes — mandatory anonymity, privacy bars allowed — is also what reduces exposure on the data protection side. If the piece identifies nobody, the personal data layer largely leaves the stage. For the more common case of a person's photo on screen outside a clinical context, see our article on employee photos on the company TV and Brazil's data protection law.
Piece approval checklist
For the Medical Technical Director to sign before a piece enters the playlist. A piece only goes up with every applicable item ticked.
- Scope — is the advertised procedure medical aesthetics (invasive)? If so, this whole list applies. If the responsible professional belongs to another council, the piece goes to that council's rule.
- Identification — does the piece carry name, CRM and the word MÉDICO? Specialty + RQE when registered, or "NÃO ESPECIALISTA" on the line below when not? The establishment name with its CRM registration and the Medical Technical Director's name?
- Legibility — is identification on a single-colour card, centred, still and legible, in Humanist typeface, with uniform font, size and colour, no bold? If it is a results piece, is identification on every frame (conservative route)?
- Timing — does the final card stay on air for at least two seconds? If it is a before-and-after video, do all frames have the same duration, at least 2 seconds each?
- Before-and-after — does the piece have all four scenes? At least four different patients in the "before" and four in the "after"? Educational text with indications, factors influencing outcomes and a description of complications? Does it show unsatisfactory outcomes and complications?
- Anonymity — no identifiable patient, even with a signed release? No images of female breasts, gluteal region or intimate areas?
- Editing — only cropping, light/sharpness adjustment or privacy bars? No "enhancement" that changes how the outcome is perceived?
- Language — no promise, guarantee or implication of a good result? No privileged capability attributed to a device or technique? No sensationalist or self-promotional tone?
- Testimonial — if present, is it sober, free of superiority adjectives and of promises? Was display frequency in the loop considered against the twice-per-semester cap?
- Equipment — is it registered with Anvisa? Does the piece state approved indications and properties?
- Third parties — does the advertising slot on the screen involve a pharmaceutical, optical, orthotics/prosthetics or medical supplies company in which any physician of the house is an investor? If so, it is forbidden.
- Real time — the piece does not stream a consultation or procedure live.
- Residual doubt — if doubt remains about this specific piece, a formal enquiry was made to the regional council's Codame before it went up.
What is left for the screen — and it is a lot
An article about rules risks ending in "nothing is allowed", and that is not the case. The Resolution restricts the results piece, not the screen. What goes on without friction:
- Health guidance and post-procedure care — what to do in the first 48 hours, what avoids complications, when to call the clinic. It is the most useful content for someone sitting in the waiting room and the closest to the "educational purpose" the rule itself privileges.
- Indications and contraindications for each procedure offered, in plain language.
- Team introduction within the titles actually registered, with correct identification.
- A tour of the premises — the Codame answers directly: "May a physician show their office? Yes, as long as no patients are identified."
- Equipment, with indications and properties approved by Anvisa and authorised by the CFM.
- Operational information — waiting times, queue order, notices, opening hours, contact channels.
- Institutional content — the clinic's history, partnerships, health campaigns.
- Pricing, under the CFM regime, with tied promotions excluded.
For the editorial side of building that schedule — length, where content comes from and pacing — the reasoning in our article on the dental office waiting room TV transfers almost entirely; what changes from one sector to the other is the rule, which is the subject of this page.
Closing caveat. This article gathers the provisions and the published official answers, with a link to each source, and does not replace analysis of a concrete piece. For a specific piece, a formal enquiry to the Codame of your regional council is the route provided for in article 15 of the Resolution — and in the Medical Advertising Manual the CFM publishes the address [email protected] for such questions, which are analysed by the Medical Disclosure Committee.
Frequently asked questions
Can before-and-after patient photos air on an aesthetic clinic waiting room TV?
If the patient signs a release, can we show her face?
Can we brighten or crop the photo so it looks better on screen?
Do we really have to show cases that did not work out alongside the good ones?
My clinic has no physician, only an aesthetician. Do CFM rules apply to me?
Can a video testimonial go into the playlist?
Do CRM and RQE numbers have to appear on the piece running on the TV?
Who is liable if the piece on the TV breaks the rules?
Can a procedure be streamed live to the waiting room TV?
Can the clinic sell advertising slots on its TV to other brands?
What can air on the waiting room TV with no risk at all?
How many times can the same patient testimonial be displayed?
Can procedure prices be advertised on the clinic TV?
Does the CRM number have to appear on every frame of the video?
My indoor TV has no sound. How do I comply with the "read audibly" part?
Can we show the clinic interior and the equipment on screen?
The professional has no RQE. Can they appear as a specialist on screen?
Where do I get a ruling on a specific piece?
I saw a recommendation to fill the screen with before-and-after, testimonials and promotions. Should I follow it?
What makes good advertising copy for an aesthetic clinic?
What does a receptionist need to know about the waiting room screen?
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