On the waiting room TV, which is the clinic's channel (a legal entity), patient before-and-after imagery does not belong: the authorisation in Resolution CFO-196/2019 belongs to the dentist who performed the procedure, and the council states expressly that for legal entities publication remains prohibited. Also out: the "during" of a procedure, prices, payment terms and "free assessment". In: informative video, graphic animation, oral health guidance and team presentations within registered titles — always with the name and registration number on the piece. Liability is joint between owner, technical director and professionals.
A note on method. Every provision cited here was read at the official source of the Brazilian Federal Council of Dentistry: the PDF of the Code of Dental Ethics (Resolution CFO-118/2012), the official FAQ on Resolution CFO-196/2019 and Resolution CFO-271/2025. The published PDF of the Code is not consolidated: Resolution CFO-271/2025 changed four provisions and the PDF still shows the old wording — which is why, whenever this article cites articles 20 (VIII and X), 32 (XIII) and 44 (XIV), it cites the 2025 version. Nothing here replaces asking your regional council about a specific piece. These rules apply to dental practice in Brazil.
The reception TV is "communication and publicity", not decoration
The first mistake when building a clinic's playlist is assuming the reception screen is an internal environment, and that an internal environment is not an advertisement. Chapter XIV of the Code of Dental Ethics (Resolution CFO-118/2012) deals with communication and publicity, and it does not distinguish by medium: a piece running eight hours a day in front of people waiting for care is publicity of a dental service, exactly like a post, a billboard or a flyer.
Two articles close that door. Article 43 requires advertisements to carry the name and registration number of the individual or legal entity — and, for a legal entity, also the name and number of the technical director. Article 46 states that the chapter's rules apply to clinics, polyclinics, operators, health plans and any other entities. In other words: the clinic is inside the rule, not outside it.
The practical consequence changes the work of whoever produces the content: this affects the layout of the piece, not just its subject. Every piece that advertises a procedure has to carry a fixed identification — an art requirement that belongs in the template before the first video enters the playlist.
Professional vs. clinic: the distinction nobody makes
This is the section that justifies the article. Resolution CFO-196/2019 is always cited as the rule that "released before-and-after imagery". It did — for the dentist who performed the procedure, with prior written informed consent, with name and registration number on the publication and with no promise of results. What almost no published content records is what the council itself answered, in the official FAQ of that resolution, about legal entities:
"Images of diagnosis and of the conclusion of a procedure are not authorised for legal entities, the clinics. The rule is clear: publication is allowed only by whoever performs the procedure (…). In the case of a clinic, a legal entity, Resolution 196 does not apply and, consequently, it cannot make that kind of publication. For legal entities, publication remains prohibited."
Applied to the reception screen, that paragraph settles the whole question. The waiting room TV is by definition the clinic's institutional channel: the publisher is the legal entity, even if the piece was produced by the dentist and carries their registration number. A patient's clinical case does not belong there.
A warning for agencies and content suppliers. Taking the post a dentist published on their own profile — lawfully, with consent and identification — and reusing it in the clinic's playlist changes the publisher. On the profile, the publisher was the professional who performed the procedure. On the reception TV, the publisher is the clinic. The piece is the same; the regulatory framing is not.
It is worth saying plainly that this contradicts what search engines' automatic answers were serving in September 2026: asked about showing before-and-after imagery on a waiting room TV, Google's AI summary replied that "you can display before-and-after photos", drawing no line between the professional and the legal entity. That line exists, it is written down, and it comes from the council itself.
The three moments of clinical imagery
Resolution CFO-196/2019 does not treat "patient photo" as a single block. It separates moments, and each one has its own regime:
| Moment | Regime | On the reception TV |
|---|---|---|
| Diagnosis (initial situation) | Authorised for the dentist who performed the procedure, with prior consent, name and registration number on the piece; publishing another professional's case is forbidden (articles 2 and 4) | No — the publisher is the legal entity |
| Conclusion (final result) | Same regime as diagnosis, with an express ban on sensationalism, self-promotion, commercialisation and promises of results (article 2, §1) | No — same reason |
| Course and performance (the "during") | Expressly prohibited for videos and images, except in scientific publications (article 3) | Never, by any publisher |
There is one more trap that kills many well-intentioned pieces: §1 of article 1 prohibits images that make equipment, instruments, materials and biological tissue identifiable. The close-up of the handpiece, the needle, the syringe and the operative field is out twice over — by the "during" rule and by that paragraph. In practice, the behind-the-scenes video the industry loves to produce is exactly the one that fits the screen least.
A provision that does not exist. A citation circulates — including in AI answers — of an "article 3, item IV" of Resolution CFO-196/2019, supposedly banning billboards, panels and visual communication to the public. That item does not exist. The resolution has five articles, and article 3 is the one about the course and performance of a procedure. The conclusion of this article about the reception TV rests on the council's official FAQ and on articles 43, 44 and 46 of the Code of Ethics — not on an invented provision.
What the council has already said about video specifically
A TV playlist is video, and there is official guidance on exactly that format. In the council's guidance on video publishing (published on 24 April 2024 and updated on 14 July 2025), the test reads like this:
"Showing procedures in videos on social media is allowed, PROVIDED THEY ARE INFORMATIVE VIDEOS, aimed at instructing the public about oral health and procedures recognised by the council (…). Attention: videos of the course of treatment, sensationalist videos or self-promotion are not allowed! Allowed, for example, are videos representing techniques and procedures with scientific recognition, such as graphic animations."
For whoever builds the grid, that is more useful than any list of prohibitions, because it gives both the criterion and an example of what is allowed: graphic animation is named explicitly as a permitted way to represent a technique or procedure. A clinic that replaces the real footage of a procedure with a 3D animation of the same procedure solves, in one move, the "during" problem, the identifiable-instrument problem and the identifiable-patient problem.
The playlist test then fits into one question per piece: does this piece instruct, or does it promote? If it teaches — what scaling is, why gums bleed, how to brush with braces — it fits. If it shows a patient's result to persuade, it does not.
The first three questions eliminate the piece; the fourth sends it back to design. None of them replaces asking your regional council about a concrete case.
The mandatory band: name and registration number
Article 43 of the Code of Ethics and article 4 of Resolution CFO-196/2019 say the same thing by two routes: advertisements and published images or videos must carry the professional's name and registration number; for a legal entity, add the name and number of the technical director. On a screen this becomes an art decision, and this is where most playlists fail without noticing:
- A fixed band at the bottom, inside the screen's safe area (some installations crop the edges).
- In every frame of the piece, not only in the last shot. The patient walks into the reception mid-playback and sees only what is on screen then — a credit that appears for three seconds at the end identifies nothing.
- Legible from three metres: on a Full HD screen, text under 28 px tall turns into noise at the real distance of a waiting room. Test it from the farthest chair, not from your monitor.
- If the piece is the clinic's institutional content, the identification is the legal entity's plus the technical director's. If it belongs to a specific professional, their name and number go in.
This requirement is why "grab a nice ready-made video online and drop it in the playlist" usually starts out non-compliant: generic material does not carry — and cannot carry — your identification.
Price, instalments and gifts — in the version in force
The most common piece on a clinic's TV is also the most exposed. Article 44, I treats as an ethics violation misleading or abusive advertising, "including with before-and-after expressions or images, with prices, free services, payment terms, or other forms that imply the commercialisation of dentistry". Along the same line, article 20, IX prohibits offering free or no-obligation consultations and diagnoses — which kills the "free assessment" piece. And article 44, VII names the word "popular" explicitly as patient solicitation and unfair competition.
A declared disagreement about pricing. In September 2026, Google's AI summary for the query "can a dentist advertise prices" (in Portuguese) answered that they can, relying on the CADE ruling (case 08700.002535/2020-91, August 2023) that supposedly barred the councils from punishing it. The organic results on the same page said the opposite. What this article verified at the primary source: article 44, I still reads that way in the text in force, and Resolution CFO-271/2025 — issued precisely in compliance with that ruling — touched discounts, discount cards, gifts and telemarketing, not article 44, I. What is not verified is whether the CADE reasoning reaches price disclosure itself. For the clinic's institutional TV, the recommendation here is conservative: price tables and instalments stay off the screen, and the question goes to the regional council before the piece airs.
And there is the other half of the story, which most indexed content still gets wrong — in the opposite direction. Resolution CFO-271/2025, of 18 June 2025, issued in compliance with the CADE ruling, dropped prohibitions that are still being published as if they were in force:
| Provision | What it says TODAY (2025 wording) | What LEFT the prohibition |
|---|---|---|
| Art. 20, VIII | Offering services, even indirectly, as a gift, prize or raffle | "Discounts" |
| Art. 20, X | Taking part in "gift vouchers" and/or similar schemes and other commercialising activities contrary to the good standing of dentistry | Discount cards, discount booklets and gift cards |
| Art. 32, XIII | Revoked (it barred association with discount card, financing and consortium companies) | |
| Art. 44, XIV | Solicitation via active telemarketing, portable or vehicle-mounted loudspeakers and sign holders, among other unfair competition practices | Discount cards and booklets, direct mail, promotional or group-buying websites and promotional stands |
What 271/2025 did not change: articles 44, I (price, free service, payment terms), 44, XII (before, during and after), 43, 45 and 33. Confusing the two is the costliest mistake in this section: discounts being allowed does not mean price tables are allowed on screen. These are different provisions, and only one of them changed.
Titles and specialties on screen
The piece that introduces the team is one of the best in the grid — and one of the easiest to get wrong. Article 44, II treats as a violation advertising a title or specialty the professional does not hold or has not registered. Article 43, §1, I requires fields of practice and procedures to appear only preceded by the specialty title registered with the regional council or the general practitioner qualification. And article 43, §2 adds the requirement that applies to the clinic: a legal entity that illustrates a specialty must have a professional registered in it on staff and make that list available to the public.
A current example, because it is the case that shows up most on reception screens: orofacial harmonisation is a recognised dental specialty in Brazil (Resolution CFO-198/2019, with competencies regulated by Resolution CFO-230/2020). So a piece advertising it depends on the clinic actually having a professional registered in that specialty — and that person's name identified on the piece, under article 43.
For playlist operations the practical rule is: the team piece is reviewed every time the team changes. A piece that was correct in January becomes non-compliant in July if the specialist left and nobody swapped the video — and swapping is exactly what a cloud-managed screen makes easy, as we explain in managing Indoor TV from your phone.
Patient testimonials: the grey area
In the rules read for this article, there is no provision that deals specifically with a patient testimonial. The answer has to be built from three things combined — and the result is conservative guidance, not a certainty:
- Article 44, V prohibits publishing clinical results through mass media and requires participation in publicity to have the exclusive purpose of clarification and education.
- Article 44, VI conditions the publication of any element identifying the patient on free and informed consent and on it not serving self-promotion or the benefit of the professional or the entity.
- The legal-entity barrier from the previous section still applies: the clinic is not authorised to publish diagnosis and conclusion, with or without consent.
The typical reception testimonial — a smiling patient saying the treatment changed their life — is, in practice, the publication of a clinical result for promotional purposes through the clinic's channel. The recommendation here is to keep it off the screen and, if the clinic insists, to submit that specific piece to the regional council first. Social proof in a dental waiting room works better through the route that does not depend on clinical cases: public reviews of the practice — a subject we cover in asking for Google reviews through Indoor TV, with one extra caveat here, because in dentistry the request may not offer anything in exchange nor amount to solicitation (article 44, VII).
When the subject is an ordinary person's image on screen, with no clinical component — the birthday photo, the customer tagged in a post — the axis is different: consent, data protection and image rights. That is all in birthday photos on a restaurant TV and consent. In a clinic the two regimes stack, and the council's is the stricter of the two.
Who signs off on the playlist (approval checklist)
Two rules turn the playlist into a governance item. Article 45 establishes that owners, the technical director and every other professional who contributed to a violation are jointly liable. Article 33 makes the technical director responsible for advising the institution in writing, including on the advertising techniques used, and for reporting violations to the regional council.
Read those two together and the conclusion is direct: the reception TV grid is a document the technical director approves. It is not the agency's job, nor the receptionist's who discovered the app. The checklist below is the minimum form of that approval — one line per question, one signature at the end.
| # | Check before the piece goes on air | Basis |
|---|---|---|
| 1 | Does the piece inform (teach oral health or a recognised procedure) rather than sell? | Council guidance on videos (2024/2025) |
| 2 | Is the piece free of patient imagery (diagnosis, conclusion or the "during")? | Res. CFO-196/2019, arts. 2 and 3 + official FAQ (legal entity) |
| 3 | Is the piece free of identifiable equipment, instruments, materials and biological tissue? | Res. CFO-196/2019, art. 1, §1 |
| 4 | Is the piece free of price, instalments, "free", "popular" and promises of results? | Code of Ethics, arts. 44, I and VII; art. 20, IX; Res. 196/2019, art. 2, §1 |
| 5 | Does the piece carry name and registration number — of the clinic and the technical director — in a fixed, legible band in every frame? | Code of Ethics, art. 43; Res. 196/2019, art. 4 |
| 6 | If the piece names a specialty or field of practice, is there a professional registered in it on staff, with the list available to the public? | Code of Ethics, art. 44, II and art. 43, §1, I and §2 |
| 7 | If the piece came from a third party (supplier, industry, agency), are authorship and usage rights documented — and is it not another professional's clinical case? | Res. CFO-196/2019, art. 4 |
| 8 | Has the piece been approved in writing by the technical director, with a date, and is the approved version the one on air? | Code of Ethics, arts. 33 and 45 |
| 9 | Is there a review date — is the grid revisited when the team, the services or the rules change? | Good practice derived from arts. 33 and 44, II |
Keep the completed checklist with the piece's assets. If the council asks, what protects the clinic is not the content being "reasonable" — it is a documented decision by someone registered with the council.
What is left for the screen — and it is a lot
After so many prohibitions, the common reaction is to switch the TV off. That is the wrong call, because what is left is exactly the content that works best in a waiting room — the kind that removes the objection born of not knowing:
- Oral health education: brushing, flossing, mouthwash, caring for braces, what to do after an extraction. This is the core of the "informative video" the council itself names.
- Procedure explainers without patients: what scaling is, the difference between types of braces, what a veneer actually is — translating the technical name answers half the questions that reach the front desk.
- 3D graphic animation of the procedure, with no blood, no needle and no identifiable instruments. It is the council's named example of what is allowed.
- The step that reassures: showing that anaesthetic gel is applied to the gum before the needle is the kind of information that changes a tense patient's expectation — and it involves nobody's clinical imagery.
- Team and facilities, within the limits of the titles and specialties section.
- Children's content in a paediatric clinic — a screen that keeps a child occupied is, on its own, better care.
- News and neutral entertainment, curated by category and shown without audio. What does not belong is live broadcast TV, with programming and third-party ad breaks the clinic did not choose.
How to build that grid from the day's procedure schedule — orthodontics in the morning, implants in the afternoon — is the subject of this article's sibling, the dental waiting room TV that explains treatment before the chair. Scheduling by shift, in practice, is in scheduling Indoor TV by time of day.
The same warning applies to anyone arriving here from retail marketing: the sales triggers that work in a store do not transfer directly to a clinic. We cover them in Indoor TV upselling triggers — and in dentistry the ruler is held by the dental council, not by an advertising self-regulation body.
Sizing the playlist by the real waiting time
One operational correction belongs here, because it travels alongside the content advice. The loop rule is that it must last longer than the average stay — never equal, never shorter. If patients wait 30 to 40 minutes and the playlist runs 30 to 40 minutes, the same piece comes back to the same person before they are called, and they stop watching. Recommendations of "a 20 to 30 minute loop" for a reception with a 40-minute wait fail in the same direction, only harder.
The arithmetic, with the recommended slack, is in how long an Indoor TV loop should be: measure the real wait in your reception and add 40% to 80%. In the dental case that slack has a good side effect — the longer the grid, the more room for genuinely educational content instead of three institutional pieces on repeat.
This article came out of an episode of Café & Tech — Indoor TV for Dental Clinics: How to Turn Your Waiting Room into Treatment Pre-Sales, with Mário Sérgio and Josimar Machado, published on 14 May 2026 (in Portuguese).
The episode covers the operation of the screen: the schedule, the playlist, the content the clinic already owns and the TV that sits switched off. The regulatory side is this article — including a correction to a passage of the episode itself, where it is claimed that before-and-after imagery can be shown in a clinic with no problem. Full episode at youtube.com/watch?v=rk5KEWVmQJ8.
Frequently asked questions
Can the clinic publish before-and-after images, or only the dentist who performed the procedure?
Can you post before-and-after photos in dentistry?
Does the regional council allow before-and-after posts?
Can a dentist advertise at all?
What can a dentist not post?
Can a dentist advertise prices?
Can a dentist advertise payment terms?
Can a clinic offer discounts or accept discount cards?
What does the regional dental council not allow you to post?
Do I need the patient's authorisation to show their photo on the waiting room TV?
Do the professional's name and registration number have to appear in the TV piece?
Who is liable if a TV piece breaks the rules — the dentist, the clinic or the agency?
What is allowed and what is forbidden in dental service advertising?
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