Hello, this is attorney Lee Young-kyung at Cheongchul Law Firm.

On July 12, 2026, the Korea Fair Trade Commission (KFTC) announced that it had imposed corrective orders and a publication order on three plastic surgery clinics for violating Article 3(1)(2) of the Act on Fair Labeling and Advertising (the "Labeling and Advertising Act"; deceptive labeling and advertising). The clinics paid promotional models economic consideration such as surgery-fee discounts to write and post surgery reviews on beauty medical apps, internet cafes, and hospital websites, yet failed to disclose that economic interest.

This action carries important practical implications for aesthetic medical institutions such as plastic surgery and dermatology clinics and for hospital marketing staff, so we summarize it from an ad pre-review and compliance perspective. This column is based on the KFTC press release dated July 12, 2026 ("Pretending to be a review, pretending not to be an ad… sanctions on plastic surgery stealth advertising"), and please note that the final disposition may change depending on the outcome of appeals such as administrative litigation.

The disposition at a glance – Failing to disclose interests in paid surgery reviews is "deceptive advertising"

Where a plastic surgery clinic pays promotional models or testers economic consideration such as surgery-fee discounts and has them write and post surgery reviews on beauty medical apps, internet cafes, and hospital websites without disclosing the economic interest, this misleads consumers into believing the reviews were written voluntarily and objectively and obstructs reasonable purchasing decisions. Such conduct constitutes "deceptive labeling and advertising" under Article 3(1)(2) of the Act on Fair Labeling and Advertising (Labeling and Advertising Act). It was clearly confirmed that even a review written by a consumer who actually underwent surgery amounts to deceptive advertising if the receipt of economic consideration is not disclosed.

● Subject of disposition: Three plastic surgery clinics A, B, and C (advertising period from around 2018 to May 2026)

● Violating media: Beauty medical apps, internet cafes, hospital websites (including collecting, editing, and re-posting reviews by model)

● Disposition: Corrective orders (cease-and-desist and prohibition orders) + publication order on Clinic A (one-sixth of the full website screen, for six days)

● Parallel measures: Sharing suspected Medical Service Act violations with the Ministry of Health and Welfare; holding a meeting with the Korean Association of Plastic Surgeons and the Korean Medical Association (June 11, 2026)

1. Facts – The structure of managing promotional models and review advertising

Selecting promotional models and signing advertising contracts

From around 2018 until around May 29, 2026, Clinics A, B, and C recruited promotional models through their own websites, selected them through document screening, individual contact, in-person consultation, and final selection, and then signed advertising contracts to the effect that "surgery fees would be discounted in return for providing surgery reviews."

Real-time management of review writing

Each clinic used KakaoTalk accounts and the like to require promotional models to post hospital reviews on beauty medical apps and internet cafes once before surgery and monthly for one year after surgery, and managed the review content in real time, including specifying word counts and requiring before-and-after photos. Some clinics also imposed a separate deposit obligation on the promotional models.

Multi-layered posting of reviews without disclosing economic interests

Clinics A, B, and C did not have promotional models state the economic interest — that they "received economic consideration such as surgery-fee discounts" — when posting surgery reviews on beauty medical apps and internet cafes. They also collected and edited reviews by model, reconstructed them into a single post on the hospital website, and used them for advertising without disclosing the economic interest. The unfair advertising media and periods by business operator are set out in the table below.

2. Applicable law – Article 3(1)(2) of the Labeling and Advertising Act, "deceptive advertising"

The provision applied in this case is Article 3(1)(2) of the Act on Fair Labeling and Advertising (Labeling and Advertising Act). The relevant provision reads as follows.

3. The KFTC's three elements for finding illegality

Deceptiveness – Omission of information material to consumer decisions

The KFTC found that whether a surgery review was written in exchange for economic consideration is information that materially affects a consumer's choice of a plastic surgery clinic; nonetheless, Clinics A, B, and C omitted this and advertised as if the promotional models had undergone surgery and written the reviews voluntarily and objectively, so "deceptiveness" was recognized.

Likelihood of consumer misperception

It was recognized that the reviews, appearing to be objectively written without any economic interest, were likely to deceive consumers or lead them to be mistaken.

Harm to fair trade

It was assessed that this obstructed reasonable purchasing decisions in choosing a plastic surgery clinic and was likely to harm the fair trade order in the relevant market.

4. Disposition by business operator

5. Frequently asked questions from hospital advertising managers (FAQ)

Q1. If a promotional model who actually had surgery writes a review of their own experience, it is a "fact," so isn't it fine?

No. Even a review written by a consumer who actually underwent surgery constitutes "deceptive advertising" under Article 3(1)(2) of the Labeling and Advertising Act if it was written in exchange for economic consideration such as a surgery-fee discount and does not disclose that fact (the economic interest) (KFTC announcement of July 12, 2026).

Q2. If we disclose only on the beauty medical app and internet cafe reviews, are the re-posted versions on the website fine?

No. Even when reviews by model are collected, edited, and re-posted on the hospital website, the economic interest must likewise be disclosed. In this case, too, the edited re-posting on the website was an important basis for the finding of illegality.

Q3. What wording makes disclosure safe?

The principle is to place wording that consumers can easily recognize — such as "This review was written in exchange for economic consideration such as a surgery-fee discount" — in the same size and position as the review body. Abbreviations (displaying only #ad or #sponsored) may create a risk of consumer misperception.

Q4. What sanctions can be imposed for a violation?

Under the Labeling and Advertising Act, corrective orders, publication orders, and administrative fines (surcharges) may be imposed, and depending on the case it may even lead to criminal punishment (imprisonment of up to two years or a fine of up to KRW 150 million). In this case, too, Clinic A was even subject to a publication order (one-sixth of the full website screen, for six days).

6. Cheongchul Law Firm's compliance advisory for plastic surgery and hospital advertising

Cheongchul Law Firm has experience advising medical institutions and advertising agencies across the multi-layered regulatory fields relating to hospital advertising, including the Labeling and Advertising Act and the Medical Service Act (prior review of medical advertising, prohibition of patient inducement and referral, etc.).

In particular, advertising practice for hospitals such as plastic surgery clinics is a highly sensitive area where the Labeling and Advertising Act and the Medical Service Act apply in overlap, and as advertising media diversify — as in this KFTC action — the risks grow accordingly. If you need a prior legal review of promotional model or tester reviews, beauty medical app advertising, or website posts, or if you have already received notice of a KFTC investigation, please feel free to contact Cheongchul Law Firm.