Unit 3.6 Paper 2

Regulations on Advertisements for the RES Exam

Last reviewed 12 October 2026

Unit 3.6 is one of the most heavily examined units in Paper 2, and one of the most specific. Nearly every question turns on a short list of concrete requirements: what the advertisement must show, whose consent it needs, what it may not say, and when it must be taken down. The rules sit in the Council for Estate Agencies’ Practice Guidelines on Ethical Advertising and in the codes under the Estate Agents (Estate Agency Work) Regulations 2010, with the Personal Data Protection Act’s Do Not Call provisions and the Housing Developers Rules layered on top.

Key points

Non-classified advertisements, including every portal listing, flyer, banner and social media post, must show five particulars as registered with CEA: the salesperson’s name, registration number and contact number, and the estate agent’s name and licence number.
A newspaper classified advertisement needs only the salesperson’s CEA-registered name (full or abbreviated) and CEA-registered contact number.
Consent to advertise may be in writing, by SMS or by any verifiable mode, must come from all owners, and must be obtained by each salesperson who advertises the property.
Copied advertisements are strictly prohibited, because the copier has no consent of his own; same agency, shared commission or new photographs make no difference.
Advertising without consent, or a property that is no longer available, is a prohibited dummy advertisement — including where the aim is only to collect leads or price data.
Advertisements must be removed as soon as practicable once the property is unavailable or the agency agreement ends, whichever is earlier; there is no grace period.
Titles such as “Specialist”, “Expert” or “King of”, guarantees of price above valuation or of a COV, and the phrases “no co-broke”, “already co-broke” and “no agents” are prohibited.
The advertised price must match the client’s instructions, and photographs of another property or misleading alterations are prohibited.
The key executive officer must approve all advertisements, or run a structured approval process, before they are issued; CEA does not pre-approve advertisements.
Property marketing is a “specified message” for Do Not Call purposes, and a DNC check result is valid for only 21 days from receipt.

Where the advertising rules come from

Three instruments matter. The Code of Ethics and Professional Client Care, the First Schedule to the Estate Agents (Estate Agency Work) Regulations 2010, binds every salesperson. Its paragraph 12 is the advertising paragraph: correct identification by registered name, contact number, licence number and registration number; verifiable claims and accurate property descriptions; prior client consent, with the advertisement matching the client’s instructions; the client’s written consent before transaction details are published; and removal of the advertisement once the property is no longer available.

The Code of Practice for Estate Agents, the Second Schedule, binds the agency. Its paragraph 4 requires documented management and supervision systems, and expressly requires the estate agent to vet all publicity and advertising before publication.

The operational detail is in CEA’s Practice Guidelines on Ethical Advertising (PG 02-11), issued on 29 June 2011 and effective 1 August 2011; the version current as at October 2026 is version 2.0, dated 10 December 2020. They do not operate as a licensing scheme: CEA does not pre-approve individual advertisements. Approval is an internal matter, and the key executive officer must approve every advertisement, or operate a structured approval process, before it is issued, internet advertising included. A less serious breach may attract a Letter of Censure with a financial penalty of up to $5,000.

The mandatory particulars, by type of advertisement

The division candidates must know cold is between non-classified and classified advertisements. A non-classified advertisement — a flyer, pamphlet, banner, website, property-portal listing, social media post or online advertisement of any kind — must show five particulars, all exactly as registered with CEA: the salesperson’s name as it appears in the Public Register; the salesperson’s registration number; the estate agent’s name; the estate agent’s licence number; and the salesperson’s CEA-registered contact number. The guidelines go further and require the two numbers to be labelled, as “Estate Agent Licence Number” and “Salesperson Registration Number” or alternatively “CEA Licence Number” and “CEA Registration Number”. A social media profile used for estate agency work must likewise carry the licence and registration numbers.

A classified advertisement in a newspaper is treated more leniently. It needs only the salesperson’s CEA-registered name, which may be given in full or abbreviated, and the CEA-registered contact number. Licence and registration numbers are not required there. This is the trap in a great many questions: a short classified advertisement showing a name and a registered number is compliant, while the same content in a portal listing or on a flyer is not.

Two further channels have their own rules. An SMS advertisement follows the classified requirements for name and contact number but must also include a number for unsubscribe requests. An email advertisement must carry the names, the licence and registration numbers and an unsubscribe option, and its subject line must begin with “<ADV>” followed by a space. Outdoor advertising brings in other agencies: an outdoor sign must display the BCA licence number on its front, and road signs must also show the LTA approval reference, a serial number and an expiry date. Nothing in these lists requires a salesperson’s NRIC number, the owner’s name or contact details, or the asking price, and publishing the owner’s particulars would raise data-protection problems of its own.

Non-classified (flyers, banners, portals, websites, social media): salesperson’s name, registration number and CEA-registered contact number, plus the estate agent’s name and licence number
Classified (newspaper): salesperson’s CEA-registered name (full or abbreviated) and CEA-registered contact number only
SMS: as for classified, plus a number for unsubscribe requests
Email: names, licence and registration numbers, an unsubscribe option, and a subject line beginning “<ADV>” followed by a space
Outdoor signs: BCA licence number on the front; road signs also show the LTA approval reference, serial number and expiry date

A salesperson must obtain the owner’s prior consent before advertising a property for sale or rent. Three refinements are tested constantly. Consent may be given “in writing, by SMS or by any other verifiable mode of communication”, so a WhatsApp message from the owner is perfectly good and nothing requires a signed document. Where the property has more than one owner, consent must come from all of them, so one joint owner’s agreement is not enough whatever share he holds. And where two or more salespersons advertise the same property, each must obtain the owner’s consent for himself. Consent given to one salesperson does not travel to a colleague, a co-broking partner or another agency, and signing an estate agency agreement does not by itself amount to consent to advertise. For a subletting, the salesperson must confirm that the owner has consented or that the tenant or sub-landlord is entitled to sublet.

That last rule is the reason copied advertisements are strictly prohibited. A salesperson who lifts another’s listing has no consent of his own, so the copy is unauthorised from the moment it is published. Being in the same agency, sharing commission with the listing salesperson, changing the photographs or putting his own name on it makes no difference.

Advertising a property without the owner’s authorisation at all falls within the prohibition on dummy advertisements, which covers both a property the salesperson has no consent to advertise and one that is no longer available — including where the purpose is merely to harvest enquiries or price data. On duplicate listings the guidelines set out no separate rule, so the position has to be reasoned from the rules that do exist: several listings of the same unit at different prices mislead the public and conflict with the requirement that the advertised price match the client’s instructions, so they are prohibited as misleading content, and a duplicate posted by a salesperson without his own consent is both a copied and a dummy advertisement.

False, misleading and prohibited content

The governing principle is short: an advertisement must not contain inaccurate, false or misleading content, claims must be verifiable, and property descriptions must be accurate. Beneath it the guidelines prohibit a list of specific things, and examiners draw on that list directly.

Self-conferred titles such as “King of”, “Mr”, “Specialist” and “Expert” are not allowed unless they can be substantiated, however strong the salesperson’s track record, and a claim such as “top producer” or “No. 1 agent” is permissible only if it is true and verifiable. Guarantees of results are prohibited: a salesperson may not promise to “sell high above value”, guarantee a cash-over-valuation figure or guarantee a price above valuation. Statements of returns, yields or capital gains must state their basis, cite a credible source, define the terms used and give the period of any past data, and market trend or forecast claims need support from reliable sources. All the terms of an advertised promotion must be disclosed up front, and footnotes and disclaimers must be set in at least font size 8 — small print cannot cure a misleading headline.

Photographs are a recurring question. A photograph may not be altered or enhanced so as to misrepresent the property, photographs of another property may not be used, interior shots must be of the actual interior, an exterior view must be taken from the unit advertised, and any illustrative image needs a clear qualifier. An unaltered photograph of the actual unit is exactly what the guidelines want. On use, a property may be advertised only for the use approved by URA or the competent authority, and dual use such as “office-cum-residential” may not be marketed; for non-residential space the approved use and the usable and void areas must be communicated clearly, so describing a strata area that includes an air-conditioner ledge as net usable space is misleading. Price must match the client’s instructions, which makes a low “bait” price a breach even though enquiries follow, and price claims may not rest solely on cash over valuation. Preferences on grounds of race or religion are prohibited, except where needed to comply with the Ethnic Integration Policy, and no advertisement may suggest a way of circumventing the law, such as HDB occupation rules. Phrases prejudicial to co-broking — “no co-broke”, “already co-broke”, “no agents” — are banned outright, even where the client asks for them. And transaction details, including specific floor levels and unit addresses, may not be disclosed without the written consent of all parties; publicly searchable caveat data does not displace that duty. Throughout, the client’s instructions never make prohibited content acceptable: the salesperson who publishes, and the key executive officer who vets, remain responsible.

When an advertisement must be removed

An advertisement must be removed as soon as practicable once the property is no longer available, or on termination of the estate agency agreement, whichever is the earlier. Questions on this point almost always give two dates and ask which one triggers the duty, and the answer is always the earlier event. If the option is exercised on 12 May and the agreement runs to 31 May, removal is due from 12 May. If the agreement is terminated on 12 June while the unit is still unsold, removal is due from 12 June, because the salesperson’s authority — and with it the consent to advertise — ended with the appointment. There is no grace period of fourteen days, thirty days or six months, and no need for the client to ask.

Leaving a listing up after either event is a dummy advertisement: a listing for a property that is not in fact available, which misleads the public whatever the salesperson says to callers afterwards. Relabelling the price, or keeping the listing to attract enquiries for other units, does not cure it, and a breach does not depend on anyone complaining. Two housekeeping requirements go with this: flyers and pamphlets must carry an issue date and be updated and reprinted when the information changes, and online listings must be removed immediately, or as soon as practicable, once they expire. The duty rests on the advertising salesperson and on the agency that must supervise her advertising, not on the portal that publishes it.

Developer projects, foreign property and the Do Not Call rules

Where the property is a unit in a licensed housing development, CEA’s guidelines apply and the developer rules apply. Rule 3 of the Housing Developers (Control and Licensing) Rules requires every advertisement for the project to state the developer’s name and licence number, the tenure of the land, the expected date of vacant possession, the expected date for the conveyance of legal title, and the location, including the lot and mukim numbers. Rule 6 prohibits false claims, references to Government patronage and unsubstantiated attributes. Note what is not on the prescribed list: the price per square foot, projected yields, the showflat address, the architect and the contractor. An artist’s impression showing a facility that is not in the approved plans misrepresents the development, and a disclaimer cannot rescue a picture of something that will not be built.

Marketing property abroad is regulated too, because “property” in section 3 of the Estate Agents Act 2010 means an interest in land whether in Singapore or elsewhere. Under the Practice Guidelines on the Marketing of Foreign Properties, effective 24 March 2023, the agency must do due diligence on the foreign vendor and the property and verify claims such as guaranteed returns against contracts that actually bind the vendor. A written risk advisory, signed by the key executive officer and stating that the transaction is subject to foreign laws, must be given before the buyer commits, with the buyer’s acknowledgment witnessed by the salesperson. Non-English materials need an English translation by a reasonably qualified translator, and records are kept for five years.

Finally, telemarketing. A message that offers or promotes land or an interest in land is a “specified message”, so property marketing falls within the Personal Data Protection Act’s Do Not Call provisions. The Registry has three registers — No Voice Call, No Text Message and No Fax Message — and under PDPC’s Advisory Guidelines on the Do Not Call Provisions, as revised on 1 February 2021, a check result is valid for 21 days from receipt, the earlier 30-day period having been shortened. A number on a register may be messaged only with the individual’s clear and unambiguous consent, evidenced in written or other accessible form, or under an Eighth Schedule exclusion such as a message to an organisation in a business-to-business context, one that facilitates or confirms a transaction already agreed, or genuine market research that promotes nothing. The “ongoing relationship” exclusion is narrow: it needs continuity, regularity and frequency, and PDPC’s position is that a once-off transaction is not enough, so a client from three years ago must be checked. Separately, and regardless of any check, the sender must identify himself and give readily usable contact information — a physical address alone is not enough — must not conceal the calling line identity on a voice call, and must not use dictionary attacks or address-harvesting software. Buying a list transfers no consent and no responsibility.

Terms to know

Non-classified advertisement: Any advertisement other than a newspaper classified — flyers, pamphlets, banners, websites, property portals, social media and online advertising — which must carry the five prescribed particulars.
Classified advertisement: A newspaper classified, which need show only the salesperson’s CEA-registered name, full or abbreviated, and CEA-registered contact number.
Dummy advertisement: An advertisement for a property the salesperson has no consent to advertise, or one that is no longer available, including a listing kept up to gather enquiries or price data.
Key executive officer (KEO): The officer responsible for the estate agent’s operations, who must approve all advertisements or operate a structured approval process before they are issued.
Specified message: Under the Personal Data Protection Act, a message a purpose of which is to advertise, promote or offer goods, services, land or an interest in land, or a business or investment opportunity.
Do Not Call Registry: The PDPC register, in three parts for voice calls, text messages and faxes, which a sender must check before sending a specified message to a Singapore telephone number.
Risk advisory: The written advisory required before a buyer commits to a foreign property, signed by the key executive officer, setting out the risks and that the transaction is subject to foreign laws.

Frequently asked questions

What must appear in a property portal listing?

A portal listing is a non-classified advertisement, so it must show five particulars exactly as registered with CEA: the salesperson’s name, the salesperson’s registration number, the estate agent’s name, the estate agent’s licence number and the salesperson’s CEA-registered contact number. The lighter requirement of a name and contact number applies only to newspaper classified advertisements. There is no requirement to publish an NRIC number, the owner’s details or the asking price.

Does a WhatsApp message count as the owner’s consent to advertise?

Yes. CEA’s Practice Guidelines on Ethical Advertising accept consent given “in writing, by SMS or by any other verifiable mode of communication”, so a WhatsApp or similar message is an acceptable mode and nothing requires a signed document. Two conditions still apply: where there is more than one owner the consent must come from all of them, and every salesperson who advertises the property must obtain consent for himself.

Can I copy another salesperson’s listing if the details are accurate?

No. Copied advertisements are strictly prohibited, because each salesperson who advertises a property must obtain the owner’s consent personally and the copier has none. Working in the same agency, co-broking on the property, sharing the commission or substituting your own photographs does not supply that consent.

When exactly must a listing be taken down?

As soon as practicable once the property is no longer available, or when the estate agency agreement is terminated, whichever happens first. So a sale or an exercised option before the agreement’s expiry date triggers removal on the earlier date, and a termination while the property is still on the market also triggers it, because the consent to advertise ended with the appointment. Leaving the listing up is a prohibited dummy advertisement.

Can an advertisement say “no agents” if the seller asks for it?

No. The guidelines expressly prohibit phrases prejudicial to co-broking, including “no co-broke”, “already co-broke” and “no agents”, and a client’s instruction does not make prohibited content acceptable. The same applies to self-conferred titles such as “Specialist” or “Expert” and to guarantees of a price above valuation.

How long is a Do Not Call Registry check valid?

Twenty-one days from receipt of the results, under PDPC’s Advisory Guidelines on the Do Not Call Provisions as revised on 1 February 2021; the earlier period of 30 days no longer applies. A message promoting land is a “specified message”, so property marketing is covered, and a fresh check is needed before any later send unless the recipient has given clear and unambiguous consent in written or other accessible form.

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