ASC compliance for real estate advertising in the Philippines
License to Sell, DHSUD Advertisement Approval, project completion date, payment terms, and the patterns that fail screening in Philippine real estate creative.
Real estate has its own layered approval process. Before a project ad reaches the ASC, it needs DHSUD's Advertisement Approval. The License to Sell must already be in hand. And the creative must carry specific disclosures in a specific way — developer name, exact location, License to Sell number, completion date, and more.
This is the working playbook for real estate creative — condominium, residential subdivision, commercial, memorial lots, and other DHSUD-regulated developments.
The two-stage approval path
Real estate creative goes through two regulators in sequence:
- DHSUD (Department of Human Settlements and Urban Development, the successor to HLURB) issues the Advertisement Approval for the specific material. This must be secured first.
- ASC reviews the material against the Code of Ethics and category-specific rules in Article VIII Section 8.
ASC will not screen real estate creative without the DHSUD Advertisement Approval Number in hand. Plan the calendar around the longer of the two timelines.
"Advertisement" vs "Announcement"
The Code distinguishes between an advertisement (which markets or sells the project) and an announcement (which only informs the public that a project exists, without marketing or selling). The two have different approval paths:
- Advertisements must be approved by DHSUD and comply with the ASC Code.
- Announcements do not require DHSUD approval but cannot include contact details, office addresses, or any information that directly or indirectly suggests sale or marketing.
The line between the two is policed strictly. An "announcement" that includes a sales hotline becomes an advertisement.
Mandatory information for broadcast, cinema, and digital video
Per Article VIII Section 8, video advertisements must include:
- The name of the owner or developer of the project.
- The location of the project including the name of the barangay and city or municipality.
- The License to Sell or Amended License to Sell number and date of issue.
Mandatory information for print, OOH, and static digital
Static advertisements must include:
- The name of the owner or developer.
- The exact location of the project including street name, barangay, city or municipality.
- The License to Sell or Amended License to Sell number.
- The Advertisement Approval Number.
- The approved project completion date as indicated in the License to Sell.
- The maximum selling price (for economic and socialized housing projects).
- For dealers, brokers, or authorised real estate agents named in the ad: their corresponding DHSUD registration numbers.
Visual representations — actual vs perspective
Any picture or illustration of the project, its features, facilities, or amenities must be captioned correctly: "actual photographs," "architect's perspective," "artist's illustrations," or a similar caption. The committee enforces this strictly. Renders shown without caption read as actuals — which they usually are not.
Amenities and improvements shown in the creative must conform to the project's approved site development plans, architectural plans, and work programs. Only amenities specified in the approved plans can be illustrated. Adding a marketing-imagined pool, clubhouse, or jogging path that isn't in the approved plan is a violation that can fall back on the developer.
Location and distance claims
Location and distance must be stated in a way that does not mislead about proximity, accessibility, or value. Specifically, the Code requires distance to be expressed in kilometres — not minutes, not "just minutes from," not "a short drive from." Vicinity maps must similarly indicate distance in kilometres.
This is the single most common preventable failure in real estate creative. Replace "10 minutes from BGC" with the actual kilometre measurement.
Payment terms and financing
No mode of payment or financing — reservation fee, initial deposit, down payment, required equity, instalment plan, schedule of payments, escalation, discount, interest rate — can appear in an advertisement unless the complete payment and financing scheme is fully disclosed in the ad, in accordance with the terms in the purchase reservation, contract to sell, or sales documents.
"₱20,000 down, move in immediately" needs the full scheme disclosed — total contract price, payment schedule, interest rate, balloon payments if any. Hooking the headline without the scheme is a violation.
What real estate ads cannot include
- Disclaimers. The Code specifically prohibits disclaimers in real estate creative. A developer cannot insert "subject to change without notice" or "renders for illustration only" as a defence. If the visual is an artist's illustration, it must be captioned as such.
- Other or future projects not covered by the License to Sell, unless they are part of a cluster development under HLURB Memorandum Circular No. 01 Series of 2015.
- Exaggerations or misleading information via text, illustration, or pictures.
Cluster developments
For projects within a cluster development, the master plan can be shown — but the advertisement must clearly specify which projects within the cluster are already covered by a License to Sell and which are not.
Announcements before License to Sell
Any announcement made before the License to Sell is issued cannot include:
- The office address or contact numbers of the owner, developer, or dealer.
- The names, office addresses, or contact numbers of authorised agents or brokers.
- Any information that conveys or suggests the sale or marketing of any lot, building, or unit.
Pre-selling and broker advertising
Pre-selling creative is permitted only after the License to Sell is issued and a DHSUD Advertisement Approval Number is granted. Broker and agent advertising must include their DHSUD registration number alongside developer information.
Social media posts by brokers and agents are increasingly within scope. Where a broker posts a project visual with brand assets, the same disclosure requirements apply.
Common reasons real estate ads get rejected
- Missing License to Sell number, Advertisement Approval Number, or completion date in the layout.
- Distance expressed in minutes instead of kilometres.
- Renders shown without "artist's illustration" caption.
- Amenities shown that aren't in the approved site development plan.
- Payment terms hooked without the full financing scheme disclosed.
- Disclaimers inserted as a workaround for visual or informational gaps.
- Pre-License announcements that cross the line into marketing.
- Broker creative without DHSUD registration number.
What to pre-screen before submission
- License to Sell and DHSUD Advertisement Approval issued.
- Developer name, project location, License to Sell number, and completion date all in the creative.
- All distances in kilometres. No "minutes from."
- All renders captioned correctly.
- Amenities and features cross-checked against approved plans.
- Payment terms either fully disclosed or pulled entirely.
- No disclaimers in the layout.
- Broker DHSUD registration numbers included where applicable.
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