Anyone planning to open a med spa in Ontario quickly finds that the province has no single "med spa licence". Instead, the rules come from the Regulated Health Professions Act, 1991 (RHPA), which restricts certain "controlled acts" to regulated professionals, and from the College of Physicians and Surgeons of Ontario (CPSO), which sets out what physicians must do when they delegate those acts or act as a clinic's medical director. This guide explains, from those primary sources read on 9 November 2026, which treatments fall inside the restricted list, what the CPSO expects of delegating physicians and medical directors, and what a clinic needs to record. It is general information, not legal advice, and a health-law lawyer should review any real plan.
Key takeaways
- The RHPA restricts "controlled acts", including performing a procedure on tissue below the dermis and administering a substance by injection. Botox-style injections and dermal fillers are the usual med spa examples.
- A physician may delegate a controlled act, but remains responsible for the patient care given through delegation.
- The CPSO says a delegating physician generally has to assess a new patient before, or within two business days of, the delegate's first controlled act, and has to supervise onsite unless an exception applies.
- Delegates should never be left to run a clinic or a patient population on their own.
- The medical record has to show who made each entry, who performed the act and who the authorizing physician is.
What "med spa" means under Ontario law
"Med spa" is a business label, not a legal category. A clinic offering facials, laser hair removal or skin-care devices may sit outside the restricted list, while the same clinic offering injectables almost certainly does not. The RHPA's controlled-acts section, as shown on e-Laws with a currency date of 4 November 2026, includes performing a procedure on tissue below the dermis and administering a substance by injection. Anyone performing those acts has to be authorized under the Act, either as a regulated professional whose scope includes the act or through delegation.
That is why a med spa that wants to offer injectables is built around a physician. The question for an owner is rarely "which licence do I apply for?" and almost always "who is authorized to perform each treatment, and under whose order?"
Who can inject in an Ontario med spa
The CPSO's delegation obligations explain the mechanics. Delegation only applies to controlled acts, so assigning tasks such as a physical examination or obtaining consent to treatment is not delegation. It also does not cover controlled acts that other regulated professionals are already authorized to perform. When a physician does delegate a controlled act, these points apply:
- The physician stays responsible for the care provided through delegation.
- Delegation is not appropriate when the main reasons are monetary gain or physician convenience.
- A physician must not delegate to a professional whose certificate of registration is revoked or suspended, or to someone who has posed as a physician.
- Delegates must identify themselves accurately and explain their role to the patient.
In short, a nurse or other delegate injecting in a clinic needs an authorizing physician behind the treatment. A med spa cannot hand the decision to a technician simply because the owner wants more appointments.
Supervision, assessment and medical directives
The CPSO states that a physician only needs to assess a patient before delegating, or within two business days of delegating, when the delegate performs a controlled act. The exceptions to the onsite supervision obligation are not intended to let a physician stay offsite permanently.
When a physician delegates through a medical directive, the CPSO expects the directive to set out the procedure ordered, the clinical conditions the patient has to meet, any contraindications, the people authorized to carry it out, the responsible physicians, the effective date and any administrative approvals. A copy-pasted template that names no physician and no conditions does not meet that description.
The CPSO's June 2026 article on cosmetic clinics adds that a medical director is responsible for oversight of clinical practice and patient safety, including delegated acts by clinic staff, and that a contract should set out the director's role. It also reminds medical directors to verify staff training and credentials and to make sure staff use appropriate titles with patients.
Records a clinic should keep
The CPSO says the medical record must clearly identify who made the entry, who performed the act and who the authorizing physician is. For an injectables practice that translates into a handful of concrete records:
- The treatment given, with date, area, product and who performed it.
- The authorizing physician and the medical directive used.
- The assessment of a new patient and when it took place.
- Patient identity, contact details and the practitioner's role as explained to the patient.
Paper charts make these links hard to prove months later. Clinic software that ties each visit to a patient, a practitioner and a treatment record makes the paper trail easier to produce, which is the kind of structure CareTrack clinic management software is built around. Software does not decide who may inject and cannot make a clinic meet any rule, but it helps the record say what the CPSO expects it to say.
How to open a med spa in Ontario: a practical start-up checklist
- List every treatment and mark which ones involve a controlled act.
- Appoint a physician medical director with a written contract that sets out the role.
- Draft medical directives with the specific conditions, contraindications and named physicians.
- Verify each practitioner's registration and training before they treat anyone.
- Set up records that show the performer and the authorizing physician on every entry.
- Get legal advice on ownership, advertising and anything the sources above do not settle.
Other jurisdictions treat the same questions differently. Readers comparing markets can see how another Canadian province approaches clinic records in this guide for Alberta physiotherapy clinics under the Health Information Act.
Where the rules are still moving
Anyone who wants to open a med spa in Ontario should treat the sources above as a starting point rather than a finished plan.
The CPSO revised its Delegation of Controlled Acts policy in 2026, clarifying the two-business-day assessment requirement and widening an emergency department exception. It has also moved from "policies" to "professional obligations" wording, and older web addresses no longer load. Anyone relying on a blog post or a clinic's old documents should check the current CPSO pages directly. Details such as who may own a clinic, how medical directors are paid and what advertising is allowed are not settled by the sources read for this guide and need professional advice.
Frequently asked questions
Does Ontario have a med spa licence?
None was found in the sources read. The controlling rules are the RHPA's controlled acts and the CPSO's expectations for delegation and medical directors.
Can a nurse inject Botox in Ontario?
Injecting is a controlled act. The CPSO describes how a physician may delegate controlled acts and stays responsible for the care, so the nurse works under the physician's authorization and the rules above.
Does the physician have to be in the clinic?
The CPSO expects onsite supervision unless an exception applies, such as low risk, and says the exceptions do not allow a physician to stay offsite permanently.
Is laser hair removal a controlled act?
That depends on the device and the treatment, and the sources read for this guide do not settle it. Clinics should confirm it with a regulator or lawyer before offering a service.
Last reviewed: 9 November 2026, against the Regulated Health Professions Act, 1991 on e-Laws, the CPSO's Obligations in Practice: Delegation of Controlled Acts and its June 2026 article on medical directors in cosmetic clinics. This article is general information and not legal advice. Clinic owners who want records that show who performed each treatment can talk to CreativeIn Tek about CareTrack.
