Who can perform Botox and filler injections in Ontario?

Ontario regulates injections by the activity, not the setting. It makes no difference that a treatment is cosmetic or that it happens in a spa rather than a clinic: the same controlled acts rules apply.

Why are Botox and filler injections controlled acts?

Section 27 of the Regulated Health Professions Act, 1991 lists controlled acts that may only be performed in the course of providing health care by an authorized member of a regulated profession, or by someone the act has been delegated to by that member. The list includes administering a substance by injection and performing a procedure on tissue below the dermis. CNO’s Aesthetic Services guideline says injecting neuromodulators and dermal fillers involves both.

Botulinum toxin is also a prescription drug on Health Canada’s Prescription Drug List, so someone with prescribing authority has to be involved.

Who can inject, and what do they need?

Who	Authority	What they need
Physician	Medicine Act, s. 4: procedures below the dermis, injection, and prescribing drugs	Their own competence and CPSO’s standards
Nurse practitioner	Nursing Act, s. 5.1, for nurses in the extended class	Their own competence and CNO’s standards
Registered nurse or registered practical nurse	Nursing Act, ss. 4 and 4.1	An order (direct order or directive) from an authorized provider, such as a physician or nurse practitioner, under s. 5
Esthetician, laser technician or other unregulated staff	None of their own	Only a valid delegation from an authorized professional, which carries strict college requirements

Other regulated professions have their own Acts and college rules, so a dentist, naturopath or other professional should check what their profession allows before offering aesthetic injections.

Can a nurse do Botox in Ontario without a doctor?

A registered nurse or registered practical nurse needs an order. Section 5 of the Nursing Act, 1991 says a nurse shall not perform a procedure under those authorized acts unless the regulations permit it or it’s ordered by an authorized person, which includes a physician or a nurse practitioner. A nurse practitioner doesn’t need a physician’s order for acts within their own authority. CNO’s guideline says the order must be clear, complete and appropriate, and that a nurse who thinks it isn’t must follow up with the authorized provider.

Can an esthetician do Botox or fillers in Ontario?

Not on their own authority. An esthetician who injects without authority breaches section 27, and section 40 sets fines of up to $25,000, or up to a year in jail, for a first offence. Their employer can also be charged under section 42.

Delegation to unregulated staff is possible in some settings, but CPSO’s delegation policy requires the physician to assess each new patient before delegating or within two business days, to be onsite or available depending on the risk, and to stay responsible for the care. CNO says a nurse who delegates keeps full responsibility for the client’s care, and that it is actively reviewing how directives and delegation are used in aesthetics.

What about lasers, microneedling and other treatments?

Each treatment needs its own check:

• Lasers. Applying a form of energy is a controlled act only for the forms of energy listed in O. Reg. 107/96, such as electricity for certain procedures, MRI and diagnostic ultrasound. Lasers aren’t on that list. Health Canada’s laser hair removal guidelines still expect a laser safety program, and insurers may set their own conditions.
• Electrolysis, piercing and cosmetic tattooing. Section 13 of O. Reg. 107/96 exempts ear or body piercing for jewellery, electrolysis, and tattooing for cosmetic purposes from the controlled acts rule.
• Microneedling, thread lifts and PRP. CNO lists these as aesthetic services nurses provide that may involve controlled acts. Whether a particular treatment does depends on what it involves.

What else must an injector get right?

• Products. CNO says drugs, products and equipment must be Health Canada-approved; approval elsewhere, such as by the US FDA, doesn’t count in Ontario.
• Consent. The client must understand the procedure, cost, risks, expected results, the product used and how any photos will be used.
• Records. Health history, the treatment, product name, lot number, dose and site, and the signed consent.
• Titles. Nurses must identify themselves by their name and designation (NP, RN or RPN), whatever the clinic calls the role.

What to do next

If you’re opening or restructuring a med spa, start with who can own a med spa and what a medical director agreement should cover. We review medical director and practitioner agreements as a contract review, starting at $400, and prepare clinic privacy and consent documents starting at $1,480.

This guide is general information about Ontario law, not legal advice for your situation. Each professional should confirm their own college’s current standards. To talk through your clinic, book a free 15-minute consult.