A regulatory shift now under consideration in Ontario could reshape how the province’s medical aesthetic clinics operate. The proposal, which would change how nurses are authorized to administer medical aesthetic services, invites a broader look at how Ontario currently regulates cosmetic injections and how the proposed changes would align the province more closely with the regulatory frameworks already in place elsewhere in Canada. While these procedures are often marketed as routine “spa” services, they remain medical acts that involve prescription products and carry clinical risks.
Ontario’s Proposed Regulatory Change
In July 2026, the College of Nurses of Ontario (CNO) published Aesthetic Services, its first dedicated practice guideline for nurses providing medical aesthetics.[1] The guideline clarifies, among other things, that a registered nurse may administer cosmetic injectable treatments only when authorized to do so by a physician or nurse practitioner. A nurse may obtain this authority in Ontario through one of two mechanisms.
The first is a medical directive, which a physician or nurse practitioner may prepare in advance and apply to a broad range of clients who meet defined conditions. A directive allows a nurse to determine when to implement treatment without the prescriber assessing each patient individually beforehand. The second mechanism is a patient-specific direct order, which requires a physician or nurse practitioner to assess each client individually and provide instructions for that particular person’s treatment.[2]
Medical directives have become popular in cosmetic practices because they are particularly well suited to high-volume, nurse-led clinics. Under this mechanism, nurses can administer treatments on a day-to-day basis without requiring a fresh, patient-specific assessment for each client, making the process highly efficient for both clinics and the patients they serve.
Despite publishing these practice guidelines in July 2026, the CNO is now considering eliminating medical directives and making patient-specific direct orders the sole authorizing mechanism for nurses administering medical aesthetics.[3] Such a change would require a physician or nurse practitioner to be consulted for every patient at every visit, including routine follow-ups and check-ins. As a result, many clinics could be forced to substantially restructure their operations to remain compliant with regulations.
Comparison to Other Provinces
Although the proposed changes would be new to Ontario, other provinces have already adopted requirements imposing similar oversight. In Quebec, British Columbia and Alberta, nurses may administer an aesthetic treatment only where it has been authorized through an individual or client-specific order.[4] Each of these provinces also requires that, during an aesthetic injection, the prescribing physician or nurse practitioner remain in close proximity to assist with any health complications that may arise during treatment.
It is also worth noting that these provinces are not standing still but they continue to tighten their frameworks. Effective February 1, 2025, the Alberta College of Pharmacy prohibited pharmacists and pharmacy technicians from administering aesthetic injections in their capacity as regulated members, narrowing the range of professionals permitted to offer these services.[5] In Quebec, four professional orders announced a joint initiative in November 2025 to develop common regulatory guardrails for medico-aesthetic care, a process that is expected to conclude in 2026.[6] Likewise, in British Columbia, the standards governing nurses acting under client-specific orders became part of the College of Nurses and Midwives bylaws effective April 2026. Taken together, these developments show that the direction of regulation across the country is moving toward closer prescriber involvement and more oversight.[7]
Key Takeaways for Clinics and Manufacturers/Suppliers
For now, the Ontario proposal remains just that. Public consultation on the issue has closed, and the CNO is expected to decide whether to adopt the change in September 2026. Until then, medical directives remain a valid authorizing mechanism in Ontario, and clinics may continue to operate as they do today.
That said, while the outcome of the CNO’s deliberations remains uncertain, clinics that currently rely heavily on the medical directive model can take proactive steps now to prepare for a possible shift to patient-specific orders. Requiring a physician or nurse practitioner to assess and order for each client at every visit would change the economics of a high-volume, nurse-led practice. Clinics should consider the operational and financial impact of requiring a physician or nurse practitioner to assess and order for each client at every visit and develop a transition plan addressing staffing, scheduling and prescriber involvement should medical directives be eliminated. Clinics that plan ahead now, rather than waiting for a decision, will be better positioned to adapt quickly if the change is adopted.
The proposed changes also carry implications for the manufacturers and suppliers of these products. As neuromodulators and dermal fillers are prescription drugs that reach patients through nurse-led clinics, manufacturers have an interest in confirming that the clinics they supply are compliant with the applicable regulations. This is due to manufacturers and suppliers potentially being liable in a lawsuit if they sell prescription products to a clinic that is not compliant with local requirements. Should the CNO implement the proposed changes, manufacturers and suppliers would be well advised to increase their due diligence when entering into arrangements with clinics. In practice, this might include requiring a clinic to disclose the name and licence number of the authorized medical director or other prescriber responsible for the directive or order, and incorporating a general compliance representation into the account-opening documentation.
Regardless of whether the CNO proceeds, there is a broader trend emerging as regulators across the country view cosmetic injectables as prescription-based medical acts and move toward closer physician and nurse practitioner involvement. Ontario would not be breaking new ground by requiring direct orders but it would be catching up to where other provinces already stand. Fasken’s Life Sciences and Health Law groups are closely monitoring these developments and regularly advise medical aesthetic clinics, prescribers and investors on regulatory compliance, corporate structuring and risk management. If you have questions about how the proposed changes may affect your practice, please contact any member of our team.
