Published 12 September 2026 · By Jatin Dua, Broker of Record, RE/MAX Quantum Realty
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Get My Free Estimate →You do not have to be a veterinarian to own an Ontario veterinary business or the building it sits in. The Veterinarians Act and Regulation 1093 do not restrict ownership of the business or the premises, and the regulation expressly contemplates a facility director who “is not an owner of the veterinary facility or a partner in the practice.” What the statute does restrict is the certificate of accreditation: s. 17(1) has the Registrar issue it “upon the application of a member of the College.” So the accreditation is a licensee’s document attached to a location, while the equity is not restricted at all. Working out which of those two things you are actually buying is the whole job.
Nobody has to be a veterinarian to own it
This surprises almost every buyer I speak to, and it is the opposite of what people assume after reading about dentistry or pharmacy.
Search the Veterinarians Act and Regulation 1093 for a restriction on who may own a veterinary business or its premises and you will not find one. What you find is a regulation drafted on the assumption that owners and practitioners can be different people. Section 10(1) of Reg. 1093 refers to “the owners of the veterinary facility or the partners in the practice conducted in or from the facility.” Section 11(2) paragraph 7 goes further and deals directly with the case where the facility director “is not an owner of the veterinary facility or a partner in the practice,” requiring in that situation “a written attestation from the owners or partners… that the facility director is authorized to be the facility director.”
You cannot draft that paragraph without contemplating non-licensee ownership. The College’s guidance for facility directors says the same from the other direction: the facility director may be an owner or a partner, “or a licensed veterinarian designated by the owner(s) or partner(s).”
So on the face of the primary sources, an investor or a holding company without a licence is not shut out of veterinary ownership the way a non-physiotherapist is shut out of a physiotherapy professional corporation. That is a real structural difference, and it is not widely understood.
But the certificate is applied for by a College member
Here is the counterweight, and it is where the analysis gets harder. Section 15 of the Act is absolute: “No person shall establish or operate a veterinary facility except under and in accordance with a certificate of accreditation.” And s. 17(1) provides that the Registrar issues a certificate of accreditation “upon the application of a member of the College.” Regulation 1093, s. 11(2) paragraph 3 requires the applicant to hold a general or restricted licence and to be engaged in practice in or from the facility.
Read those together. Ownership of the business is unrestricted. The application for the accreditation is not — it comes from a licensee who practises there. So every deal structure has to answer one question: who is the licensee standing behind this facility’s accreditation, and what happens to them on closing?
That is a different question from the one a pharmacy buyer faces, where the College requires a new certificate on every purchase. In veterinary medicine the statute says no such thing, and the silence is the problem.
Five years, and four ways the certificate dies early
A certificate expires five years after issue or renewal under s. 12(1) of Reg. 1093. But s. 12(2) lists four events that expire it sooner.
| Early expiry trigger (Reg. 1093, s. 12(2)) | What it means for a buyer |
|---|---|
| The facility, or a stationary element of a facility with a mobile element, is relocated | The certificate is location-specific. Moving the practice expires it — including a move you plan after closing |
| The facility no longer has a facility director | If the vendor is the facility director and leaves, the certificate is exposed until a successor is in place |
| The facility no longer has any members who would meet the requirements in Reg. 1093 s. 11(2) para. 3 | There must be a licensee engaged in practice in or from the facility who could have applied for the accreditation |
| The facility no longer has any members who have made an undertaking | The undertakings given by members at the facility are part of what holds the certificate up |
Now notice what is not on that list. A change of business ownership is not an early expiry trigger. Nothing in s. 12(2) expires the certificate because shares changed hands or assets were sold.
Two of the four, though, are exactly what a purchase tends to disturb. If the vendor veterinarian is the facility director and retires on closing, trigger two is live. If the vendor is the only licensee practising in or from the facility, trigger three is live. The certificate does not fail because you bought the practice. It fails because the person holding it up walked out on the closing date and nobody replaced them.
Section 13 of Reg. 1093 adds a notification duty: the holder must “immediately notify the College, in writing” of any change to the facility name, species treated, scope of services, relocation, or the identity of the facility director. “Immediately” is the regulation’s word. It does not give you a number of days.
A purchase is not an expiry trigger, but it is an inspection event
The part that resolves how this works in practice comes from the College rather than the regulation. Its published accreditation process treats a purchase as requiring an inspection. There is a specific form for it — a “Change of Information for Accreditation Facility – Purchase form” — and an inspection is required on the purchase of an existing facility. By contrast, an inspection is not required for a change of facility directorship alone.
Two things follow. First, the College will look at the premises when you buy, whatever the regulation says about expiry triggers — budget for an inspection and for remediation, and read the accreditation standards before you write the offer. Second, the College distinguishes a purchase from a directorship change, so changing only who directs the facility is treated differently from changing who owns it.
The professional corporation is a different, tighter rule
None of this changes the rule for a veterinary professional corporation. Under s. 3.2 of the Business Corporations Act, all issued and outstanding shares of a professional corporation must be legally and beneficially owned, directly or indirectly, by one or more members of the same profession — for veterinary professional corporations, 100% licensee ownership. No minority outside shareholder, unlike the majority test that governs pharmacy corporations under the Drug and Pharmacies Regulation Act.
Two different vehicles, constantly conflated. A professional corporation through which veterinarians practise is wholly licensee-owned. A corporation that simply owns the business or the real estate is not subject to that restriction under the Act or Reg. 1093. Which vehicle you are buying, and which one holds the accreditation, decides what your cap table can look like. That is for a lawyer with the minute book open.
The new Act is law and it is not in force
The Veterinary Professionals Act, 2024 has been passed. It is not in force.
The e-Laws headnote on the current Veterinarians Act reads: “Note: This Act is repealed on a day to be named by proclamation of the Lieutenant Governor.” In the Table of Proclamations, the rows for the operative sections of the 2024 Act carry a blank date in force. The College states that while the new Act is now law, it is not yet in full effect. No regulations have been made under it.
There is no proclamation date. Distrust anyone who gives you one. The Veterinarians Act is the operative statute for your transaction today.
What changes on proclamation, on the face of the 2024 Act: the College is renamed — s. 2(1) continues the College of Veterinarians of Ontario “under the name College of Veterinary Professionals of Ontario” — and existing accreditations carry over, because s. 103(1) deems a certificate of accreditation in force under the Veterinarians Act immediately before the transition date to be a certificate issued under the new Act. That matters for a buyer: the transition, when it comes, is not drafted to wipe out existing certificates.
What the regulations under the new Act will require, I cannot tell you, because they do not exist yet. On a long earn-out or a staged share transfer, that unknown belongs in the agreement as a risk to be allocated, not as an assumption.
The short version
Ownership of an Ontario veterinary business and its premises is not restricted by the Veterinarians Act or Reg. 1093, and the regulation expressly contemplates a facility director who is not an owner or partner. The accreditation, though, is applied for by a College member, runs five years, and expires early on relocation, loss of the facility director, loss of a qualifying member, or loss of the members’ undertakings. A change of ownership is not on that list — but the College still treats a purchase as an inspection event with its own purchase form. A veterinary professional corporation must be 100% licensee-owned. The 2024 Act is law, is not in force, and has no proclamation date.
Asset or shares: what actually moves
The general Ontario mechanics apply as to any business purchase, and they interact with the accreditation question above.
| Item | Asset purchase | Share purchase |
|---|---|---|
| The corporation’s liabilities | Only what you assume in the agreement | They stay with the corporation, which you now own |
| Ontario Land Transfer Tax on the real estate | Payable on registration of the conveyance | “The transfer of shares of a corporation which holds land in its own right does not ordinarily attract tax under the Act” |
| Employees’ service | Deemed continuous with you under ESA s. 9 | Employer never changed; service continues |
| The lease | Assignment, with landlord consent where the lease requires it | Tenant entity unchanged, but read the change-of-control clause |
| Tax cost of the assets | Set at your allocated purchase price | You inherit the corporation’s existing cost base |
| The accreditation | A new licensee applicant and an inspection | Unresolved on the primary sources — get advice |
If you are buying the building too, price the land transfer tax. Ontario LTT tops out at 2.0% above $400,000 for non-residential property, and Toronto’s Municipal Land Transfer Tax has applied to all properties in the City since 1 February 2008, with the same 2.0% top tier for “all other” property — 4.0% combined, plus the $102.56 MLTT administration fee and HST. The April 2026 MLTT revision raised high-value residential brackets only.
HST, the election, and the trap in a buy-the-clinic-and-the-building deal
Ontario HST is 13%. Vendor and purchaser can jointly elect under s. 167 of the Excise Tax Act so that tax does not apply to the supply, where the recipient is acquiring “all or substantially all of the property that can reasonably be regarded as being necessary” to carry on the business — generally 90% or more of the fair market value of that property. The election is made on Form GST44. Separately, s. 167.1 keeps goodwill outside the tax calculation where the conditions are met, whether or not the election is filed.
The trap is the carve-outs that survive the election. Tax still applies to a taxable sale of real property where the recipient is not a GST/HST registrant. Buy the clinic and the building through an unregistered holding entity and you can face HST on the real estate notwithstanding a properly filed election. I have set out the drafting side in my note on HST clauses. Your accountant confirms the registration status of the actual buying entity, not the one you meant to use.
The staff come with the practice
On an asset sale, s. 9(1) of the Employment Standards Act, 2000 deems the employment of an employee you hire from the vendor not to have been terminated, and deems their service with the vendor to be service with you for any later calculation of length of employment. “Sells” is defined broadly to include leases, transfers or disposal “in any other manner.” The only escape is the narrow s. 9(2) exception, which applies where you hire more than 13 weeks after the earlier of the employee’s last day with the vendor and the day of the sale.
In practice a long-service registered veterinary technician lands on your payroll with a decade or more of deemed service. ESA notice runs to at least eight weeks at eight years; severance is engaged at five years or more where payroll is $2.5 million or more, capped at 26 weeks’ regular wages. Quantify it before closing.
Zoning, the permit, and the licence Toronto does not have
Toronto’s Zoning By-law 569-2013 defines “veterinary hospital” as premises used by a licensed veterinarian for the medical treatment of animals, and expressly excludes it from the “pet services” definition. A use permission for pet services does not carry a veterinary hospital.
In the Commercial Local (CL) zone, a veterinary hospital appears among the uses permitted without conditions. But never conclude a use is permitted from the map alone — some Toronto properties remain subject to former municipal by-laws, and some provisions of 569-2013 are under appeal to the Ontario Land Tribunal and are not in full force and effect. Buy the City’s Zoning Use Review at $214.79 per registered lot. My note on zoning conditions covers making that a condition of the offer.
A useful absence: I found no City of Toronto business licence class for veterinary practices in Municipal Code Chapter 545. Accreditation and zoning are the gates, not a City licence.
If you are converting a retail unit, s. 10(1) of the Building Code Act, 1992 requires a permit for a change of use even with no construction where hazard increases as determined under the building code, and Toronto states the change-of-use permit requirement without that qualifier. A permit cannot issue where the use would contravene “any other applicable law” — the hook that makes zoning a permit condition. And read the lease before the offer goes out, which is why I build in a lease review condition.
What a veterinary practice is worth
The College does not publish sale values, and I have not found an Ontario or federal government source that does. Any multiple you are quoted comes from somebody’s own transaction book. That can be real information, but it is not a benchmark you can check and it should not stand in for an earnings review, a look at case mix, and a lender’s underwriting. Ask where the number came from.
FAQ
Do I have to be a veterinarian to buy a veterinary practice in Ontario?
Not to own the business or the premises. The Veterinarians Act and Regulation 1093 do not restrict who may own a veterinary facility, and s. 11(2) paragraph 7 of the regulation expressly deals with a facility director who is not an owner or a partner, requiring a written attestation from the owners or partners that the director is authorized. The certificate of accreditation is a different matter: s. 17(1) of the Act has the Registrar issue it on the application of a College member.
How long does a certificate of accreditation last?
Five years from issue or renewal under s. 12(1) of Reg. 1093. It expires earlier on four events set out in s. 12(2): relocation of the facility or a stationary element of a facility with a mobile element; the facility no longer having a facility director; no longer having any member who would meet the s. 11(2) paragraph 3 requirements; and no longer having any member who has made an undertaking. A change of business ownership is not one of them.
If ownership is not an expiry trigger, does the accreditation just carry on after I buy?
That is not answered on the face of the primary sources, and I will not pretend otherwise. The statute is silent, the s. 12(2) list does not mention ownership, and the College nevertheless treats a purchase as requiring an inspection, using its own Change of Information for Accreditation Facility – Purchase form. Put your specific structure to the College in writing and take legal advice before your conditions come off.
What happens if the selling veterinarian is the facility director?
Then two of the four early expiry triggers are live on your closing date. The certificate expires early if the facility no longer has a facility director, and again if it no longer has any member who would meet the requirements in s. 11(2) paragraph 3 — a licensee engaged in practice in or from the facility. Line up the successor facility director before closing, and remember s. 13 requires the holder to notify the College in writing immediately of a change in the facility director’s identity.
When does the Veterinary Professionals Act, 2024 come into force?
No date has been named. The e-Laws Table of Proclamations shows a blank date in force for the operative sections, the Veterinarians Act carries a headnote saying it is repealed on a day to be named by proclamation, and the College states that while the new Act is law it is not yet in full effect. No regulations have been made under it. Anyone quoting you a proclamation date is guessing.
What will change when it is proclaimed?
On the face of the 2024 Act, the College of Veterinarians of Ontario is continued under the name College of Veterinary Professionals of Ontario under s. 2(1), and existing accreditations carry over: s. 103(1) deems a certificate of accreditation in force under the Veterinarians Act immediately before the transition date to be a certificate issued under the new Act. Beyond that, the regulations that will do most of the practical work do not exist yet, so the detail is genuinely unknown.
Can I bring in a non-veterinarian investor?
Into a corporation that owns the business or the real estate, the Act and Reg. 1093 do not stand in the way. Into a veterinary professional corporation, no — s. 3.2 of the Business Corporations Act requires all issued and outstanding shares to be owned by members of the same profession. That is stricter than pharmacy, where the Drug and Pharmacies Regulation Act applies a majority test. Which vehicle holds the accreditation is the question to settle with counsel first.
Do I need a City of Toronto licence to operate a veterinary clinic?
I found no business licence class for veterinary practices in City of Toronto Municipal Code Chapter 545. The gates are the College’s accreditation and the zoning. Toronto’s Zoning By-law 569-2013 defines “veterinary hospital” separately from “pet services,” and a pet services permission does not carry a veterinary hospital. Get a Zoning Use Review in writing rather than relying on the interactive map, because some provisions of the by-law are under appeal and not in force.
Sources
- Ontario e-Laws — Veterinarians Act, R.S.O. 1990, c. V.3
- Ontario e-Laws — R.R.O. 1990, Reg. 1093 (General) under the Veterinarians Act
- Ontario e-Laws — Veterinary Professionals Act, 2024
- Ontario e-Laws — Table of Proclamations
- College of Veterinarians of Ontario — Legislation
- College of Veterinarians of Ontario — Accreditation Process and Renewal
- Ontario e-Laws — Business Corporations Act
- Ontario e-Laws — Employment Standards Act, 2000
BUYING A VETERINARY PRACTICE IN THE GTA?
I work the premises and deal-sequence side of veterinary purchases in Toronto and across the GTA: the zoning use confirmation, the lease and its assignment and change-of-control clauses, whether the space can carry the accreditation standards, and how to time an inspection against your closing. The accreditation and corporate questions go to your lawyer and the College — I will tell you which ones to ask, and when.
Book a 15-minute call or call or text 833-330-1925.
If someone has told you the accreditation “just transfers” on a share deal, I would want to see that in writing from the College before relying on it. So would your lender.
More in this series
Jatin Dua is Broker of Record and co-founder of RE/MAX Quantum Realty, Brokerage, Unit 101, 799 The Queensway, Etobicoke. Four-plus years in the GTA and more than $100M in sales volume. He works on commercial and business purchases across Toronto and the west GTA.
This is general professional commentary from a Broker of Record on commercial and business acquisitions in Ontario. It is not legal, tax or accounting advice, and it does not create any professional relationship. Whether a licence transfers, how a purchase should be structured, what tax applies and what a regulator will require on your particular file are questions for your lawyer, your accountant and the regulator itself. Rules, fees and published requirements change — verify anything you intend to rely on against the primary source on the day you rely on it.