Published 12 September 2026 · By Jatin Dua, Broker of Record, RE/MAX Quantum Realty
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Get My Free Estimate →The College of Veterinarians of Ontario’s Accreditation Standards for Veterinary Facilities are made by Council under s. 8(1) of the Veterinarians Act, and the standards document itself states that they have the same force as the regulations. They prescribe no square footage. Instead they prescribe outcomes: a self-contained reception area entered directly from outside and not within an examination room; a client washroom whose sink is used only for hand washing; fluid-impervious examination room floors, with unsealed concrete not acceptable; a drained sink with hot and cold running water in each treatment area; and a surgical suite that is dedicated, single-purpose, closed, walled floor to ceiling and has no sinks at all. Qualitative standards shift the risk onto the inspection.
These are standards with the force of regulations
Buyers tend to treat a College’s “standards” as guidance and a regulation as law. In veterinary medicine that distinction does not help you.
The Accreditation Standards for Veterinary Facilities in Ontario are made by Council under the authority of s. 8(1) of the Veterinarians Act, and the standards document states that they have the same force as the regulations. The version in circulation was approved by Council on 6 December 2023. Meanwhile s. 15 of the Act is unqualified: “No person shall establish or operate a veterinary facility except under and in accordance with a certificate of accreditation.”
So the premises requirements in that document are not aspirational. They are the test an inspector applies, and the College’s published accreditation process treats the purchase of an existing facility as requiring an inspection, using its own Change of Information for Accreditation Facility – Purchase form. You buy, an inspector comes.
No square footage is prescribed, and that is the risk
Here is the part that makes veterinary premises harder to diligence than a pharmacy.
A pharmacy buyer can take a tape measure to a unit and compare it to a published number — 18.6 m² total accredited area, 9.3 m² dispensary. Nothing equivalent exists for a veterinary facility. The standards speak of a reception area “of adequate size” and “adequate space for storage of drugs, equipment, cleaning materials, food supplies, medical records.” Adequate is not a number.
People read that as good news. It is not. When a standard is quantified, you can price compliance before you sign. When it is qualitative, compliance is assessed by a person on a date after you have already closed. The risk moves from the measuring tape to the inspection, and that is a worse place for a buyer to carry it.
What you can do is read the standards and walk the building against them, line by line, during your conditional period — and treat every item where you are not clearly inside the standard as a cost to be priced or a condition to be negotiated. The items below are the ones that actually catch people.
The reception area has to be entered directly from outside
The standards require a self-contained reception area of adequate size, entered directly from outside, and not within an examination room.
Read those three requirements as a floor plan test. “Entered directly from outside” rules out a clinic whose front door opens into a shared corridor and then into a room that doubles as reception — a common arrangement in converted houses and in second-storey units in small plazas. “Not within an examination room” rules out the small-practice habit of using the front room as both greeting area and exam space.
If you are buying a practice in a converted dwelling in Etobicoke or a unit inside a multi-tenant building, this is the first thing I would look at, because fixing it is a demolition-and-partition job and sometimes it cannot be fixed at all within the demised premises. That is a question about the space, and it belongs in the offer as a condition rather than in the renovation budget as an unknown.
The client washroom sink is for hand washing only
The standards require a client washroom whose “sink is only used for the purpose of hand washing.”
Small rule, real consequence. A clinic that has been rinsing equipment, filling buckets or emptying mop water in the client washroom sink is not compliant, and the inspector is entitled to ask. The fix is usually not the sink — it is having somewhere else for that work to happen, which means another plumbing fixture in another room, which means drains, which means slab or ceiling work and a landlord consent under the alterations clause.
Fluid-impervious floors, and unsealed concrete is not acceptable
Examination room floors must be fluid-impervious, and the standards say plainly that “Unsealed concrete is not acceptable.”
That second sentence exists because bare or partly sealed concrete is exactly what you find in converted industrial and light-industrial space, which is where a lot of GTA veterinary and animal-care uses end up. If you are looking at a unit in an employment zone with a polished or dusty slab, budget for a proper sealed or sheet-goods floor system with coved edges, and do not assume a topical coating that has already worn through counts as sealed.
This also interacts with the lease. Flooring is a leasehold improvement, and under the Canada Small Business Financing Program guidelines, where the borrower rents the property the improvements are leasehold improvements rather than improvements to real property — which puts them inside a $500,000 sub-limit within the program’s $1,000,000 term-loan maximum, with a further $150,000 cap on intangible assets and working capital. Getting that classification wrong can affect a later claim. Your lender should be settling it before the fit-out is tendered.
A drained sink with hot and cold running water in each treatment area
Each treatment area must have “a drained sink with hot and cold running water.” Each treatment area. Not one sink for the floor.
In a fit-out this is the requirement that drives the mechanical layout, because sinks need drains and drains need falls and stacks. In an existing practice you are buying, the sinks are usually there — which is a strong argument for buying an operating facility rather than converting a shell, and a reason to photograph and locate every fixture during your visits rather than relying on the vendor’s floor plan.
The surgical suite: dedicated, closed, solid, and sink-free
The surgical suite is the most prescriptive part of the standards and the part most likely to be out of compliance in an older practice.
| What the standards require | What it means in a real building |
|---|---|
| Major surgery performed in a “dedicated, single purpose surgical suite” | The room cannot double as treatment, dental or storage space |
| “separate, closed, single purpose rooms for aseptic surgery only” | An alcove or a curtained bay does not qualify |
| “a closed room with no through traffic” | The suite cannot be a passage to anywhere else — a second door to a back area can be the problem |
| “completely enclosed with solid walls floor to ceiling and a covered ceiling” | Partitions to the ceiling grid are not enough; open-web joists or an exposed deck above need a covered ceiling |
| No sinks in the surgical suite | Existing sinks must be removed before the inspection; the legacy provision is no longer permitted |
Take “no through traffic” seriously. In narrow units, the surgical suite is often the only route to a back door, a mechanical room or an exterior yard, and correcting that can mean re-planning the whole rear of the premises. Take “solid walls floor to ceiling and a covered ceiling” seriously too: in industrial-conversion space with an exposed deck, that is a real construction scope, and it may engage sprinkler relocation and therefore a permit.
X-ray registration belongs to the employer, not to the building
This is the one that trips up asset purchases.
The standards require x-ray equipment to be maintained, registered and operated as required under Ontario’s Radiation Protection Services, and a copy of the x-ray registration number is required at the inspection. The standards also say Radiation Protection Services must be contacted on a change in ownership.
Now go to the underlying law. Under R.R.O. 1990, Reg. 861 (X-Ray Safety) made under the Occupational Health and Safety Act, s. 5(1) provides that “An X-ray source shall not be used at a workplace unless the employer who has possession of the X-ray source is registered with a Director.” And s. 5(5) provides that registration “terminates when the employer notifies a Director that the employer no longer has possession of any X-ray sources.”
Registration attaches to the employer in possession. It is not a property of the machine or of the room. So on an asset purchase, where a new corporation takes possession of the equipment, the buyer registers in its own name — and the vendor’s registration terminates when the vendor tells a Director it no longer has possession. Do not put the vendor’s registration number on your inspection paperwork and hope.
Controlled substances and the locked storage area
The standards require that controlled substances be stored “in a separate lockable area with limited authorized access.” The regulation is more specific: Reg. 1093 s. 28(4) requires a member to ensure controlled substances in their possession “are kept in a locked storage area designed and constructed to ensure the reasonable security of the controlled substances,” and s. 28(5) requires it kept locked except when in use.
“Designed and constructed” is the phrase to notice. Like the pharmacy time-delay safe requirement, this is a construction item, and anchoring or building a secure cabinet engages the lease’s alterations clause and any end-of-term restoration obligation. Sort out consent before you order anything that gets bolted to a wall.
The short version
The accreditation standards have the same force as the regulations, and they prescribe no square footage — so compliance is judged qualitatively, by an inspector, after you own the place. Walk the building against the standards while you are still conditional: reception entered directly from outside and not inside an exam room; a client washroom sink used only for hand washing; fluid-impervious exam room floors with unsealed concrete ruled out; a drained sink with hot and cold water in each treatment area; and a dedicated, closed, solid-walled, sink-free surgical suite with no through traffic. Register the x-ray equipment in your own name. And remember the certificate names the location, so relocating expires it.
The certificate names the location, so moving expires it
Under Reg. 1093 s. 15(1), a certificate of accreditation must include the facility name, its location, any terms, conditions or limitations, and the date of expiry. And under s. 12(2) paragraph 1, the certificate expires early where “A veterinary facility, or a stationary element of a facility with a mobile element, is relocated.”
The consequence for a buyer is easy to state and easy to forget: the accreditation you are looking at belongs to that address. If part of your business plan is to move the practice to a better unit down the street in year two, that plan expires the certificate, and you should be planning the new accreditation and its inspection as part of the move rather than discovering it afterwards. Section 13 also requires the holder to notify the College in writing immediately of a relocation.
It also means a landlord relocation clause — the kind that lets a landlord move a tenant to comparable premises within a shopping centre — is not a neutral clause in a veterinary lease. It is a clause that can expire your certificate. That belongs on the list of lease clauses to fight about before you sign, and it is one of the reasons I want a lease review condition in the offer.
Accessibility, the building permit, and the things the College does not decide
Three layers sit outside the College and they all touch the same fit-out.
Accessibility. Under the Integrated Accessibility Standards Regulation, the Design of Public Spaces requirements apply to public spaces “newly constructed or redeveloped,” and “redeveloped” is defined as “planned significant alterations to public spaces, but does not include maintenance activities, environmental mitigation or environmental restoration.” So routine maintenance does not engage it; a planned significant alteration does. The requirements cover exterior paths of travel, accessible off-street parking and obtaining services — including service counters, where the trigger is “When constructing new service counters, which includes replacing existing service counters.” A veterinary reception desk is a service counter. If your renovation replaces it, that rule is live. Small organizations have been inside the Design of Public Spaces compliance schedule since 1 January 2018, and the accessibility compliance report for businesses with 20 or more employees is next due 31 December 2026.
The building permit. Section 10(1) of the Building Code Act, 1992 requires a permit for a change of use even where no construction is proposed, where the change would result in an increase in hazard as determined in accordance with the building code. The City of Toronto states the requirement without the hazard qualifier: if a change of use is proposed, a building permit is required. Inside Toronto, work to the City’s formulation and confirm with the chief building official. A permit cannot issue where the proposed use would contravene “any other applicable law,” which is what makes zoning a permit condition, and my note on the building permit condition sets out how to handle that in an offer.
Zoning. 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 “pet services” — a pet services permission does not carry a veterinary hospital. Confirm the use in writing through the City’s Zoning Use Review at $214.79 per registered lot, because some properties remain under former municipal by-laws and some provisions of 569-2013 are under appeal to the Ontario Land Tribunal and not in full force and effect.
None of these three is decided by the College, and the College’s inspection will not tell you that you got them wrong. That is the buyer’s problem to solve before closing.
FAQ
How big does a veterinary facility have to be in Ontario?
No square footage is prescribed. The College’s accreditation standards are qualitative — a reception area “of adequate size,” “adequate space for storage of drugs, equipment, cleaning materials, food supplies, medical records.” That sounds permissive and is actually riskier than a number, because adequacy is assessed by an inspector rather than measured by you before closing. Walk the standards through the building during your conditional period and price every item you are not clearly inside.
Are the accreditation standards actually binding, or just guidance?
Binding in effect. The standards are made by Council under s. 8(1) of the Veterinarians Act, and the standards document states that they have the same force as the regulations. Section 15 of the Act prohibits establishing or operating a veterinary facility except under and in accordance with a certificate of accreditation, and the College treats the purchase of an existing facility as requiring an inspection. Treat the standards as the test, not as advice.
Can the surgical suite have a scrub sink in it?
No. The standards require a dedicated, single-purpose surgical suite — a closed room with no through traffic, completely enclosed with solid walls floor to ceiling and a covered ceiling — with no sinks. And the College has closed off grandfathering: practices with sinks in the surgical suite are required to remove them prior to the inspection, and the legacy provision is no longer permitted. If the practice you are buying has one, that removal is a priced item in your offer.
Can reception double as an examination room in a small practice?
Not under the standards. The reception area must be self-contained, of adequate size, entered directly from outside, and not within an examination room. In converted houses and multi-tenant units this is frequently the hardest item to satisfy, because the fix is partitions and sometimes a new entrance — and occasionally it cannot be fixed inside the demised premises at all. Check it on your first walkthrough, not after closing.
Does the seller’s x-ray registration transfer to me?
No. Under R.R.O. 1990, Reg. 861, an x-ray source may not be used at a workplace unless the employer who has possession of it is registered with a Director, and a registration terminates when the employer notifies a Director that it no longer has possession. Registration attaches to the employer in possession, not to the machine or the room. On an asset purchase you register in your own name, and the standards also require Radiation Protection Services to be contacted on a change in ownership.
What happens to the accreditation if I move the practice?
It expires. Regulation 1093 s. 15(1) requires the certificate to include the facility’s location, and s. 12(2) paragraph 1 expires it early where the facility, or a stationary element of a facility with a mobile element, is relocated. Section 13 also requires the holder to notify the College in writing immediately of a relocation. If a move is part of your business plan, plan the new accreditation and its inspection into the move.
What flooring will pass?
Examination room floors must be fluid-impervious, and the standards state that unsealed concrete is not acceptable. That rules out the bare or partly sealed slabs common in converted industrial space. Plan on a proper sealed or sheet-goods system rather than a topical coating that has already worn through. Flooring is a leasehold improvement where you rent, which matters for how a Canada Small Business Financing Program loan is classified.
Is the reception desk an accessibility issue?
It can be. The Integrated Accessibility Standards Regulation’s service counter requirements are triggered “When constructing new service counters, which includes replacing existing service counters,” and a veterinary reception desk is a service counter. The Design of Public Spaces requirements apply where a public space is newly constructed or “redeveloped,” meaning planned significant alterations rather than maintenance. Sort the counter height, knee clearance and clear floor space at the millwork drawing stage.
Sources
- College of Veterinarians of Ontario — Accreditation Standards for Veterinary Facilities in Ontario
- Ontario e-Laws — R.R.O. 1990, Reg. 1093 (General) under the Veterinarians Act
- Ontario e-Laws — Veterinarians Act, R.S.O. 1990, c. V.3
- Ontario e-Laws — R.R.O. 1990, Reg. 861 (X-Ray Safety) under the Occupational Health and Safety Act
- College of Veterinarians of Ontario — Accreditation Process and Renewal
- Ontario e-Laws — Integrated Accessibility Standards Regulation, O. Reg. 191/11
- Ontario e-Laws — Building Code Act, 1992
- City of Toronto — Zoning By-law 569-2013, Chapter 800 Definitions
WALK THE STANDARDS BEFORE YOU FIRM UP
If you are looking at a veterinary facility in Toronto or the GTA, I will walk the premises with the accreditation standards in hand — the reception entrance, the exam room floors, the treatment area sinks, the surgical suite and its through traffic — and flag what is a priced fit-out item and what is a clause to negotiate in the lease before the offer is firm. The inspection is the College’s. The building is my part.
Book a 15-minute call or call or text 833-330-1925.
I cannot tell you what an inspector will conclude about “adequate size.” I can tell you which rooms are going to be the argument.
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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.