Buying a Medical Spa in Ontario: Who May Do Which Procedures, the Medical Director and What Transfers

By Jatin Dua · Broker of Record, RE/MAX Quantum Realty · Updated 29 September 2026 · 12 min read — how Ontario’s controlled-act rules, the CPSO, the College of Nurses and public health rules shape what a medical spa buyer actually gets.

What you are really buying

A medical spa is two businesses under one roof: a medical practice that performs regulated procedures, and a beauty business that offers facials, waxing or laser hair removal. The value sits in the client list, prepaid packages and memberships, the injectors and estheticians, the devices, product inventory, the lease and the brand. The medical side depends on people and authorizations that do not come with the keys.

No regulator, government body or real estate board in Canada publishes sale prices or valuation multiples for these practices. Anyone quoting you “the multiple” is quoting a private opinion. Price the business from its own records instead, and make the seller produce them.

Which procedures are controlled acts

The Regulated Health Professions Act, s. 27(1), says no one may perform a controlled act in the course of providing health care unless they are a member authorized by their profession’s Act or the act has been delegated to them by such a member. The list in s. 27(2) includes:

• item 2: performing a procedure on tissue below the dermis;
• item 5: administering a substance by injection or inhalation;
• item 7: applying a form of energy prescribed by the regulations.

The College of Nurses of Ontario’s aesthetic services guideline says injecting neuromodulators and dermal fillers involves the controlled acts of performing a prescribed procedure below the dermis and administering a substance by injection. It covers neuromodulators, dermal fillers, thread lifts, platelet-rich plasma and microneedling.

The forms of energy prescribed under item 7, in O. Reg. 107/96, are specific uses of electricity, electromagnetism for MRI and soundwaves for diagnostic ultrasound or lithotripsy. Lasers are not on that list. Toronto Public Health’s BodySafe program lists laser hair removal as an aesthetic service it inspects.

The medical director and delegation

The CPSO’s Delegation of Controlled Acts policy, last updated May 2026, requires a physician to delegate only within an existing or anticipated physician-patient relationship; to clinically assess a new patient before delegating or within two business days of the delegate starting care, subject to exceptions; to be physically on site to supervise unless an exception applies; and not to delegate primarily for monetary gain or convenience. Medical directives must set out the procedure, the conditions, contraindications, who is authorized and the physician’s signature.

In June 2026 the CPSO published its expectations of physician medical directors in cosmetic clinics. It expects a contract that sets out the director’s role, verification of staff competence, and delegation that works as a “physician extender, not a physician replacement.”

For a buyer, the practical point is that the director’s directives, delegations and oversight belong to that physician and those staff. If the medical director leaves on closing, the injectable side stops until a new arrangement is in place. Make the director’s continued role, or a replacement, a condition of your offer. The same people-dependence runs through buying a dental practice in Ontario, another practice where regulated professionals carry the value.

Nurse injectors

The College of Nurses’ 2026 guideline applies to nurse practitioners, registered nurses and registered practical nurses. Where a procedure requires a controlled act, the nurse needs an authorizing mechanism, such as a direct order or directive, from an authorized provider such as a nurse practitioner or physician, and it must be based on an assessment of the client. The guideline expects all drugs, substances, products and equipment used to be Health Canada-approved, sets rules for advertising, and expects nurse practitioners who issue orders and directives to stay actively involved with the team carrying them out. CNO also says it is still consulting on how directives and delegation are used in this area, so expect change.

Check every injector on the public register of their College before you rely on their revenue.

Who may own it

I did not find a published Ontario rule that says who may or may not own a cosmetic clinic business. The rules above govern who performs procedures and who authorizes them, not who owns the company. There is one structural limit: if the seller operates through a medicine or nursing professional corporation, the Business Corporations Act, s. 3.2, requires its shares to be owned by members of that profession, so a non-member buys assets, not shares. Have a health lawyer structure the deal.

Inspected premises, public health and Toronto licensing

The CPSO’s Out-of-Hospital Premises program covers procedures under general anaesthesia, parenteral sedation or regional anaesthesia, and cosmetic procedures including injection or insertion of permanent filler. It does not apply to “temporary fillers, laser skin resurfacing, botox and sclerotherapy” without those types of anaesthesia. Where it applies, the medical director must apply, pay a $500 fee and pass an inspection before performing those procedures. Ask which list the seller’s services fall on.

Ontario’s personal service settings regulation, O. Reg. 136/18, does not apply where services are primarily provided by regulated health professionals practising their profession, and the Ministry’s guideline says medi-spas should be inspected to decide which side of that line they fall on. In Toronto, a personal services worker excludes members of regulated health professions, so aesthetic services by estheticians bring the personal services setting licence. Toronto licences are not transferable; see buying a day spa in Ontario for how a new owner applies.

HST, packages and staff

The Excise Tax Act deems a “cosmetic service supply”, made for cosmetic rather than medical or reconstructive purposes, not to be part of the exempt health care list. So cosmetic procedures are generally taxable even when a physician or nurse performs them. On the sale itself, a s. 167 election on CRA form GST44 may be available if you buy all or substantially all of the business assets.

Prepaid packages, memberships and gift certificates are services you will have to deliver. Get the list with balances. Under the Employment Standards Act, s. 9, employees you keep bring their service with them unless you hire them more than 13 weeks after the earlier of their last day with the seller and the sale date.

Documents I would want before an offer

1. Three years of financial statements, tax and HST returns, with revenue split by injectables, devices, esthetics and retail.
2. The medical director contract, all medical directives and delegation records.
3. Every injector’s and physician’s College registration status.
4. A list of procedures performed, and whether any need a CPSO-inspected premises.
5. Device list with purchase records, service logs and manufacturer instructions.
6. Product purchase records, showing sources.
7. Toronto personal services setting licence, endorsements and the most recent public health inspection notice and reports.
8. Open packages, memberships and gift certificates with balances.
9. The lease and assignment conditions.

The space has its own checklist; see medical spa premises in Ontario.

Where I fit

I work with buyers and sellers of clinics and spas across Toronto and the GTA on the lease, the assignment and the space. The salon and spa business value estimator below gives a rough range for a beauty-services business. When you have a clinic in mind, book a call or phone 833-330-1925.

Frequently asked questions

Sources

• Regulated Health Professions Act, 1991, s. 27 — e-Laws — controlled acts
• O. Reg. 107/96 (Controlled Acts) — e-Laws — prescribed forms of energy
• CPSO — Delegation of controlled acts — last updated May 2026
• CPSO Dialogue — Expectations of physician medical directors in cosmetic clinics — June 2026
• CPSO — Out-of-hospital premises inspection program — which cosmetic procedures need an inspected premises
• College of Nurses of Ontario — Aesthetic services practice guideline
• College of Nurses of Ontario — New guideline for nurses on aesthetic services
• Ministry of Health — Personal Service Settings Guideline, 2019 — medi-spas and regulated professionals
• O. Reg. 136/18 (Personal Service Settings) — e-Laws — notice, setting, equipment and records rules
• Toronto Public Health — About BodySafe — inspections and 14-day notice
• Excise Tax Act, Schedules V and VI — Justice Laws Website — exempt practitioner services, cosmetic service supplies, prescription eyewear
• Employment Standards Act, 2000 — e-Laws — s. 9 sale of a business; s. 67.2 non-compete agreements

Related reading

• Medical spa premises in Ontario
• Buying a day spa in Ontario
• Buying a massage therapy clinic in Ontario
• Buying a dental practice in Ontario
• Buying a pharmacy in Ontario
• AI salon business value estimator
• Book a call with Jatin