Chiropractic Clinic Space in Ontario: Zoning, Change of Use, X-Ray Rooms and the Lease

By Jatin Dua · Broker of Record, RE/MAX Quantum Realty · Updated 29 September 2026 · 11 min read — the zoning, Building Code, X-ray and lease questions I work through before a chiropractor signs for a unit.

Zoning: how your clinic is classed

Zoning decides whether a clinic may operate in the unit. Toronto’s Zoning By-law 569-2013 names medical office as a use, and each zone lists the uses it permits. The by-law’s definitions chapter defines related uses such as massage therapy and wellness centre, so how a chiropractic clinic is classified in a particular zone is a question for the zoning examiner, not a guess.

The City of Toronto says a change of use needs a building permit even if no construction is proposed, and that the zoning by-law must be complied with even where no permit is needed. Every other GTA municipality has its own by-law; the principle is the same, the wording is not.

Ask the landlord to confirm the permitted uses in writing, and make the lease conditional on zoning if there is any doubt.

Building Code: occupancy and fit-out

Under the Ontario Building Code, medical offices, dental offices and offices are in the business and personal services group; shops are mercantile. The Ontario Association of Architects’ occupancy guide lists them that way. Moving from retail to clinic use is typically a change of occupancy, which brings drawings, a permit and a review of exits, washrooms, fire separations and barrier-free access. The current Code is the 2024 edition, in force since 1 January 2025.

For a chiropractic fit-out I look at room count against the number of practitioners, a washroom patients can reach without crossing staff areas, space for a reception and waiting area, and whether the floor can take adjusting tables and any X-ray equipment.

Planning an X-ray room

The Healing Arts Radiation Protection Act sets clear steps:

• Approval before installation. Section 3(1): no one may install an X-ray machine unless the Director has issued written approval. The Act says installation includes shielding the area where the machine is installed.
• Build to the approved plans. Section 3(4): once approved, the machine must be installed according to the plans and specifications submitted.
• Changes count as new installations. Sections 3(6) and 3(7): changing an approved installation needs the Director’s written approval.
• Registration before use. Section 4(1): the machine, its location and the owner’s name and business address must be registered before it is used on people. Changes of business address or email must be reported within 15 days.

For a lease, that means the landlord must allow shielding work, your schedule must allow for approval, and relocating the machine at the end of the term is its own approval process. If you are buying an existing clinic, see buying a chiropractic clinic in Ontario for the registration side.

Records storage and privacy

CCO standard S-002 requires records to be kept at least seven years after the last visit. Standard S-022 covers storage, security and destruction. Whether records are paper or electronic, the space needs somewhere secure for them and a front desk laid out so screens and files are not visible to the waiting room. In a shared clinic, the agreement should say who controls the records and how they are divided if the arrangement ends, without restricting patient access.

Lease terms that matter for a chiropractor

• Use clause. Name chiropractic treatment and any other services you plan, such as massage therapy or physiotherapy, and X-ray if relevant.
• Alterations. Landlord consent for shielding, plumbing and room partitions, and what must be removed at the end of the term.
• Assignment. The conditions for assigning the lease on a sale of the clinic, and whether a change in share ownership counts.
• Term and renewals. Long enough to recover the fit-out and any X-ray installation.
• Hours and access. Many clinics run early mornings, evenings and Saturdays; the lease should allow it.
• Exclusivity. Whether the landlord can lease nearby units to competing clinics.

Accessibility

Many chiropractic patients arrive in pain or with limited mobility. Under the AODA, businesses with fewer than 20 employees need accessibility policies and training; at 20 or more an accessibility compliance report is due by 31 December 2026; at 50 or more a multi-year plan must be posted online. The Design of Public Spaces standard applies to new construction and renovated public spaces, such as service counters, so a fit-out triggers it. A step-free entrance, a reachable washroom and parking close to the door matter here more than in an ordinary office.

Buying the unit instead of leasing

Owning removes the renewal risk that hangs over every clinic lease, and an approved X-ray installation stays where you built it. It also means your capital is in real estate as well as the practice. Check zoning, parking and building condition, and for a commercial condominium unit, the declaration’s use restrictions and the reserve fund. For comparisons, see optometry clinic space in Ontario and physiotherapy clinic space in Ontario.

Where I fit

I help chiropractors and clinic owners across Toronto and the GTA find, lease and buy space, and I read the zoning and lease before the design work starts. The office space value estimator below gives a quick range for clinic and office space. When you have a unit in view, book a call or phone 833-330-1925.

Frequently asked questions

Sources

• City of Toronto — Zoning By-law 569-2013, Chapter 800 definitions — personal service shop, massage therapy, wellness centre, body rub service
• City of Toronto — When do I need a building permit — change of use needs a permit even with no construction
• Ontario Association of Architects — Guide to occupancies — business and personal services examples
• Government of Ontario — Ontario’s Building Code — 2024 Building Code in force 1 January 2025
• Healing Arts Radiation Protection Act — e-Laws — X-ray installation approval and registration
• College of Chiropractors of Ontario — S-002 Record keeping — seven-year retention
• College of Chiropractors of Ontario — S-022 Ownership, storage, security and destruction of records — clinics owned by non-members; custodians
• Government of Ontario — Accessibility rules for businesses and non-profits — requirements by number of employees; compliance report due 31 December 2026

Related reading

• Buying a chiropractic clinic in Ontario
• Optometry clinic space in Ontario
• Massage therapy clinic space in Ontario
• Physiotherapy clinic space in Ontario
• Dental office space in Ontario
• AI office space value estimator
• Book a call with Jatin