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Medical Spa Premises in Ontario: Zoning, Inspected Premises, Public Health Rules and the Lease

Published 29 September 2026 · By Jatin Dua, Broker of Record, RE/MAX Quantum Realty

Upscale ground-floor commercial unit with frosted glass in a GTA retail plaza, suited to an aesthetic clinic (illustrative)

By Jatin Dua · Broker of Record, RE/MAX Quantum Realty · Updated 29 September 2026 · 10 min read — how the medical and aesthetic halves of a medical spa each bring their own premises rules, and what I check in the unit and the lease.

Short answer

A medical spa’s space answers to two sets of rules. The medical side: the CPSO requires an inspected premises for permanent fillers and procedures under general, regional or parenteral anaesthesia, after a $500 application and an inspection; Botox, temporary fillers, laser skin resurfacing and sclerotherapy without those do not need it. The aesthetic side: where services are not primarily provided by regulated health professionals, O. Reg. 136/18 applies, with a dedicated hand-washing sink, a separate reprocessing sink for reusable equipment, easily cleanable surfaces, sterilizer testing at least every two weeks and 14 days’ notice to public health before opening. In Toronto, a change of use needs a building permit even with no construction, and zoning distinguishes a personal service shop from a medical office. Confirm the use first.

Zoning: medical office, personal service shop, or both

Toronto’s Zoning By-law 569-2013 defines a personal service shop as “premises used to provide personal grooming services or for the cleaning or care of apparel”, and separately names medical office as a use. A medical spa mixes the two. Which use the City treats yours as, and whether the zone permits it, is a question for the zoning examiner before you sign.

The City says a change of use needs a building permit even if no construction is proposed, and zoning must be complied with even where no permit is needed. Other GTA municipalities use different words for the same idea; check the by-law where the unit is.

Building Code occupancy

The Ontario Association of Architects’ occupancy guide, based on the Building Code, lists medical offices and beauty parlours in the business and personal services group, and shops in mercantile. A retail unit becoming a medical spa is usually a change of occupancy, with drawings, a permit and a check of exits, washrooms and fire separations. Procedures under sedation or anaesthesia raise different questions again, which is one more reason to know your service list before you design. The 2024 Building Code has been in force since 1 January 2025.

When the CPSO must inspect the premises

The CPSO’s Out-of-Hospital Premises inspection program covers procedures performed under general anaesthesia, parenteral sedation or regional anaesthesia, and cosmetic procedures including the injection or insertion of permanent filler. It does not apply to “temporary fillers, laser skin resurfacing, botox and sclerotherapy” performed without general, regional or parenteral anaesthesia.

Where the program applies, the medical director must complete a New Premises Inspection Application, pay a $500 fee and pass an inspection before those procedures start; the CPSO says the inspection is conducted within 180 days. If your business plan includes permanent fillers or sedation, build the inspection into the lease timeline and the design brief.

The aesthetic side: O. Reg. 136/18 setting rules

O. Reg. 136/18 does not apply where services are primarily provided by members of regulated health professions practising their profession. The Ministry’s 2019 guideline says medi-spas should be inspected to decide which side they fall on. If estheticians provide much of the work, plan the space to the regulation, which requires:

  • a setting free of health hazards, with floors, walls, ceilings, fixtures and furniture that are smooth, impermeable and easily cleanable;
  • no part of the setting used as a dwelling, including for eating or preparing food;
  • potable hot and cold running water under pressure;
  • at least one sink used only for hand washing, near the work area, with soap in a dispenser and single-use towels or a hot-air dryer;
  • where reusable equipment is used, a separate reprocessing sink big enough for the largest item, with counter space, not in a washroom, and separated from service areas;
  • enough lighting, ventilation, storage and waste receptacles, including for biomedical waste.

Sterilizers must meet Health Canada and CSA standards and be checked at least every two weeks unless public health directs otherwise. Sharps go into CSA-compliant containers near where the service happens.

Notices and Toronto licensing

Under O. Reg. 136/18, s. 3, anyone who intends to operate a personal service setting must notify the medical officer of health in writing at least 14 days before opening, and again at least 14 days before adding services or starting a renovation. Toronto Public Health asks for the notice at BodySafe@toronto.ca. In Peel, the region also asks for floor plans.

In Toronto, owners and operators of personal services settings need a licence with an endorsement for each class of service, and must give 30 days’ written notice before changing the classes offered. The most recent inspection notice must be posted near the entrance. If you are buying an existing business, read buying a medical spa in Ontario first.

Devices and power

I have not found an Ontario premises standard written specifically for laser rooms. Where O. Reg. 136/18 applies, equipment must be maintained according to the manufacturer’s instructions, and those instructions must be kept at the setting where staff can reach them. So the manufacturer’s installation requirements for power, ventilation and room layout become your design brief. Get them before you sign, and make sure the unit’s electrical service can carry the devices you plan.

Lease terms for a medical spa

  • Use clause. Cover both medical aesthetic procedures and personal services, naming the service classes.
  • Plumbing. Consent and capacity for a hand-washing sink and a separate reprocessing sink.
  • Waste. Landlord rules for biomedical and sharps waste pickup.
  • Alterations and removal. What you may build, and what must come out at the end.
  • Assignment. Conditions on a sale, and whether a change of control counts.
  • Exclusivity. Protection from a competing clinic in the same plaza.

Under the AODA, every business needs accessibility policies and training; at 20 or more employees a compliance report is due by 31 December 2026. The Design of Public Spaces standard applies to renovated public spaces, including service counters. For a more esthetics-led business, see day spa premises in Ontario; for a comparable clinic fit-out, dental office space in Ontario.

Where I fit

I help clinic and spa owners across Toronto and the GTA find, lease and buy space, and I check the zoning and the service list against the unit before the design 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.

Free tool — AI office space value estimator

Frequently asked questions

Does a Botox clinic need a CPSO premises inspection?

Not for Botox alone. The CPSO’s Out-of-Hospital Premises program excludes Botox, temporary fillers, laser skin resurfacing and sclerotherapy done without general, regional or parenteral anaesthesia. Permanent fillers and procedures under those types of anaesthesia need an inspected premises. Where required, the medical director pays a $500 fee and must pass the inspection first.

What sinks does a medical spa need in Ontario?

Where O. Reg. 136/18 applies, at least one sink used only for hand washing near the work area, and, if reusable equipment is used, a separate reprocessing sink big enough for the largest item, not in a washroom and separated from service areas.

Do I need to notify public health before opening a medical spa?

If the setting falls under O. Reg. 136/18, yes: written notice to the medical officer of health at least 14 days before opening, listing the services. In Toronto that goes to BodySafe; Peel also asks for floor plans. Settings primarily run by regulated professionals may be exempt.

Is a medical spa a medical office or a personal service shop under Toronto zoning?

It can look like either. Toronto’s by-law defines a personal service shop as premises for personal grooming services and names medical office as a separate use. Ask the zoning examiner how your service mix is classed in the property’s zone.

Are there Ontario rules for laser rooms?

I have not found an Ontario premises standard specific to laser rooms. Where O. Reg. 136/18 applies, equipment must be maintained to the manufacturer’s instructions, which should be kept at the setting, so the manufacturer’s installation requirements drive the design.

Sources

Related reading

About the author — Jatin Dua, Toronto and GTA real estate broker

I am Jatin Dua, Broker of Record and co-founder of RE/MAX Quantum Realty Inc., Brokerage, Unit 101, 799 The Queensway, Toronto. I work with buyers and sellers across Toronto and the GTA and have helped more than 100 families sell. Four-plus years of active GTA transactions and over $100 million in sales volume. Every figure here comes from a published table, regulator or statute linked in the sources, so you can check all of it without asking me.

Reach me at connect@jatindua.com or 833-330-1925, or book a call.

Please read this. General information current as at 29 September 2026. It is not legal, tax, accounting or financial advice. I am a registered real estate broker, not a lawyer or accountant. Nothing here values any specific business or property. Licensing and regulatory rules come from the regulators and legislation linked above and can change; confirm them with the regulator, your lawyer and your accountant before you sign anything. Worked examples use round illustrative numbers and are labelled as such; commission is negotiable and no rate here is a quote. Not intended to solicit clients currently under contract with another brokerage. Images are illustrative. E. & O.E.

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