Do You Need a Medical Director to Open a Med Spa in Ontario?

The question behind the question

“Med spa” is a marketing term, not a legal category. What determines your obligations is the *services* you deliver. The moment your menu includes a controlled act such as injecting Botox or filler, you move into territory that requires physician involvement and clear lines of accountability.

What a medical director does

A medical director is a physician who takes responsibility for the medical quality and safety of the clinic's care. In cosmetic settings, the College of Physicians and Surgeons of Ontario has set out expectations covering patient assessment, appropriate delegation, supervision and oversight of delegated controlled acts. • Establishing protocols and medical directives for the procedures offered. • Ensuring practitioners are qualified and that delegation is appropriate and safe. • Overseeing patient assessment and complication management. • Retaining accountability for the medical care delivered under their direction.

Injectables: prescriber + authorization

Because botulinum toxin is a prescription drug and injecting is a controlled act, a clinic offering injectables needs a prescriber (physician or NP) involved and nurses working under an order or directive. Current College of Nurses of Ontario guidance (2026) reinforces this prescriber-linked model, and further tightening has been discussed.

Non-medical services: a different rulebook

If you only offer non-controlled-act services, your primary obligations are facility and infection-control standards under O. Reg. 136/18, inspected by your local public health unit — plus business basics like insurance, WSIB where applicable, and municipal requirements. Comparison — Injectables (Botox, filler, PRP) — Medical director / prescriber?: Yes; Main oversight: CPSO expectations + CNO authorization. Laser / IPL — Medical director / prescriber?: Often advisable; not a controlled act; Main oversight: Device-safety + facility rules. Facials, waxing, microneedling (non-medical) — Medical director / prescriber?: Usually not; Main oversight: O. Reg. 136/18, local public health.

Planning your clinic and your training

A practical way to structure oversight

If your clinic will offer medical services, decide the oversight model before you sign a lease or hire injectors. In broad terms, clinics either bring a physician in as an owner/partner, contract a medical director for defined oversight duties, or build the business around a nurse practitioner who can order and administer within their own scope. Each has different cost, control and accountability implications, and each must be a genuine clinical relationship — not a name on paper. • Clarify who assesses patients, who prescribes, and who is accountable for delegated acts. • Put protocols, medical directives and emergency procedures in writing. • Confirm the arrangement satisfies current college expectations before opening. • Budget realistically — genuine oversight has a cost, and shortcuts create liability. A recurring enforcement theme in cosmetic clinics is 'paper' medical directors who lend their name without real involvement. Regulators have signalled increasing scrutiny of exactly this. Structuring authentic oversight from day one is cheaper than fixing it after a complaint, and it protects patients, your injectors and your business. Deciding your service menu early tells you what oversight and staffing you need. Many owners start with non-injectable services they can deliver directly, then add injectables once physician oversight and qualified injectors are in place. Ziba's Medical Aesthetic Specialist diploma and comprehensive Aesthetic Diploma include practice-context training to help you plan realistically. Always confirm structure with a health lawyer and the relevant colleges before opening.