RHPA Controlled Acts Explained for Aesthetic Practitioners
Ontario restricts higher-risk procedures through 'controlled acts.' Here is which aesthetic treatments are affected, and how authorization and delegation work.
Key idea: A 'controlled act' is a procedure Ontario law says is risky enough that only certain authorized professionals may perform it. Not every aesthetic treatment is a controlled act — but the ones that are (like injecting) carry strict rules you should understand before you choose a course.
What a controlled act is
Under the Regulated Health Professions Act, 1991, most health procedures are unrestricted, but a defined list of higher-risk procedures — the controlled acts — may only be performed by professionals whose legislation authorizes them (or by someone acting on a valid delegation). The goal is public safety: these are the acts where a mistake can cause real harm. For aesthetics, the controlled act that matters most is administering a substance by injection. Procedures that break the skin in other ways, or that use energy devices, may or may not be controlled acts depending on how they are performed and what is being treated — which is exactly why practitioners get confused.
Aesthetic treatments and the controlled-acts question
The table below is a general orientation for students, not legal advice. Whether a specific treatment is restricted can depend on depth, intent, the substance used and current regulatory interpretation. Always confirm with the relevant college. Comparison — Botox / neurotoxin injection — Typically involves a controlled act?: Yes — injection; Notes: Prescription drug; prescriber must be involved. Dermal filler injection — Typically involves a controlled act?: Yes — injection; Notes: Restricted to authorized injectors. PRP (draw + inject) — Typically involves a controlled act?: Yes — injection (and taking blood); Notes: Multiple controlled acts may apply. Microneedling — Typically involves a controlled act?: Depends on depth/intent; Notes: Superficial device work is often treated differently than medical needling; confirm scope. Laser / IPL — Typically involves a controlled act?: Generally not a controlled act; Notes: Governed instead by device-safety and facility rules. Chemical peels — Typically involves a controlled act?: Depends on depth; Notes: Superficial peels differ from medium/deep peels. Micropigmentation — Typically involves a controlled act?: Generally not a controlled act; Notes: Governed by personal-service-setting infection-control rules.
How delegation works
Some professionals perform a controlled act not because their own licence authorizes it directly, but because an authorized professional has delegated it under strict conditions. For nurses, authorization typically comes through an order or directive from a physician or NP; the College of Physicians and Surgeons of Ontario sets out how physicians may delegate and remain accountable for safe delegation. Delegation is not a loophole for unregulated practitioners. It flows between health professionals within a governed framework, with the delegating professional retaining responsibility.
Why this matters when you choose a course
Understanding controlled acts helps you invest in training you can actually use. If your credential does not authorize injection, an injectable course will not change that — but courses like laser technician training, microneedling, or the foundational Medical Aesthetician program can expand what you offer today. If your goal is injecting, plan the regulated-credential step first.
How to check a treatment's status before you offer it
When you're unsure whether a service you want to add involves a controlled act, work through a simple sequence rather than guessing. First, identify exactly what the procedure does to the body — does it involve injecting, taking blood, or working below the skin's surface into living tissue? Those features are the strongest signals that a controlled act may be involved. Second, check the position of the relevant regulatory college, which often publishes plain-language guidance for its members. Third, if you're a regulated professional, confirm the treatment sits within your own scope and any required authorization. • Ask: does it break the skin, inject a substance, or take blood? If yes, treat it as high-scrutiny. • Check the relevant college's published guidance and standards. • For regulated professionals, confirm your own scope and any orders/directives required. • When still unsure, get advice before offering the service — not after a complaint. This habit protects you as new treatments and devices constantly enter the market faster than guidance can keep up. A disciplined check also protects your insurance: insurers expect you to operate within scope, and a claim arising from an out-of-scope procedure may not be covered. Ziba's comprehensive Aesthetic Diploma is designed so students understand both technique and the professional context in which each treatment is delivered.
Ziba Aesthetics Training Institute
Ziba Aesthetics Training Institute is located at 7191 Yonge St, Unit 701, Markham, ON, serving the Greater Toronto Area. To learn more about the Aesthetic Diploma program or discuss your goals, book a consultation or start your application with our admissions team.
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External Resources
- Regulated Health Professions Act, 1991 (RHPA), s.27 controlled acts — Ontario e-Laws
Establishes that 'administering a substance by injection or inhalation' is a controlled act. Canonical e-Laws page (content is JavaScript-rendered; corroborated by multiple regulator summaries). Source: https://www.ontario.ca/laws/statute/91r18
- Delegation of Controlled Acts — College of Physicians and Surgeons of Ontario
CPSO policy on how physicians may delegate controlled acts and their accountability. Verified page reference. Source: https://www.cpso.on.ca/physicians/policies-guidance/policies/delegation-of-controlled-acts
- Scope of Practice — practice standard, College of Nurses of Ontario
CNO practice standard on controlled acts, orders and authorizing mechanisms for nurses. Verified. Source: https://cno.org/Assets/CNO/Documents/Standard-and-Learning/Practice-Standards/49041-scope-of-practice.pdf
