What you can and cannot offer without a physician in Quebec: how the line is drawn
Read this first. This page does not tell you which treatments you may offer. Nobody responsible can do that in an article, because the answer depends on the specific act, the specific professional performing it, and a regulator’s current position — not on what the treatment is called.
What this page does is explain who decides, on what basis, and how to get a defensible answer for your own menu before you advertise it, hire for it, or buy the device that delivers it.
This is the question that most often gets answered by the wrong person: a supplier with a machine to sell, a competitor who may themselves be wrong, or a forum. It is also the question with the least forgiving consequences, because getting it wrong reaches your insurance, your liability and, for any regulated professional involved, their standing with their order.
The central misunderstanding
“Medical aesthetics” is a marketing category, not a legal one. No rule in Quebec turns on whether a service is described as medical, medico-aesthetic, advanced or clinical. Regulation operates on acts, and asks whether a given act falls within an activity the law reserves to members of a particular professional order.
So the useful question is never “is this treatment medical?” It is: what exactly is being done to the person, by whom, and does that act belong to someone’s reserved scope? Two services with the same commercial name can land on opposite sides of that question depending on depth, energy, what is introduced into the body, and what is claimed for it.
Who decides in Quebec
Quebec organises regulated work through professional orders established under the Professional Code, which is the statute that creates the orders and the framework of reserved activities. Each order governs its own members and publishes positions on how its reserved activities apply in practice.
For anything touching medicine, the relevant body is the Collège des médecins du Québec, which has published its observations on aesthetic medicine and the responsibilities attaching to procedures using energy-based devices — see the CMQ on aesthetic medicine. If your plan involves injectables, energy-based devices, or anything that alters tissue below the surface, that document is where to start reading rather than a supplier’s brochure.
Where nursing professionals are involved, their own order governs what they may perform and under what conditions. The relevant question is always which order claims the act, and what that order currently says.
Delegation exists. You cannot create it yourself
Reserved activities can, in defined circumstances, be performed by others under conditions the regulator sets. That is a real mechanism and many clinics operate within it properly.
What does not work is manufacturing authority privately: a supervision clause in an employment contract, a physician who signs off remotely without meeting anyone, a “medical director” whose involvement is nominal, or a training certificate treated as a licence. A certificate proves you were taught something. It does not confer the right to perform a reserved act, and no supplier can grant that right by issuing one.
How to get a defensible answer for your own menu
Do this per service, before it goes on the price list:
- Describe the act physically, not commercially. Write down exactly what happens to the tissue, with what instrument, at what depth or energy setting, and what substance if any is introduced. That description — not the brand name of the treatment — is what an order will assess.
- Identify who would perform it, with their profession and their current registration.
- Ask the relevant order directly, in writing, describing the act as written in step one. Orders answer these questions; suppliers guess at them.
- Take legal advice where the answer is not plainly clear, and before you build a business case around the service.
- Keep the answer, dated, in a file with the service. Positions evolve, and what matters later is what you asked and when.
- Re-check on a schedule, and always before adding a modality or changing who performs one.
Five ways people get this wrong
| The mistake | Why it fails |
|---|---|
| Taking the supplier’s word | A vendor is not a regulator and carries none of the consequence. “Other clinics use it” is a sales line, not a legal position |
| Treating a certificate as authority | Training proves competence in a technique. It does not confer the right to perform a reserved act |
| Copying a competitor | You cannot see their staffing, their supervision arrangements, or whether they are correct. Some of them are not |
| Nominal medical direction | An arrangement that exists on paper but not in practice tends to be assessed on what actually happened, not on what the contract said |
| Marketing beyond the act | Claims can change how a service is characterised. Describing a treatment in medical terms invites the question of whether it is one |
Why this is a business question, not only a compliance one
Three commercial consequences follow directly, and all of them are expensive:
- Insurance. Professional liability generally responds to declared activities performed by qualified people. A modality outside that description is exactly where cover is argued about, and that argument happens at the worst possible moment.
- The equipment decision. A device is only an asset if you can lawfully use it. Confirm both that it is licensed for sale in Canada and that someone on your team may operate it, before you sign for it — see lease or buy for what that signature commits you to.
- The menu you may have to withdraw. Building demand for a service you later stop offering costs more than never offering it: you lose the revenue, the marketing spend, and the clients who came for that one thing.
If you are buying an existing clinic, this is also a diligence item rather than an assumption — the seller’s arrangement is not automatically yours and may not have been correct in the first place. It is item nine on the list in buying an existing clinic.
What to ask whom
| Ask a supplier | Ask a regulator or your lawyer |
|---|---|
| What the device does, physically, and at what settings | Whether that act is reserved, and to whom |
| Whether it holds a current Canadian device licence | Whether the person you intend to have perform it may do so |
| What training is provided and to whom | What supervision, if any, is required and what it must consist of |
| What the manufacturer’s indications are | How the service may lawfully be described in your advertising |
Keep those columns apart. Most of the trouble in this area comes from someone answering a question from the right-hand column while standing in the left-hand one.
For the wider picture of what a clinic requires before opening, see how to open a med spa in Quebec and the business plan.
Frequently asked
Can I offer medical aesthetic treatments without a physician in Quebec?
It depends entirely on the specific act, not on how the treatment is marketed. Some acts are reserved to members of a professional order; others are not. Describe the act physically, identify who would perform it, and ask the relevant order in writing before offering it.
Is “medical aesthetics” a legal category?
No. It is a marketing category. Regulation operates on acts and asks whether an act falls within an activity reserved to a professional order, which is why two services with the same commercial name can be treated differently.
Does a training certificate let me perform a treatment?
No. A certificate demonstrates that you were trained in a technique. It does not confer the right to perform an act reserved to a professional order, and no supplier can grant that right by issuing one.
Is a medical director enough to cover a clinic?
Delegation and supervision are real mechanisms, but they are defined by the regulator and assessed on what actually happens rather than on what a contract says. An arrangement that exists only on paper is unlikely to be treated as one that exists.
Who should I ask?
The professional order that would claim the act, in writing, with the act described physically rather than by brand name — and a lawyer where the answer is not plainly clear. Not the company selling you the device.
Next in this series
Sources
- Gouvernement du Québec, Professional Code (C-26). Checked 30 August 2026.
- Collège des médecins du Québec, Médecine esthétique: observations et responsabilités. Checked 30 August 2026.
- Health Canada, Medical Devices Active Licence Listing (MDALL). Checked 30 August 2026.
This page is general information about how scope of practice is determined in Quebec. It is not legal advice, it is not a statement of what any particular person or clinic may lawfully do, and it must not be relied on as authority for offering any treatment. Reserved activities, regulators’ positions and their application to specific acts change over time. Confirm your own position in writing with the relevant professional order and with a lawyer before offering, advertising or hiring for any service. Nothing here is a representation of the financial performance of any New Age Spa location or franchise, and it is not an offer to sell a franchise; where the law requires one, an offer is made only by disclosure document.
