What happened: On July 3, 2026 the College of Nurses of Ontario (CNO) published Aesthetic Services, its first practice guideline written for nurses who do medical aesthetics. It also said it “continues to consult” on how authorizing mechanisms, including directives and delegation, are used in this area. A law-firm bulletin from Fasken (September 1, 2026) describes a proposal to move away from medical directives toward client-specific orders, with a CNO decision expected in September 2026.
Status as of October 8, 2026: Public consultation closed on July 22, according to CBC, and the CNO said Council would consider the change at its September meeting. The CNO’s own Council calendar lists meetings on September 23 and 24, and December 9 and 10. We could not find a published outcome. Treat the directive change as proposed, not in force.
What the July guideline says
The guideline is the CNO’s first for aesthetics. It applies to NPs, RNs and RPNs and lists neuromodulators, dermal fillers, thread lifts, platelet rich plasma and microneedling as examples of aesthetic services. The parts that matter most to a clinic:
- Authority. If a procedure involves a controlled act, such as injecting a substance or performing a procedure below the dermis, the nurse needs an authorizing mechanism, either a direct order or a directive, from an authorized provider such as a physician or NP. The mechanism must be “clear, complete and appropriate”, judged against the client’s health history, contraindications and assessment. If it isn’t, the nurse must follow up with the authorized provider.
- A standing caveat. The guideline says the CNO “continues to consult with health system partners” on how directives and delegation are used in this area, and that nurses are expected to stay informed of changes when they take effect.
- Policies. Employers should set out the authorized provider’s availability for prompt consultation, emergency resources, and use of Health Canada-approved drugs, products and equipment. Approval elsewhere, such as by the FDA, does not carry over.
- Consent. Informed consent covers the procedure, costs, risks, expected results, the exact products used and why, alternatives, and how any photos or video will be used. It must be renewed when the care plan or condition changes.
- Documentation. The record should capture relevant health history, the care discussed and given, the drug or product used (name, lot number, dose, route and site), and the client’s consent.
- Advertising. Ads must be truthful, professional and ethical. They should include the nurse’s full name and designation, and the name of the authorizing provider or medical director. Prescription drug advertising is limited to name, price and quantity under section C.01.044 of the Food and Drug Regulations, which the guideline says rules out before-and-after pictures and testimonials about therapeutic effects. Media of clients needs consent and must not be digitally enhanced.
- Titles. Nurses must identify themselves with their full name and the designation that matches their CNO registration. Titles such as “expert” or “master” may mislead.
What is being proposed
Today, many Ontario clinics run on a medical directive: a physician or nurse practitioner prepares a standing plan for clients who meet defined conditions, and the nurse decides when to implement it without the prescriber assessing each client first. Directives suit high-volume, nurse-led clinics because treatment does not wait on a fresh assessment each time.
According to Fasken’s life sciences bulletin (September 1, 2026), the CNO is considering eliminating medical directives and making patient-specific direct orders the only authorizing mechanism for nurses in medical aesthetics. CBC reported the same proposal in July.
How much prescriber involvement would it take?
This is the part that has been misread, so it is worth being precise:
- The first reading was broad. When the proposal became public, some nurses and early coverage understood it to mean a physician or nurse practitioner would need to see the client at every visit, follow-ups included.
- The CNO says that is not the intent. A CNO spokesperson told CBC in July that under a direct-order approach a plan of care can continue over time without a new assessment or order at each visit, as long as the client’s condition, treatment goals and circumstances stay unchanged. In August the CNO told CBC that a medical director could authorize an ongoing care plan, provided the nurse keeps exercising professional judgment and accountability and the client is reassessed by the authorized provider if their condition or treatment needs change. It called the broader reading a misconception.
- Fasken’s bulletin now matches. Fasken updated its September bulletin after receiving clarification from the CNO. The current version describes prescriber involvement at the initial consultation and at later visits where the client’s circumstances change. Older copies of the bulletin may still carry the broader language.
We have not seen the CNO’s proposed wording itself. The June Council package contains only a brief mention that the CNO is working with partners on accountabilities in aesthetics, not the proposal text.
Reaction so far
- A petition against the change has more than 2,000 signatories, according to CBC. It argues that nurses could no longer independently carry out routine follow-up treatments and that the change’s safety benefit is not clear.
- The Registered Nurses’ Association of Ontario’s CEO told CBC the association is on the college’s side on the need to regulate these procedures.
- A Toronto clinic CEO told CBC the change would alter many business models, while also saying directive-based models can put patient safety at risk.
- Some Sudbury nurses told CBC they want more clarity on what the authorization changes would mean for their practice.
Nothing has changed yet. Fasken’s position is that, until the CNO decides, medical directives remain a valid authorizing mechanism and clinics can keep operating as they do now.
How this compares with other provinces
Fasken notes that Quebec, British Columbia and Alberta already require a client-specific order for nurses to give an aesthetic treatment (Alberta’s nursing college says so in its own practice advice, and adds that standing orders must never be used), and that the prescribing physician or nurse practitioner must stay close by during the injection in case of complications. Its argument is that Ontario would be catching up rather than breaking new ground. See our provincial roundup.
What suppliers may start asking
Fasken also flags a supply-side effect. Neuromodulators and fillers are prescription drugs, and a supplier that sells to a non-compliant clinic could face liability. If Ontario adopts the change, expect manufacturers and distributors to ask clinics for the name and licence number of the medical director or prescriber behind each directive or order, and for a compliance representation in account-opening paperwork. Having those details on hand is cheap insurance.
What to do now
You do not need to restructure yet. You can get ready for either outcome:
- Inventory your authorizations. List every directive in use, who signed it, its date, and which treatments it covers.
- Check how orders and assessments are recorded. If a client-specific order becomes the norm, your chart needs to show the order, who gave it, and when, tied to the visit it authorized, plus any change in the client’s condition or goals that triggered a new one. See our guide to injectable charting.
- Check your ads and clinic profiles. Names and designations should match the CNO register, and the authorizing provider or medical director should be named.
- Watch the CNO’s news page for the Council outcome rather than relying on social media summaries.
- Talk to your medical director now about how an order-based model would work: who assesses new clients, how an ongoing care plan would be written, what counts as a change in condition or goals that triggers reassessment, and what the extra prescriber time would cost.
- Have your medical director’s name and licence number ready for supplier due diligence.
Where Zdrovia fits
The guideline’s documentation list includes drug name, lot number, dose, route and site, plus signed consent. Zdrovia’s treatment charts, consent forms and lot tracking are built for that kind of record, which is also the documentation a client-specific order model would lean on. We will not pretend any software settles a regulatory question. Your college and your medical director do that. For a broader view of the nurse-injector workflow, see our guide to software for nurse injectors in Canada.
This is general information, not legal or regulatory advice. We update news items when the facts change, and the “verified” date above shows when we last checked.