Physicians in Aesthetic Medicine in Quebec: Obligations, Opportunities, and What the CMQ Requires - Aesthetic Training

Educational reference for physicians in Quebec considering or currently practising aesthetic medicine. This article does not constitute legal advice, an official CMQ interpretation, or authorization to perform any procedure. Always confirm current requirements with the CMQ, your professional liability insurer, and qualified legal counsel before undertaking or modifying aesthetic medicine practice.

Quebec’s aesthetic medicine sector has expanded over the past decade. Physicians from family medicine, emergency medicine, anesthesiology, pain medicine, and other disciplines may consider adding aesthetic medicine to their practice. These services are generally provided outside the public insurance system and may offer physicians a different clinical and scheduling model, but no particular income, demand, or work-life outcome can be assumed.

But this expansion has not occurred without regulatory attention. The Collège des médecins du Québec has been consistent and increasingly forceful in its position: aesthetic medicine is medicine first. The commercial setting of an aesthetic clinic does not reduce the physician’s obligations. The fact that patients are paying out of pocket does not mean the standard of care is lower. And the interprofessional model, in which physicians write orders for nurses to execute, does not transfer the physician’s professional responsibility to anyone else.

In May 2024, the CMQ and the Ordre des infirmières et infirmiers du Québec published a joint advisory concerning non-compliant practices in Quebec’s aesthetic medicine sector. In November 2025, the CMQ joined the ODQ, OIIQ, and OIIAQ in announcing a joint initiative to develop common parameters for medical-aesthetic care. As of July 22, 2026, no completed common framework was identified on the CMQ’s public aesthetic medicine page.

For physicians who want a serious, sustainable career in aesthetic medicine, understanding the full scope of what the CMQ requires is not bureaucratic compliance. It is the foundation of safe practice and sound professional reputation.

This article covers the framework that applies to Quebec physicians in aesthetic medicine: training and practice-change obligations, patient evaluation, prescribing, the 15-minute physician-availability requirement, commissions and revenue-sharing, clinical records and registers, advertising, privacy, fees, clinic arrangements, responsible-physician roles, and professional opportunities.

What Do the CMQ Aesthetic Medicine Guidelines Require from Quebec Physicians?

The CMQ aesthetic medicine guidelines treat these services as medical practice. A Quebec physician must practise within competence, follow the applicable CMQ process when adding or returning to the field, evaluate every patient in person, establish a diagnosis and individualized treatment plan, obtain written informed consent, write complete individual orders when delegating treatment, remain available for rapid complication management, maintain compliant records and registers, charge only permitted fees, and follow advertising, privacy, and professional-independence rules.

What the CMQ Means by Aesthetic Medicine, and Why the Definition Matters

The CMQ defines aesthetic medicine as any non-surgical medical technical act, performed using an instrument, substance, injectable product, or energy-based device, with the principal aim of modifying a patient’s appearance for aesthetic purposes, to the exclusion of therapeutic or reconstructive goals.

This definition covers a wide range of procedures: botulinum toxin A injections, hyaluronic acid dermal fillers, biostimulators, platelet-rich plasma, microneedling, laser resurfacing, intense pulsed light treatments, radiofrequency, high-frequency ultrasound, and chemical peels of medical grade. The common thread is that the primary purpose is aesthetic modification, not treatment of a pathological condition.

The CMQ’s foundational position is equally clear: “exercer dans le domaine de la médecine esthétique, c’est d’abord et avant tout exercer la médecine.” Aesthetic medicine is the practice of medicine. A physician who provides botulinum toxin A injections has the same obligations of evaluation, diagnosis, treatment planning, informed consent, prescribing, follow-up, and documentation that apply in any other medical context. The spa-like environment of an aesthetic clinic, the cash payment model, and the elective nature of the treatments do not reduce those obligations.

This framing is not merely philosophical. It is the basis of every regulatory requirement that follows. A physician who treats aesthetic medicine as a beauty service they happen to be legally permitted to provide will find themselves exposed professionally. A physician who treats it as medicine, applying the same rigour and the same ethical framework they would bring to any other domain, will build practice that is sustainable, safe, and defensible.

The CMQ’s Regulatory Evolution: 2016 to 2026

Understanding where the regulatory framework has been helps physicians understand where it is going.

In 2016, the CMQ adopted a working-group report recommending fundamental changes to how aesthetic medicine was practised in Quebec. At the time, collective orders were widely used, physician involvement was often minimal, and the practice environment had significant gaps in patient safety. The working group recommended mandatory individual evaluations, the end of collective orders for aesthetic injections, formal training requirements for physicians entering the field, and a comprehensive guide to practice.

In May 2017, the new framework took effect. Collective orders for aesthetic injections were prohibited from that date. Physicians were required to conduct in-person evaluations before writing aesthetic injection orders.

In August 2020, the CMQ published its comprehensive 66-page Guide d’exercice on aesthetic medicine. This guide remains the governing document for physician practice in this field. It covers physician training, patient evaluation, individual orders, prescribing standards, the 15-minute on-site availability requirement, record keeping, clinical file management, advertising, interprofessional collaboration, fees, and professional independence. Every physician practising aesthetic medicine should have read this guide.

In November 2023, the CMQ published a clarifying article titled “Médecine esthétique: observations et responsabilités,” reinforcing key requirements and adding specifics about the service corridor concept and the 15-minute on-site availability rule. This article also addressed the roles of each professional in the interprofessional model.

In May 2024, following a Radio-Canada investigation into practices at Quebec aesthetic clinics, the CMQ and OIIQ issued a joint advisory. The advisory identified specific abuses: physicians writing orders without ever evaluating the patient, physicians and nurses failing to establish conditions for rapid complication management, injections administered in unsafe environments, and injections at non-prescribed or non-recommended sites. The CMQ president’s accompanying statement described deep concern about the non-respect of roles and responsibilities.

In July 2024, a new regulation on clinical records came into force, raising the physician’s record retention obligation from 5 years to 10 years.

In August 2025, the CMQ added an advisory based on a coroner’s report concerning severe cerebral anoxia during medical-aesthetic surgery. The publication renewed attention to safety standards, sedation, emergency preparedness, and adverse-event management in private medical-aesthetic settings.

In November 2025, the CMQ, ODQ, OIIQ, and OIIAQ jointly announced a collaborative initiative to define common parameters for aesthetic medicine practice across all four professions. The framework was expected to conclude during 2026. As of July 2026, it has not yet been published.

Before You Begin: Who Needs to Notify the CMQ and Why

A physician licensed to practise in Quebec who wants to add aesthetic medicine as a new domain of practice must first notify the CMQ and submit the Demande d’ajout, de changement de domaine ou de retour à l’exercice. This initiates the CMQ’s assessment of whether an activity de perfectionnement is required before the physician begins or resumes practice in the requested aesthetic medicine domain.

The CMQ’s published guidance identifies physicians whose specialty training ordinarily includes relevant aesthetic medicine education as plastic surgeons, dermatologists, ophthalmologists, otorhinolaryngologists, and cervicofacial surgeons. Physicians who were previously trained in aesthetic medicine but have not practised in the field for three years or more must contact the CMQ before beginning or resuming the practice.

Every other physician, including family physicians, emergency physicians, anesthesiologists, internists, gynecologists, and specialists whose postdoctoral program did not include the relevant aesthetic medicine training, must notify the CMQ before adding the domain. The CMQ reviews the physician’s current practice, intended products or techniques, prior education, and proposed training plan to determine what theoretical or practical improvement activity is required.

The CMQ’s aesthetic medicine page currently directs physicians to complete the Demande d’ajout, de changement de domaine ou de retour à l’exercice and submit it to the CMQ’s professional-development service. The CMQ’s broader improvement-activities page also directs physicians to begin through Accès M.D. Because these public instructions are not expressed identically, physicians should use the current process shown in their CMQ account or confirm the required submission channel directly with the CMQ before sending documents.

The CMQ establishes the physician-specific objectives and determines the accepted supervision and reporting process. The physician then completes the required theoretical and practical components. The stage supervisor documents the physician’s progress and achievement of the objectives, and the CMQ determines whether the pathway is complete or whether additional training is required.

Because the pathway is physician-specific, a private course certificate does not independently create CMQ recognition or authorization. Physicians should obtain the CMQ’s written direction before enrolling in or paying for training. AMEQ Academy may participate in the pathway when Dr. Angelina Guzzo is named or accepted by the CMQ as the maître de stage for the physician’s file and the training parameters have been confirmed in writing.

The Training Obligations: Theoretical and Practical Components

If the CMQ determines that training is required before a physician may begin aesthetic medicine practice, the pathway is assessed in relation to that physician’s own experience, proposed procedures, and practice-change file. The CMQ does not automatically accept a private course certificate as the required theoretical training or formal practical stage. Before enrolling in or paying for a course, the physician should communicate with the CMQ department responsible for practice improvement and professional development, submit the required practice-change information, and obtain written direction about the training objectives, practical stage, supervisor, patient exposure, reporting, and supporting documents the CMQ will require.

Theoretical Training

The CMQ’s position on theoretical training is explicit: reading product monographs, attending pharmaceutical representative presentations, or participating in device demonstrations by sales representatives does not constitute adequate theoretical training. A formation in clinical dermatology is described as particularly important.

A complete theoretical training for aesthetic medicine must enable the physician to demonstrate knowledge of:

• Facial anatomy at clinical depth, including histology and cutaneous physiology, the principles of skin aging, and the anatomical structures relevant to each aesthetic procedure, including vascular anatomy and danger zones.
• The ability to distinguish and diagnose different cutaneous pathologies, including pigmented lesions, rosacea, vascular lesions, acne, scarring, and precancerous conditions, because a physician practising aesthetic medicine may encounter these presentations and must be able to manage or refer them appropriately.
• The ability to establish a diagnosis and a treatment plan that responds to the patient’s needs and expectations, while remaining within the standards of current medical practice.
• Deep knowledge of injectable products, including neuromodulators and filling agents, as well as laser and energy-based modalities, chemical exfoliations, and other relevant treatments. For each modality, the physician must know the mechanisms of action, the indications, the contraindications, the technical parameters, the expected and possible adverse effects, and the follow-up obligations.
• The management of complications, including the recognition and treatment of immediate and delayed adverse events, and the conditions under which the physician must refer the patient elsewhere.
• The ability to assess the quality of treatments administered and to evaluate patient satisfaction objectively.
• Understanding of the deontological and regulatory framework that applies specifically to aesthetic medicine in Quebec.

The CMQ notes that physicians who intend to limit their aesthetic medicine practice to specific procedures (for example, only injectable treatments) are still required to complete theoretical training covering the full scope of aesthetic medicine. This is because comprehensive knowledge allows the physician to determine the most appropriate treatment for each patient and to refer appropriately when a different modality would be better.

Practical Training

Beyond theoretical knowledge, the physician must complete a formal practical training stage. This stage is supervised by a CMQ-mandated maître de stage, who must be a physician who has been practising aesthetic medicine for more than five years and specifically using the techniques being taught for that period.

The CMQ’s current standard requires a practical stage of a minimum of four days, including the treatment and follow-up of a minimum of five patients across different anatomical regions, using different products or devices. The follow-up session, at which the physician reviews patients treated during the stage and evaluates results, is explicitly included in the four-day minimum.

During the stage, the maître de stage must observe the physician directly, provide corrective feedback, and evaluate the physician’s achievement of defined objectives. A stage report documenting the achievement of objectives must be completed by the maître de stage and submitted to the CMQ.

After the stage, the supervisor submits the required report and the CMQ evaluates whether the physician-specific objectives have been met. The CMQ may require additional training or documentation when the objectives have not been demonstrated.

The practical training can be individual or in a group format. It must allow the physician to observe the maître de stage evaluating patients, demonstrate clinical judgment, write a treatment plan, obtain informed consent, perform the required procedures, and document each patient encounter appropriately.

Before Paying for Training: Confirm the Pathway with the CMQ

Physicians may enrol in and pay for a private aesthetic medicine course, only to learn afterward that the program does not satisfy the CMQ process applicable to their file. Tuition payment and a provider certificate do not create CMQ recognition or authorization. The CMQ process must therefore be confirmed before the physician commits financially to training.

The CMQ guide states that, before beginning theoretical or practical training in aesthetic medicine, the physician must communicate with the CMQ so the objectives and terms of any required improvement activity can be evaluated. The CMQ first confirms whether formal training is required. Where it is required, the CMQ is responsible for the physician-specific process, including the appointment or acceptance of the stage supervisor, the required objectives, the stage report, and the committee’s final assessment.

Before paying a deposit or tuition, the physician should obtain written answers to the following questions:

• Has the CMQ reviewed my proposed addition, change of domain, or return to aesthetic medicine practice?
• Does my file require theoretical training, a formal practical stage, or both?
• Will the proposed theoretical program address the objectives the CMQ has identified for my file?
• Who may act as the maître de stage, and must that person be appointed or accepted by the CMQ before the stage begins?
• Does the proposed practical format provide the minimum duration, patient exposure, direct supervision, follow-up, and reporting required for my file?
• What documents must the provider and supervisor supply so the CMQ can evaluate completion?

A physician should be cautious with terms such as “CMQ-accredited course,” “CMQ-approved course,” or “guaranteed CMQ recognition.” The CMQ evaluates the physician’s pathway and the required training process. A private provider may offer content aligned with the CMQ guide, but the provider cannot replace the CMQ’s assessment or guarantee authorization.

Competence Maintenance

Completing initial training is the beginning, not the end, of the physician’s education obligations in aesthetic medicine. The Code de déontologie des médecins requires physicians to practise within the limits of their competence, to maintain and develop their knowledge, and to recognize and respect the limits of their expertise.

In aesthetic medicine specifically, the CMQ suggests that a physician maintaining their competence might envisage practising aesthetic medicine for 10 to 15 hours per week minimum, within a two-year window after beginning practice, in order to encounter patients with varied needs, practise different techniques, and ensure follow-up of procedures. This recommendation reflects the degree of clinical exposure the CMQ considers consistent with competence maintenance.

Formal continuing education activities recognized by the CMQ are also expected. These can include individual activities (stages, tutoring) or collective learning activities (workshops, seminars, conferences, reading groups) offered by recognized medical associations, or recognized quality evaluation activities. These activities must be specific to aesthetic medicine and to the physician’s particular practice.

The In-Person Medical Evaluation: No Exceptions

Every patient who wishes to receive aesthetic medical care in Quebec must first receive an in-person medical evaluation by a physician. This is the CMQ’s foundational clinical requirement, and it admits no exceptions.

The CMQ is explicit: “le médecin doit évaluer le patient en personne. Une évaluation à distance, par voie de télémédecine, ne répond pas aux exigences d’une pratique adéquate et sécuritaire pour ce type d’exercice.”

A video consultation does not satisfy this requirement. A review of photographs submitted by the patient does not satisfy this requirement. A telephone conversation does not satisfy this requirement. A review of an intake form completed by clinic staff does not satisfy this requirement. An evaluation conducted by a nurse who then reports to the physician does not satisfy this requirement.

The physician must examine the patient in person, because many of the clinical assessments required for safe aesthetic treatment cannot be made from photographs or history alone. Skin texture, volume distribution, facial symmetry, the presence of underlying pathologies, the assessment of natural facial motion, and many other clinically important observations require physical examination.

The in-person evaluation must:

• Confirm the patient’s relevant medical history, including medications, prior treatments, allergies, contraindications, and personal and family health history relevant to the proposed treatment.
• Assess the patient’s anatomical presentation in the treatment zones, including the conditions of the skin, the volume distribution, the muscular patterns, and any asymmetries or pre-existing conditions that affect treatment planning.
• Establish a diagnosis in the aesthetic medicine sense: what is the patient’s condition, what is the clinical indication for treatment, are there contraindications, and is this patient a safe and appropriate candidate for the proposed treatment?
• Develop an individualized treatment plan specific to this patient: which sites will be treated, with which products, at which doses, using which technique, at which frequency.
• Obtain the patient’s informed written consent for the proposed treatment, after a full discussion of risks, benefits, alternatives, and what happens if no treatment is performed.
  

In the interprofessional model, where the physician writes an order for a nurse to execute, the physician’s in-person evaluation must occur before the nurse’s session. The physician cannot evaluate the patient retrospectively or concurrently with the nurse’s administration of the treatment.

Diagnosis and Treatment Planning: Clinical Standards That Apply to Aesthetic Medicine

The physician’s obligation to elaborate a diagnosis carefully, using current scientific methods, applies fully to aesthetic medicine. This is not merely a box to tick before writing an order. It is a clinical requirement with real professional consequences.

In aesthetic medicine, the diagnostic step involves: identifying the patient’s presenting concern, assessing the anatomical and physiological basis for the concern, determining whether the proposed treatment is medically and aesthetically appropriate, ruling out contraindications and underlying conditions, and determining the most appropriate treatment approach.

Before writing an order for a nurse to execute, the physician must be confident of the following: that they have evaluated this specific patient in person; that they have an individualized treatment plan based on that evaluation; that the planned treatment is within both the physician’s and the nurse’s competence; that appropriate consent has been obtained; and that the conditions exist to manage any adverse event.

The physician who writes an aesthetic injection order without proceeding through these steps rigorously and competently is in violation of the CMQ’s Guide d’exercice. This is one of the abuses specifically flagged in the May 2024 CMQ-OIIQ joint advisory.

Individual Orders: The Complete Prescribing Obligation

Since May 2017, collective orders for aesthetic injections have been prohibited. Every patient receiving aesthetic injectable treatment in Quebec under a nurse’s administration must have their own individual order, written by a physician (or, in the ODQ scope, a trained dentist) who has evaluated them in person.

A collective order is a standing prescription that authorizes a nurse or group of nurses to treat patients who meet defined criteria without an individual physician evaluation. In some healthcare contexts, collective orders are appropriate and effective. In aesthetic medicine, they are prohibited because the clinical decision cannot be standardized: each patient’s anatomy, health history, and aesthetic indication is unique and requires an individual clinical assessment.

What a Complete Individual Order Must Contain

An aesthetic medicine individual order is a clinical document, not a form. Under the Règlement sur les normes relatives aux ordonnances faites par un médecin (RLRQ c. M-9, r. 25.1), it must include:

• The physician’s identification: name in print, permit number, and contact information including telephone number at which the executing nurse can reach the physician.
• The patient’s identification: at minimum, name and date of birth.
• The date of the order and its validity period.
• For an order to treat (ordonnance de traitement): the nature of the treatment, the anatomical sites, the specific product at each site, the quantity or dose at each site, the frequency of treatment, and the total duration if applicable. For botulinum toxin A, this means naming the specific muscles or regions and the units prescribed for each. For dermal fillers, this means the specific anatomical region, the product type, and the volume prescribed.
• For an order to initiate or adjust (ordonnance visant à ajuster ou à initier): the name and contact information of the nurse or group of nurses authorized to execute the order; the indication opening the order to use; the dosage adjustment parameters the nurse is authorized to make; the conditions that require a new physician evaluation; the conditions for stopping or deferring treatment; and the communication protocol for follow-up notes.
• The protocol applicable in the event of adverse effects or complications, including the physician’s contact information, the contact information of colleagues who can be reached if the prescribing physician is unavailable, and the service corridor arrangement.
• For orders involving injectable products: a diagram or detailed description of the sites to be treated is explicitly recommended by the CMQ as a way of ensuring that the executing nurse treats only the prescribed sites and quantities.

The validity period of the order is important. An order to administer medications has a maximum validity of 24 months from signature, unless the physician specifies a shorter period. The physician should specify when reassessment is needed, and under what conditions the order expires.

The Patient’s Freedom to Choose Their Executor

The Code de déontologie des médecins recognizes the patient’s right to choose who provides their care and where. When a physician writes an individual order for treatment, the patient generally has the right to have that order executed by the qualified professional of their choice.

However, when the physician writes an order to initiate or adjust treatment, the physician may specify which nurse or group of nurses is authorized to execute it. This is not a restriction on patient freedom but a practical mechanism: the CMQ has recognized that physicians writing remote orders need to know who will execute them to satisfy their on-site availability and service corridor obligations.

In practice, specifying the executing nurse in the order is important: it allows the physician to verify the nurse’s training, insurance, and compliance conditions; it ensures the treatment occurs in a location where the physician can satisfy the 15-minute availability rule; and it provides a clear record of who was authorized to act.

The 15-Minute Physician-Availability Requirement: What It Actually Means

One of the most operationally significant requirements in Quebec aesthetic medicine concerns access to a competent physician after an injection.

The CMQ’s 2023 clarification describes the requirement as accessibility and availability sur place, meaning with the patient, within 15 minutes after an injection. Services must be organized so the prescribing physician or another responsible physician at the clinic can attend the patient, assess a complication, and administer urgent treatment, including an antidote when required.

The requirement is not satisfied by telephone or video availability alone when no competent physician can physically be with the patient within 15 minutes. At the same time, the CMQ’s public wording does not state that the physician must already remain inside the treatment room or clinic building throughout every physician-ordered injection session. The practice model must make physical attendance within 15 minutes realistic and reliable.

The practical question is therefore not simply whether a physician is nominally affiliated with the clinic. It is whether a named, competent physician can actually be with this patient, at this treatment location, within the required time.

This requirement has geographic and scheduling consequences. A physician cannot cover simultaneous sessions at locations that make attendance within 15 minutes impossible. Clinics should document the responsible physician, communication process, expected response, urgent-treatment access, and escalation pathway for every injection session.

The clinical reason is straightforward. Some complications from aesthetic injections are time-sensitive. Suspected vascular compromise, anaphylaxis, and other serious reactions require rapid assessment and treatment. The urgent medication and supplies appropriate to the services offered must be immediately available.

The clinic must also maintain a pre-established and functional service corridor to a physician with the expertise required to manage the complication when the prescribing or replacement physician cannot resolve it. Relevant information about the product, treatment, antidote, timing, prescriber, injector, and active contact methods must accompany a transfer.

Physicians should review every proposed collaboration, clinic location, and session schedule against the actual travel time and response process. A remote or nominal medical-director arrangement does not satisfy the requirement when no competent physician can physically attend the patient within 15 minutes.

A physician collaborating with nurse injectors may work across more than one location only when each session is organized so the requirement can be met at the relevant location. The number of clinics, nurses, or concurrent sessions cannot override the physician’s individual clinical and deontological obligations.

When hyaluronic acid dermal filler is administered, hyaluronidase and the supplies required for urgent response must be present, unexpired, and immediately accessible. Emergency equipment and a functional transfer process must also reflect the procedures offered by the clinic.

Commissions, Ristournes, and the Prohibition on Revenue-Sharing

The Code de déontologie des médecins (art. 73) prohibits physicians from seeking or obtaining a financial advantage through the ordering of apparatus, examinations, or medications, except for their professional fees. This prohibition applies directly, indirectly, and through a company the physician controls or in which they participate.

In the context of aesthetic medicine, this rule has produced specific guidance from the CMQ’s Bureau du syndic that physicians in this field need to understand clearly.

A physician may charge professional fees for medical activities they personally performed: the patient evaluation, the diagnosis, the treatment plan, the writing of the individual order, the administration of injections they perform themselves, and the follow-up consultation. These are the legitimate revenues of a physician in aesthetic medicine.

A physician may not: receive a percentage of the revenues generated by nurses who administer injections under the physician’s orders; accept a rent arrangement at an aesthetic clinic where the rent is tied to the number of orders written or patients evaluated; receive commissions from pharmaceutical suppliers in connection with the products used in ordered treatments; allow nurses or clinic operators to purchase injectable products using the physician’s credentials and accounts; or offer free treatments to social media influencers or others in exchange for publicity visibility.

The 2017 disciplinary decision in Médecins c. Bergeron made these prohibitions concrete. A physician who had accepted commissions calculated on the basis of injection volumes performed by nurses under a collective order, and who had arranged for nurses to purchase injectable products using pharmaceutical accounts opened in the physician’s name, was found guilty of serious deontological violations and received a suspension. The CMQ’s Bureau du syndic has since reinforced that this case represents a clear application of the existing deontological rules.

The principle is simple: a physician may not monetize their prescribing authority beyond fees for services personally rendered. Arrangements that generate revenue for the physician based on clinical volumes they do not personally create, using their professional title as an instrument for commercial gain, violate the independence and disinterestedness that the Code de déontologie requires.

This rule affects a range of business arrangements that are common in aesthetic medicine clinics. Physicians reviewing any commercial structure involving aesthetic medicine revenues should ask, for each revenue stream: Is this compensation for a medical service I personally performed? If the answer is no, the arrangement may be problematic and should be reviewed with legal counsel.

Record Keeping: The Updated 10-Year Retention Rule and What It Requires

Effective July 11, 2024, the Règlement sur les dossiers cliniques, les lieux d’exercice et la cessation d’exercice d’un médecin increased the general minimum retention period for clinical records and registers from five years to ten years, calculated from the last entry or insertion.

A transitional rule continues to apply to records or portions of records that were on paper on July 11, 2024. Those paper records generally retain a five-year minimum, subject to the regulation’s requirements for transferring certain documents to the technological portion of the file. Physicians should confirm the applicable transition rule for their existing records.

Beginning January 1, 2027, new entries for physicians practising outside an institution must generally be maintained on a technological medium certified by the MSSS. Physicians practising solo who have accumulated more than 35 years of practice have until January 1, 2030. Existing paper records do not all need to be retroactively digitized.

What the Clinical File in Aesthetic Medicine Must Contain

The physician’s clinical file for aesthetic medicine patients must include:

• Patient identification information: name, sex, date of birth, and contact information.
• The date and substance of each consultation or inscription to the file.
• Information on allergy and adverse reaction risk.
• The history and examination notes from each patient encounter.
• Any complication or accident information related to care provided.
• The diagnosis and, where the physician will perform the treatment directly, the personalized treatment plan.
• All orders written, including aesthetic injection orders, with the complete content required under the prescribing regulation.
• Consent documentation: this must be present in the file in writing. In aesthetic medicine, where consent must be written and must cover all possible risks including rare ones, the consent form or the physician’s detailed note documenting the consent discussion is essential.
• Notes on the treatment performed, including what was administered, where, and in what quantities.
• Follow-up notes, including the physician’s assessment of treatment results and any complications.
• All communications with the patient or with other professionals.

The clinical file must remain complete and immutable. Inscriptions cannot be deleted, modified, or redacted after the fact. If a correction is needed, the physician must add a supplementary note dated the day it was made.

The Required Registers

The current regulation identifies nine registers that physicians must maintain when the related activities apply:

• patient register;
• interventions register;
• anatomopathology submissions register;
• incidents and accidents register;
• independent medical evaluations and expert assessments register;
• research-subject register;
• narcotics, controlled drugs, and targeted substances register;
• collective-orders register; and
• equipment-maintenance register.

Not every register will apply to every aesthetic medicine practice. The patient, incidents and accidents, and equipment-maintenance registers are commonly relevant. The interventions register excludes injections and medication infiltrations, but may apply to other procedures that meet its definition. A controlled-substances register becomes relevant when the physician or clinic stores applicable substances.

The physician should review the current CMQ register guidance against the actual services offered at each practice location. Registers must be maintained in every relevant setting and retained according to the current regulation.

Consent Documentation

In aesthetic medicine, the consent process has heightened standards. Because aesthetic procedures are not required by the patient’s health state (they are elective), the patient must be informed of all possible risks, even those that are rare, and the consent must be written.

A consent form in aesthetic medicine must cover: the specific procedure and technique proposed; the products to be used; the expected results; the possible adverse effects and their duration; the risks, including rare and serious ones, including the risk of necrosis, permanent scarring, and in extreme cases, death; the consequences of not treating; the alternatives; the fact that the treatment carries no guarantee of result; the physician’s obligations for touch-ups or revision if applicable; and the cost.

The physician must also ensure that the patient has understood the information provided, not merely signed a form. This obligation is personal: the physician must obtain consent themselves. This act cannot be delegated to clinic staff, a nurse, or an administrative coordinator.

Working in a Clinic You Do Not Own: Obligations That Do Not Diminish

Many physicians practising aesthetic medicine do so at clinics they do not own, under arrangements with a clinic operator or management company. The Code de déontologie is clear that the physician’s professional obligations are not reduced by these arrangements.

A physician who is an employee of a clinic, a contractor at a clinic, or a service provider to a clinic remains fully and personally responsible for the clinical quality of their practice. They cannot defend a deontological complaint by saying they were following the clinic’s procedures.

Specific requirements when practising at a location you do not own:

• Written agreement: the physician should have a written rental, employment, or service agreement that preserves professional independence. Compensation or rent tied to the number of orders, patients, or procedures may create a prohibited commission, rebate, or conflict-of-interest arrangement and should be reviewed before implementation.
• Clinical records and access: clinical records must remain distinct from the clinic’s commercial records. Access must be limited to people who are authorized and have a legitimate care or operational need under the applicable professional and privacy framework. Records must not be opened to commercial, marketing, or sales use.
• The physician must not use the clinic’s advertising to make claims that violate the Code de déontologie on advertising. The physician remains responsible for all advertising about their services, even if produced by the clinic. A physician cannot avoid responsibility for misleading advertising by saying the clinic produced it.
• The physician must not lend their professional title, permit number, or name to commercial purposes that they do not personally control. Specifically, a physician cannot allow a clinic to use their name in advertising in a way that implies a medical endorsement they have not given, or to use their account to purchase products for use by others.
• When a physician leaves or is unable to continue their relationship with a clinic, they must ensure that patients can continue to receive the care they have started, either from the physician at another location, or from another qualified professional. This continuity obligation has a limited scope in elective aesthetic care but should not be ignored.

Advertising: What Physicians May and May Not Say

Advertising by physicians in aesthetic medicine is governed by the Code de déontologie des médecins (arts. 88-93.3) and by the CMQ’s guide on physician advertising. The CMQ has also issued specific guidance on advertising in the aesthetic medicine context, noting that this field is particularly susceptible to advertising that “vend du rêve” and creates unrealistic expectations.

The core requirements:

• Advertising must be factual, precise, and verifiable. A physician cannot make clinical claims that cannot be supported, promises of outcomes that cannot be guaranteed, or comparisons with colleagues that could damage their reputation.
• A physician may not present themselves as a “specialist in aesthetic medicine” or an “expert in aesthetic medicine” in any way that implies formal recognition of a specialty by the CMQ. Aesthetic medicine is not a recognized specialty in Quebec. The correct presentation is the physician’s recognized specialty (or specialties), followed by a statement that they provide aesthetic medicine services. For example: “Dr. X, family medicine physician, providing aesthetic medicine services.”
• Before-and-after photographs are not prohibited but carry specific requirements. They must not be presented as a guarantee of typical outcomes. If published, they require explicit written consent from the patient, specifying that the photographs will be used in advertising. The photos themselves must be accompanied by a disclaimer that they represent one individual outcome and do not constitute a promise of results.
• Testimonials from patients are subject to strict limitations. The Code de déontologie prohibits testimonials that are misleading, that create false hopes, or that could constitute an insistent solicitation. The CMQ has identified “influencer marketing” specifically: providing free aesthetic treatments to bloggers, vloggers, or social media influencers in exchange for visibility constitutes a material advantage for an endorsement, which the Bureau du syndic has found to violate the Code. This applies to all social media platforms.
• Physicians who work at aesthetic clinics that produce their own advertising must ensure that all advertising about their services complies with the Code de déontologie. The physician cannot hide behind the clinic’s status as a non-medical business entity. If the advertising promotes the physician’s services, the physician is responsible for its compliance regardless of who produced it.
• Price advertising is permitted in aesthetic medicine, but when a physician publishes prices, the Code requires that the published price be accurate, that any applicable restrictions be disclosed, and that additional fees that may be required be mentioned. A physician may not advertise a price that is conditional on conditions the patient cannot reasonably anticipate from the advertisement.

The Physician as Medical Director and Responsible Physician

Aesthetic clinics may use titles such as responsible physician or medical director. The CMQ’s public guidance makes clear that the role must involve real responsibility for the quality and safety of care, not a nominal affiliation used for commercial positioning.

A responsible physician should have regular aesthetic medicine practice and must help ensure that complication-management mechanisms, urgent treatment, team procedures, and appropriate service corridors are in place and understood.

The responsible physician role does not replace the obligations of each prescribing physician. A physician who evaluates a patient, establishes the plan, or writes an order remains responsible for that work and the required follow-up. The clinic must also be organized so a competent physician can physically attend the patient within 15 minutes after an injection.

A physician should not lend their name, title, permit number, or affiliation to a clinic that they do not meaningfully oversee. Any medical-director arrangement should define clinical authority, quality and safety responsibilities, record access, emergency coverage, advertising review, and the limits of the role in writing.

Fees, Billing, and What Can Legitimately Be Charged

The Code de déontologie des médecins establishes clear rules for physician fees in aesthetic medicine. Because aesthetic medicine is outside the Quebec public health insurance system, patients pay directly for services. The physician is not subject to the RAMQ billing rules, but remains subject to the deontological rules on fees.

Legitimate fees for a physician in aesthetic medicine include:

• Fees for the medical evaluation (consultation).
• Fees for additional assessments or diagnostics, if required.
• Fees for treatments the physician personally administers.
• Fees for follow-up consultations.
• Fees for writing orders (though these must represent actual medical work performed, not a flat per-order fee detached from clinical work).

The physician must provide a detailed invoice to the patient that identifies separately the services rendered, the products or devices used and their cost, and any other charges. The invoice cannot aggregate everything into a single undifferentiated amount.

Prices must be posted in the waiting room of the clinic where the physician practises. This is a Code de déontologie requirement (art. 105), not merely a consumer protection measure.

A physician may request an advance deposit for aesthetic treatments, which are outside the public insurance system. The deposit must be reasonable in relation to the services to be provided.

The physician must provide a receipt for all payments received.

Privacy: Patient Data in Aesthetic Medicine Under Quebec Law

Aesthetic medicine clinics handle sensitive health information. Quebec physicians must comply with professional secrecy, the current Quebec framework governing health and social-services information, and the private-sector privacy obligations that apply to the clinic or organization.

For physicians practising at aesthetic medicine clinics, the relevant privacy obligations include:

• Patient photographs taken as part of clinical assessment or to document treatment results must have explicit written consent that specifies exactly what the photographs will be used for. Consent to photography for clinical records does not authorize use in advertising, social media, or staff training materials. Separate, specific consent is required for each non-clinical use.
• Access controls: patient information must be stored on secure systems. Access should be limited to authorized people who need the information for care or a legitimate clinical or administrative function. Administrative access should be limited to what is necessary and should never extend to unrelated marketing or sales use.
• If a clinic uses an external software platform to manage patient records, the physician should ensure the platform’s data storage, access controls, and transfer policies comply with Quebec privacy law.
• If the physician is practising at a clinic they do not own, they must ensure that the clinic cannot access patient medical records for commercial purposes (marketing, sales analysis, referral to third-party service providers without consent).
• A privacy incident involving patient health data at a clinic where the physician practises has implications for the physician personally. The Code de déontologie’s obligation to maintain the confidentiality of patient information applies throughout.
  

Products, Devices, and the Physician’s Purchasing Obligations

A physician in aesthetic medicine has specific obligations about how injectable products and devices are obtained, stored, and used.

Regarding injectable products: a physician who personally administers injectables may purchase them directly from a supplier or through a pharmacy. The Code de déontologie prohibits a physician from selling injectable products to another health professional for that professional’s independent use, or from allowing others to purchase products using the physician’s account. This is directly connected to the prohibition on commissions: allowing a nurse to purchase botulinum toxin A or fillers using the physician’s pharmaceutical account creates an arrangement where the physician effectively provides commercial purchasing authority in exchange for a volume-dependent benefit.

A physician may supply the injectable products prescribed in an individual order to the nurse who will execute the order at the physician’s own office. This is a permitted exception: the products remain under the physician’s control, and the use occurs in the physician’s own practice setting.

Regarding devices and equipment: the physician must ensure that all devices, instruments, and equipment used in aesthetic medicine are appropriate for the procedures being performed, properly maintained and calibrated, and used in a way that meets infection control standards. Staff who operate laser or energy-based devices must have received adequate specific training on those devices.

The clinic must maintain documentation of equipment maintenance, calibration, and sterilization procedures. This documentation may be reviewed during a CMQ inspection.

Professional Opportunities in Quebec Aesthetic Medicine

The regulatory framework is not a promise of commercial success. It defines the conditions for professional, safe, and defensible practice. Within those conditions, aesthetic medicine may offer physicians an additional clinical domain, a private-practice model, and opportunities for interprofessional collaboration.

Patient interest, local access, competition, referral patterns, and practice viability vary by region. A physician considering Montreal, Saint-Sauveur, or another Quebec community should assess local demand, existing services, clinic infrastructure, insurance, prescriber and injector relationships, and the ability to meet CMQ requirements before committing to a business model.

A physician who completes the applicable CMQ-directed pathway may collaborate with trained nurses when every patient-specific evaluation, order, competence, follow-up, physician-availability, and emergency-readiness requirement is met. The model should be designed around safe care rather than the number of nurses or treatment sessions it can support.

The ODQ’s 2025 framework also permits appropriately trained dentists to evaluate, plan, prescribe, and collaborate with nurses for treatments within the dentist’s authorized scope. Physicians continue to manage patients, diagnoses, complications, and treatments that require medical expertise or fall outside the dental framework.

Knowledge developed through aesthetic medicine education may overlap with therapeutic uses of botulinum toxin A and other modalities. Therapeutic indications, product authorization, public or private coverage, competence, and prescribing requirements must be assessed separately. Aesthetic training does not automatically authorize or establish competence for every therapeutic application.

Greater regulatory clarity can favour physicians who maintain strong clinical systems, accurate documentation, appropriate collaboration, and conservative public communication. The defensible advantage is professional quality and compliance, not a guaranteed patient volume, income, or competitive position.

The 2026 Inter-Order Framework: What Physicians Should Expect

In November 2025, the CMQ, ODQ, OIIQ, and OIIAQ announced a joint initiative to define common parameters for medical-aesthetic care. The CMQ stated that the work was expected to be completed during 2026. As of July 22, 2026, the completed framework was not identified on the CMQ’s public aesthetic medicine page.

The initiative is intended to clarify remaining areas of uncertainty and improve consistency across the professions. Possible subjects include:

• professional roles and interprofessional responsibilities;
• training and competence expectations;
• patient-safety and complication-management systems;
• documentation and communication in collaborative models; and
• the organization of medical-aesthetic services across clinic types.

The four orders have not publicly confirmed every final subject or outcome. Physicians should therefore avoid predicting that the framework will either relax or materially expand current professional authority.

Until a completed framework is published, existing CMQ guidance, regulations, professional-order requirements, and individual professional responsibility remain in effect.

Physicians should monitor the official CMQ, OIIQ, OIIAQ, and ODQ publications and reassess their practice model when new common parameters are released.

Training That Prepares Physicians for Compliant Practice

The CMQ’s training requirements for physicians entering aesthetic medicine are specific: theoretical foundation covering the full scope of aesthetic medicine, and practical training under a CMQ-accepted maître de stage for a minimum of four days with a minimum of five patients.

Physicians should submit the practice-change notification and obtain the CMQ’s direction before enrolling in or paying for a program. The physician can then provide the CMQ with the proposed curriculum, instructor credentials, practical format, patient exposure, follow-up structure, and reporting process. This sequence reduces the risk of completing an expensive program that the CMQ later determines does not satisfy the physician-specific requirements.

AMEQ Academy offers physician education in aesthetic medicine in Montreal and Saint-Sauveur, Quebec, led by Dr. Angelina Guzzo, BSc, PhD, MDCM, FRCPC, Specialist in Anesthesia and aesthetic medicine educator since 2014. Programs address facial anatomy, product pharmacology, patient assessment, injection technique, complication management, and the Quebec regulatory framework. When the CMQ identifies or accepts Dr. Guzzo as the maître de stage for a physician’s file, AMEQ can provide the corresponding theoretical and supervised practical components within the parameters established by the CMQ. Prospective participants should obtain that physician-specific confirmation in writing before registering or paying.

Completing an AMEQ Academy physician program, or any other private program, does not automatically satisfy the CMQ’s formal perfectionnement stage requirements, does not constitute CMQ authorization to practise, and does not replace the CMQ notification and assessment process. Physicians should not rely on a training provider’s statement that a course is accredited, approved, or guaranteed to be accepted unless the CMQ has confirmed the physician-specific pathway in writing.

To discuss physician training options, contact AMEQ Academy at education@cliniqueag.ca or call (514) 574-4636.

Practical Checklist: Before You See Your First Aesthetic Patient

For a physician preparing to begin or formalize aesthetic medicine practice in Quebec, the following items should all be confirmed:

• Before paying for training, you submitted the notification to the CMQ and obtained written direction about whether theoretical training, a formal practical stage, or both are required for your file.
• You confirmed that the proposed theoretical program addresses the objectives identified by the CMQ for your practice-change file. You did not assume that a private certificate or provider claim created automatic CMQ recognition.
• Where a formal practical stage is required, you confirmed the supervisor, minimum duration, patient exposure, follow-up, direct supervision, and reporting requirements with the CMQ before beginning the stage.
• You have confirmed with your professional liability insurer that your current policy covers aesthetic medicine practice, including the specific procedures you intend to offer.
• You have reviewed the CMQ’s 2020 Guide d’exercice on aesthetic medicine and the November 2023 clarification in full.
• You have reviewed the May 2024 CMQ-OIIQ joint advisory.
• You understand the individual order requirements and can write a complete, compliant order.
• You understand the requirement to organize services so a competent physician can be with the patient within 15 minutes after an injection, and your practice model can satisfy it at every treatment location.
• You understand the commission prohibition and have reviewed any existing or planned business arrangements for compliance.
• You maintain clinical records and all applicable registers under the current ten-year and transitional retention rules, and you have planned for the certified technological-medium requirements beginning in 2027.
• You have a system for obtaining and storing written informed consent.
• If you work at a clinic you do not own, your written agreement preserves professional independence, your clinical records remain distinct from commercial records, and access is limited to authorized people with a legitimate need.

Frequently Asked Questions

Must a Quebec physician notify the CMQ before beginning aesthetic medicine?

A physician adding aesthetic medicine or a new aesthetic procedure should begin with the current CMQ practice-change process. The CMQ determines whether a physician-specific improvement activity is required. Physicians previously trained in the field who have not practised aesthetic medicine for three years or more must also contact the CMQ before beginning or resuming practice.

Which specialties does the CMQ identify as ordinarily trained in aesthetic medicine?

The CMQ’s public guidance identifies plastic surgery, dermatology, ophthalmology, otorhinolaryngology, and cervicofacial surgery. This does not remove the obligation to practise within competence or to contact the CMQ after a practice interruption of three years or more.

Does completing a private aesthetic medicine course authorize a physician to practise?

No. A private certificate does not independently create CMQ authorization or guarantee recognition. The CMQ evaluates the physician’s individual file, training objectives, supervisor, practical stage, patient exposure, reporting, and completion requirements when an improvement activity applies.

What training may the CMQ require for physicians entering aesthetic medicine?

The CMQ guide describes broad theoretical education and a supervised practical stage. The practical standard described in the guide includes at least four days and the treatment and follow-up of at least five patients across different anatomical regions using different products or devices. The exact pathway must be confirmed for the physician’s file.

Can the required aesthetic medicine evaluation be completed remotely?

No. The CMQ requires an in-person physician evaluation for this type of practice. Photographs, video, telephone, intake forms, or a nurse’s assessment do not replace the physician’s personal medical evaluation, diagnosis, treatment plan, consent discussion, and prescribing responsibilities.

Can a physician use a collective order for aesthetic injections?

No. Collective orders for aesthetic injections have been prohibited since 2017. When a nurse administers the treatment, the patient requires an individual order based on the physician’s in-person evaluation and individualized treatment plan.

Must the physician remain inside the clinic during every nurse injection session?

The CMQ requires services to be organized so the prescribing physician or another responsible and competent physician can be with the patient within 15 minutes after an injection. Telephone or video availability alone is insufficient when physical attendance cannot occur within that period. The operational model must make the response realistic at the actual treatment location.

Can a physician receive a percentage of a nurse injector’s treatment revenue?

Volume-based compensation, commissions, rebates, and financial benefits tied to prescriptions or services performed by others may violate the physician’s professional-independence and disinterestedness obligations. Physicians should receive compensation only for legitimate professional services and should have proposed financial arrangements reviewed before implementation.

How long must a Quebec physician keep aesthetic medicine clinical records?

The current general minimum is ten years from the last entry or insertion. Transitional rules apply to paper records that existed on July 11, 2024. Physicians must also maintain the registers applicable to their actual activities and prepare for certified technological record systems beginning in 2027.

Can a physician advertise as a specialist in aesthetic medicine?

Aesthetic medicine is not a recognized medical specialty in Quebec. Physicians should identify their recognized specialty accurately and describe that they provide aesthetic medicine services without implying a CMQ-recognized specialist title that does not exist.

Official Sources and Further Reading

• CMQ: Aesthetic medicine resource centre
• CMQ: Guide d’exercice, La médecine esthétique
• CMQ: Médecine esthétique, observations et responsabilités, November 23, 2023
• CMQ: Protection of the public in aesthetic medicine, May 30, 2024
• CMQ: Four-order collaboration on medical-aesthetic care, November 28, 2025
• CMQ: Improvement activities and practice changes
• CMQ: New clinical-record regulation
• CMQ: Required registers
• CMQ: Certified technological media for clinical records
• Légis Québec: Code de déontologie des médecins
• Légis Québec: Regulation respecting standards for prescriptions by physicians

Professional Responsibility Notice

This article provides educational information about the regulatory framework for physicians in aesthetic medicine in Quebec. It does not constitute legal advice, an official CMQ interpretation, or authorization to perform any procedure.

The information reflects official sources reviewed through July 22, 2026, including the CMQ Guide d’exercice, La médecine esthétique; the CMQ article Médecine esthétique : observations et responsabilités; the May 2024 CMQ-OIIQ advisory; the November 2025 four-order announcement; the current CMQ pages on clinical records, registers, technological media, and improvement activities; the Règlement sur les dossiers cliniques, les lieux d’exercice et la cessation d’exercice d’un médecin; the Règlement sur les normes relatives aux ordonnances faites par un médecin; and the Code de déontologie des médecins.

Regulations and professional guidance may change. Physicians must confirm their current obligations directly with the CMQ, their professional liability insurer, and qualified Quebec legal counsel before beginning or modifying an aesthetic medicine practice. Completing training at AMEQ Academy or another private provider does not independently constitute CMQ authorization, CMQ approval, or recognition of a new field of practice.

Prepared by AMEQ Academy. Reviewed and approved by Dr. Angelina Guzzo, BSc, PhD, MDCM, FRCPC, Specialist in Anesthesia and aesthetic medicine educator since 2014. Regulatory information reviewed July 22, 2026.