Who Can Inject Botox and Filler in Quebec? (Qui peut injecter du Botox au Québec?)

Quick answer: In Quebec, physicians can inject cosmetic neuromodulators (botulinum toxin, sold under brands such as Botox) and dermal fillers after individually assessing each patient. Nurses (infirmières) can inject only with an individual prescription. A physician must be available onsite within 15 minutes after injections, and collective prescriptions for aesthetic injections are no longer allowed. NAIMA trains licensed professionals in Montreal.

En bref (résumé en français) : Au Québec, le médecin évalue chaque patient individuellement, pose un diagnostic et établit un plan de traitement avant toute injection esthétique de neuromodulateurs (toxine botulique) ou d'agents de comblement. L'infirmière peut injecter selon une ordonnance individuelle. Les ordonnances collectives pour les injections à des fins esthétiques ne sont plus autorisées, et un médecin doit être accessible et disponible sur place dans les 15 minutes suivant les injections. Toutes les formations NAIMA sont offertes à Montréal. Confirmez les exigences actuelles auprès de votre ordre professionnel.

Key facts

• The Medical Act reserves invasive procedures and prescribing to physicians, subject to listed exceptions.
• Physicians must individually assess each patient, make a diagnosis and set a treatment plan with an individual prescription.
• Collective prescriptions (ordonnances collectives) for aesthetic injections are no longer authorized (joint CMQ and OIIQ notice).
• A physician must be "accessible et disponible sur place dans les 15 minutes" after injections.
• Nurses assess the client before each treatment and refer back to the physician if they find a contraindication.
• The CMQ, ODQ, OIIAQ and OIIQ have announced a joint initiative on common medico-aesthetic guidelines, so the rules may be updated.
• Scope of practice is set by your regulatory college. Confirm with your college before practising.

This article is general information for licensed professionals, not legal advice. NAIMA, the North American Institute of Medical Aesthetics, is a professional training and certification platform with more than 15,000 graduates. It trains in seven Canadian cities (Toronto, Vancouver, Calgary, Edmonton, Montreal, Kitchener and Regina), and every NAIMA course and masterclass is offered in Montreal. A NAIMA certificate is a training credential. It does not, by itself, authorize anyone to inject.

Who can inject Botox (neuromodulators) and filler in Quebec, by profession?

Physicians assess, prescribe and inject. Nurses inject on an individual prescription, with a physician available onsite. For other professions, confirm with your college. The table below shows what the sources say.

Scope of practice is set by your regulatory college. Confirm with your college before practising.

Which activities are reserved in Quebec?

Quebec law reserves invasive procedures and prescribing to physicians, with listed exceptions for other professions. Section 31 of the Medical Act (M-9) sets out the activities reserved to physicians. Section 43 says "no person may engage in any activity described in the second paragraph of section 31, unless he is a physician," subject to the exceptions listed.

Section 36 of the Nurses Act (I-8) reserves certain activities to nurses, including "administering and adjusting prescribed medications or other prescribed substances" and "providing and adjusting medical treatment, according to a prescription." That is the legal basis for nurse injection in Quebec: the nurse acts on a prescription.

What do Quebec nurses need to inject Botox or filler?

Nurses need an individual prescription, and a physician must be available nearby. The joint notice from the Collège des médecins du Québec (CMQ) and the Ordre des infirmières et infirmiers du Québec (OIIQ) sets five requirements:

• No collective prescriptions: "les ordonnances collectives autorisant les infirmières à réaliser des injections à des fins esthétiques ne sont plus autorisées."
• Individual physician assessment: the physician must "évaluer avec soin chacun de ses patientes et patients," make a diagnosis and set a treatment plan with an individual prescription.
• Physician availability: the prescribing physician, or another responsible physician, must be "accessible et disponible sur place dans les 15 minutes suivant une procédure d'injections."
• Nurse assessment: the nurse assesses the client before each treatment and refers back to the physician if a contraindication appears.
• Plan changes: the nurse adjusts the treatment plan only where a protocol allows it.

The individual prescription requirement for nurse-injected Botox has applied in Quebec since 2017, as reported by Global News. The joint CMQ and OIIQ press release adds that anyone seeking medico-aesthetic care "doit au préalable avoir eu une évaluation individuelle." The sources reviewed do not say whether that assessment can be done by telemedicine, so confirm this with the CMQ.

Are Quebec's aesthetic injection rules changing?

They may be. In a joint announcement, four professional orders said they would set common guidelines for medico-aesthetic care. The four are the CMQ, the Ordre des dentistes du Québec (ODQ), the Ordre des infirmières et infirmiers auxiliaires du Québec (OIIAQ) and the OIIQ. Check each order's site for the current guidance before you set up or change your practice. The guidance may clarify the scope of dentists and nursing assistants.

Can estheticians inject Botox or filler in Quebec?

No. Injection and prescribing are reserved activities under the Medical Act and the Nurses Act, and estheticians are not among the authorized professionals. We found no Quebec primary source that addresses estheticians and injections directly.

You may see a Court of Appeal decision cited as support for esthetician injections. That case involved an esthetician and laser tattoo removal, not injections. Don't treat it as authority for estheticians performing any injectable treatment.

What federal rules apply in Quebec?

The federal layer is the same as in the rest of Canada:

• Botulinum toxin is a prescription drug. This covers neuromodulator products such as Botox, Dysport and Xeomin. It appears on Health Canada's Prescription Drug List. Health Canada has also advised consumers to check the product label for a Drug Identification Number (DIN).
• Dermal fillers are medical devices. Under Health Canada guidance, fillers without animal or human tissue are Class III devices, and fillers that contain such tissue are Class IV. They are not federal prescription drugs, but Quebec's framework still requires a physician's assessment and an individual prescription for nurse injection.
• Advertising is restricted. Food and Drug Regulations section C.01.044 limits public advertising of a prescription drug to its brand name, proper name, common name, price and quantity.

What are Quebec's advertising rules for injectors?

The federal C.01.044 restriction applies in Quebec. We could not confirm the Quebec-specific rules on testimonials and before-and-after photos for physicians and nurses in the primary sources reviewed. Check the Code of ethics of physicians and the OIIQ's guidance before you publish testimonials or promotional content. Using generic terms such as "neuromodulator" or "botulinum toxin type A" in educational content is a safer approach.

What about PRP in Quebec?

The sources reviewed do not set out Quebec rules for aesthetic PRP or the blood draw it requires. Confirm with your college (the CMQ or OIIQ) before you offer PRP. For training, see PRP Training in Montreal.

What this means if you're training at NAIMA in Montreal

NAIMA's eligibility rule fits Quebec's framework. Its FAQ says licensed medical practitioners can enrol, including physicians, surgeons, NPs, RNs, LPNs, RPNs and internationally trained medical graduates.

NAIMA's Montreal training draws professionals from Laval, Longueuil and Greater Montreal. Some travel in from Gatineau and Ottawa.

• Venue: GLIF Medical, 14 Place du Commerce, Suite 430, Verdun, QC H3E 1T5, is a training venue NAIMA uses in Montreal. Your Admissions call confirms the venue for your session.
• Montreal programs: every NAIMA course and masterclass is offered in Montreal, including the Neuromodulators and Dermal Filler certifications and masterclasses such as PRP Hair & Face, Penile Enhancement & Hormonal Therapy and Joint PRP Injectables.
• Dates: sessions run regularly. Book a call with Admissions to choose your dates.
• Language: NAIMA course pages list English as the language of instruction. Confirm language options with admissions.

For Quebec nurses, the practical point is that training builds competence, but each client still needs a physician's individual assessment and prescription. A physician must also be available onsite within 15 minutes.

Related posts:

• Medical Aesthetics Training in Montreal
• Botox Training in Montreal (Formation Botox)
• Dermal Filler Training in Montreal

Course details and tuition:

• The Neuromodulators Certification is a 2-day course with a minimum of 13 supervised procedures on live models. Tuition is CAD $2,500. Tuition is subject to change; confirm with admissions.
• The Dermal Filler Certification is a 2-day course. Tuition is CAD $4,500.
• The PRP Hair & Face Masterclass is a 1-day course. Tuition is CAD $2,000.

See current options at naimaed.ca/courses?city=Montreal.

About the faculty

These NAIMA faculty are connected to Montreal and Eastern Canada:

• Dr. Peguy Telusma: Family & Aesthetic Medicine Physician and PRP Instructor. Teaches the PRP Hair & Face Masterclass in Montreal.
• Dr. Jimmy Kwok: Clinical Assistant Professor and Masterclass Instructor. Leads the men's health and joint PRP masterclasses.
• Dr. Shadi Amin Ranjbar: Program Coordinator, Eastern Canada.
• Maneesha Fraser: Head of NAIMA & Lead Aesthetics Trainer.

Frequently asked questions

Can nurses inject Botox in Quebec? (Une infirmière peut-elle injecter du Botox au Québec?)

Yes, with an individual prescription. According to the joint CMQ and OIIQ notice, a physician must first individually assess the patient and set a treatment plan. The prescribing physician or another responsible physician must be accessible and available onsite within 15 minutes after injections.

Are collective prescriptions allowed for Botox in Quebec? (Ordonnance collective pour le Botox?)

No. The CMQ and OIIQ state that collective prescriptions authorizing nurses to perform injections for aesthetic purposes are no longer authorized. Each client needs an individual prescription.

Does a patient need to see a physician before Botox in Quebec?

Yes. The CMQ and OIIQ say anyone seeking medico-aesthetic care must first have an individual assessment, and the physician must diagnose and set a treatment plan. The sources reviewed do not say whether this can be done virtually, so confirm this with the CMQ.

Can estheticians inject Botox in Quebec? (Une esthéticienne peut-elle injecter du Botox?)

No. Injection and prescribing are reserved activities under Quebec's Medical Act and Nurses Act, and estheticians are not authorized professionals. A Court of Appeal case about an esthetician concerned laser tattoo removal, not injections.

Can dentists or nursing assistants inject Botox for cosmetic purposes in Quebec?

Confirm with your college. The ODQ and OIIAQ are part of a joint initiative on medico-aesthetic guidelines with the CMQ and OIIQ, so check with your order for current requirements.

Is NAIMA training in Montreal taught in French? (La formation est-elle offerte en français?)

NAIMA course pages list English as the language of instruction. Contact admissions to confirm the language options for a specific course.

Next steps

Review the Neuromodulators Certification, the Dermal Filler Certification and the PRP Hair & Face Masterclass. Then Book a call with Admissions to choose your Montreal dates. You can also call 416.623.8424 or email education@naimaed.ca. To compare rules in other provinces, read our guides for Ontario, British Columbia and Alberta.

Scope of practice is set by your regulatory college. Confirm with your college before practising.