Providing Services to Clients in Ontario

Purpose

This advisory provides guidance to members of the Association of Cooperative Counselling Therapists of Canada (ACCT) regarding the provision of services to clients who are physically located in Ontario.

Members are responsible for ensuring their practice complies with all applicable laws and regulations in the jurisdiction where the client resides.

Regulatory Context in Ontario

In Ontario, the controlled act of psychotherapy is regulated by the
College of Registered Psychotherapists of Ontario (CRPO).

Under Ontario law:

• The controlled act of psychotherapy may only be performed by authorized professionals (e.g., CRPO registrants or other regulated health professionals permitted to perform the act).

• Jurisdiction is determined by the location of the client, not the practitioner.

Implication:
If a client is physically located in Ontario at the time of service, Ontario law applies—even if the ACCT member is located in another province.

Member Responsibility

ACCT members must understand and comply with Ontario’s legal and regulatory framework when working with Ontario-based clients.

• Compliance is the sole responsibility of the member.

• ACCT does not provide legal advice on interjurisdictional practice.

• ACCT cannot advocate on behalf of members who are subject to investigation or enforcement by Ontario regulators or authorities.

Permitted Activities (Lower Risk)

ACCT members who are not registered with CRPO may:

• Provide non-psychotherapy services, including:

• Coaching

• Psychoeducation

• General wellness support

• Non-clinical counselling that does not meet the definition of psychotherapy

• Accept Ontario clients who independently seek their services, provided that:

• No targeted marketing to Ontario residents has occurred

• The services provided do not constitute the controlled act of psychotherapy

Prohibited or Restricted Activities

ACCT members who are not authorized to practise psychotherapy in Ontario must not:

1. Perform the Controlled Act of Psychotherapy

This includes, but is not limited to:

• Treating mental health disorders (e.g., depression, anxiety, trauma)

• Using structured psychotherapy modalities (e.g., CBT, EMDR, trauma processing)

• Engaging in interventions that significantly affect a client’s:

• Thoughts (cognition)

• Emotional regulation

• Behaviour patterns

If the service meets the definition of psychotherapy, the member must be registered with CRPO (or another authorized Ontario regulatory college).

2. Represent Themselves as Authorized to Practise in Ontario

Members must not:

• Use protected titles (e.g., “psychotherapist”) in Ontario unless authorized

• Suggest or imply equivalency to Ontario-regulated professionals

• Misrepresent their scope of practice or regulatory status

3. Actively Market or Solicit Ontario Clients for Psychotherapy Services

Members must not:

• Target Ontario residents through advertising, SEO, or outreach

• Promote psychotherapy services specifically to Ontario clients

• Establish a clear intention to practise psychotherapy in Ontario without authorization

4. Mischaracterize Services to Avoid Regulation

Describing services as:

• “Coaching”

• “Counselling”

• “Support”

…does not exempt a member from regulation if the actual services provided meet the definition of psychotherapy.

Regulatory bodies assess the nature of the service, not the label used.

Risk Awareness

Members should be aware of the following:

• Accepting an Ontario client does not automatically make the service permissible

• “Passive” client engagement does not override legal restrictions

• The risk level increases significantly when:

• Clinical issues are addressed

• Therapeutic techniques are applied

• The client presents with mental health conditions

Potential Consequences of Non-Compliance

Failure to comply with Ontario law may result in serious consequences, including:

Regulatory and Legal Consequences

• Investigation by the College of Registered Psychotherapists of Ontario or other Ontario authorities

• Orders to cease and desist providing services

• Monetary penalties or fines (where applicable)

• Potential legal action for unauthorized practice of a controlled act

Professional Consequences

• Complaints filed with ACCT

• Possible findings of professional misconduct

• Disciplinary action by ACCT, including:

• Conditions on membership

• Suspension or revocation of designation

• Publication of disciplinary outcomes

Reputational and Civil Liability Risks

• Damage to professional reputation

• Exposure to civil claims (e.g., negligence, misrepresentation)

• Lack of insurance coverage if practising outside permitted scope

Recommended Best Practices

ACCT recommends that members:

• Clearly disclose:

• Their jurisdiction of practice

• That they are not registered to practise psychotherapy in Ontario (if applicable)

• Use accurate, non-clinical language when appropriate

• Maintain clear boundaries regarding scope of service

• Seek independent legal advice if uncertain about interprovincial practice

• Consult their professional liability insurer regarding coverage limitations

ACCT Position

ACCT supports ethical, lawful, and transparent practice across jurisdictions.

However:

• ACCT does not regulate practice in Ontario

• ACCT does not intervene in matters involving Ontario regulatory authorities

• ACCT will not advocate on behalf of members who are found to be in breach of Ontario laws

Summary

An ACCT member who is not registered with CRPO:

May:

• Provide non-psychotherapy services to Ontario clients under limited circumstances

Must Not:

• Provide psychotherapy to Ontario clients

• Represent themselves as authorized in Ontario

• Market psychotherapy services into Ontario

Is Fully Responsible:

• For understanding and complying with Ontario law