In Ontario, the controlled act of psychotherapy is a legally restricted health activity: treating a serious mental health disorder through psychotherapy technique within a therapeutic relationship. Only members of certain regulated colleges, or people working under their supervision, may do it. If you are choosing a therapist, the rule exists to protect you. If you are a practitioner, it defines where your scope of practice carries legal weight.
The wording sounds forbidding, and it is easy to misread. It does not mean that every conversation about your feelings is a regulated procedure. This guide explains what the act covers, who may perform it, what sits outside it, and what to ask before you begin therapy.
TL;DR
- The controlled act of psychotherapy is one of 14 controlled acts in Ontario's Regulated Health Professions Act, 1991, and it covers only the treatment of serious disorders using psychotherapy technique through a therapeutic relationship.
- Members of six Ontario colleges (psychotherapists, nurses, occupational therapists, physicians, psychologists and psychological associates, and social workers and social service workers) may perform it, as may supervised students and trainees who meet specific conditions.
- Counselling and support, crisis intervention, intake and referral, and spiritual guidance are among the activities that fall outside the act.
- The titles "psychotherapist" and "Registered Psychotherapist" are protected separately, so you can ask any provider for their college and registration number.
- The rules follow the client: a practitioner outside Ontario who treats an Ontario client online is still within their reach.
What is a controlled act, and where does psychotherapy fit?
Ontario's Regulated Health Professions Act lists 14 controlled acts and restricts performing them in the course of providing health care to authorized members or to people to whom an authorized member has delegated the act. Psychotherapy is the 14th on that list. Other examples include setting a fracture or performing surgery, which tells you the level of risk the legislature had in mind.
The logic is simple. The framework restricts inherently risky activities to professionals who are qualified, regulated and accountable to a college. If something goes wrong, you have a body to complain to, standards that practitioners must meet, and a public register to consult.
It helps to think of it like first aid versus a surgical procedure. Many people can offer comfort and practical help, and that is valuable. A small group of interventions carries enough potential for harm that the law reserves them for people with verified training and oversight.
When the restriction took effect
Ontario created the College of Registered Psychotherapists (CRPO) and protected the titles in 2015. The restriction on performing the controlled act itself followed later: it was proclaimed in force on December 30, 2017. That is why you may hear that psychotherapy has been "regulated" since 2015 by some people and since 2017 by others. Both are right, because title and act were brought in separately.
How the law defines the controlled act of psychotherapy
The definition, as the CRPO sets it out, is treating an individual's serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair judgement, insight, behaviour, communication or social functioning. The treatment must use psychotherapy technique and be delivered through a therapeutic relationship.
An activity belongs to the controlled act only when all five elements are present at once:
- There is treatment (not simply education or information).
- The treatment uses psychotherapy technique.
- It is delivered through a therapeutic relationship.
- It addresses a serious disorder of thought, cognition, mood, emotional regulation, perception or memory.
- That disorder may seriously impair the person's functioning.
Remove any one element and the activity is no longer the controlled act. This is the point most often missed. A conversation about stress after a hard year, or coaching on communication habits, may not meet the fourth and fifth elements. Treating severe depression with a structured therapeutic approach probably does.
The practical consequence is that the line is drawn by what is being done and for whom, not by the job title on a business card or the room where it happens.
Who can perform the controlled act in Ontario
Authorized professionals are registrants of the colleges for psychotherapists, nurses, occupational therapists, physicians, psychologists or psychological associates, and social workers or social service workers. That is six colleges in all. Each regulates its own members, and each member must also be competent to do the work in question.
| Profession | Regulator | Notes |
|---|---|---|
| Registered Psychotherapist | College of Registered Psychotherapists of Ontario | Psychotherapy is the core of the scope of practice |
| Psychologist or psychological associate | College of Psychologists and Behaviour Analysts of Ontario | Often includes assessment and diagnosis |
| Physician, including psychiatrists | College of Physicians and Surgeons of Ontario | Can combine psychotherapy with medical care |
| Registered nurse or nurse practitioner | College of Nurses of Ontario | Authorized where competent |
| Occupational therapist | College of Occupational Therapists of Ontario | Must have the knowledge, skill and judgment to do it safely |
| Social worker or social service worker | Ontario College of Social Workers and Social Service Workers | Subject to that college's practice guidance |
Authorization is not a blank cheque. Registrants are ethically and professionally required to decline the act if it is beyond their individual competence or if it would be counter-therapeutic for the client. An occupational therapist, for example, must have the knowledge, skill and judgment to perform it safely, decide whether the person's condition warrants it, and weigh the known risks and benefits, as the regulation spells out.
That is worth knowing as a client. A good clinician will tell you when your needs call for someone else, such as a psychiatrist for medication questions or a specialist for a particular kind of trauma.
Supervised students and trainees
People still training are not shut out. Students in recognized psychotherapy education programs may perform the controlled act while supervised by a CRPO registrant who is qualified to provide clinical supervision. People who meet CRPO registration requirements may likewise perform it under a qualified Registered Psychotherapist's clinical supervision, according to the CRPO's guidance.
Accountability stays with the supervisor. The CRPO's clinical supervision guide makes the point that even a supervised student must deliver the same standard of safe, ethical care.
Other exceptions
The RHPA also carves out a few situations from the restriction. These include rendering first aid or temporary assistance in an emergency, fulfilling requirements to become a member of a health profession while supervised, and treating a person by prayer or spiritual means in accordance with the giver's religion. The same Act allows delegation of a controlled act, provided it complies with the regulations under the delegating member's own profession's Act.
What falls outside the controlled act
Much of what people call therapy or counselling never reaches the threshold. The CRPO lists activities that fall outside the controlled act, and the list is not exhaustive:
- advocating and case management
- counselling and support
- crisis intervention
- hypnotherapy, for example for smoking cessation
- intake and referral
- mediating
- psychometric testing
- spiritual or faith guidance
- single-session counselling
- teaching and problem solving
This matters for couples in particular. Mediating a separation, for example, is a different activity from treating a serious disorder of mood or cognition, and a communication skills workshop is education. A single-session conversation to help someone think through a decision is counselling.
None of this makes those activities low in value. A well-run problem-solving session can change a household. The distinction is regulatory: these activities do not trigger the legal restriction, even though a skilled professional will still bring care, ethics and judgment to them.
The reverse also holds. If someone starts out offering support and the work turns into ongoing treatment of a serious disorder through psychotherapy technique, the activity may cross the line, and the person offering it needs to be authorized.
"Therapist" versus "psychotherapist": what the titles mean
Two separate rules are often blended. One governs the act. The other governs titles.
People who are not registered with the CRPO or with one of the other five Ontario bodies whose registrants practise psychotherapy cannot use the titles "psychotherapist" or "Registered Psychotherapist". Certain members authorized to perform the act, such as some physicians or social workers, may use the title "psychotherapist" if they meet the identification requirements in the RHPA, which involve oral and written disclosure of their college and status.
The word "therapist" on its own is a different matter, and the CRPO does not own it. Anyone can say they offer counselling or coaching, as long as they do not use a protected title and do not perform the controlled act without authority. So the practical test for you is not whether someone uses a friendly word. It is whether they can name their regulatory college and registration.
Online therapy and practitioners outside Ontario
Video sessions have blurred geography, but the law follows the client. The controlled act applies to practitioners physically in Ontario and to those outside Ontario who provide services to clients in Ontario, by video call for instance.
The CRPO's cross-border guidance is more nuanced than a blanket ban. The College generally will not act against a practitioner regulated elsewhere for infrequent e-therapy to an Ontario client. Non-registrants, however, cannot perform the controlled act on Ontario clients unless an exception applies, and a substantial Ontario connection may stop them from using the title "psychotherapist" unless they are regulated in Ontario.
If you are choosing an online provider while living in Ontario, ask where they are registered and whether they are authorized for Ontario clients. Our guide to video therapy etiquette in Canada covers the practical side of sessions on screen.
How Ontario compares with other provinces
Regulation of psychotherapy is a provincial matter. According to the Canadian Counselling and Psychotherapy Association, Ontario and Quebec are unique in regulating both the professional title and the controlled act. Nova Scotia, New Brunswick and Prince Edward Island, among others, mainly focus on protecting the title instead of a specific controlled act.
Where no legislation applies, professional credentials such as the Canadian Certified Counsellor designation act as voluntary standards. That is a useful reminder if you move or see a provider licensed elsewhere: a credential that means one thing in Ontario may mean something different, or something voluntary, in another province.
Our perspective at Dewycounselling
We have worked with diverse client groups for more than 20 years, and our view is that the controlled act is best understood as a promise of accountability, not a barrier. Clients come to us with grief, addiction, anxiety, depression, relationship conflict and sexual concerns. Some of what they need is education or support. Some is treatment. Being honest about which is which, early on, is part of caring for someone well.
We use more than one therapeutic modality and rely on evidence-based approaches, because no single method suits every person or every couple. That also means we talk with clients about fit. If your needs would be better served by a different kind of professional, we would rather say so than keep you in the wrong room.
We also think cost should not decide whether the right person sees you. We offer sliding scale pricing, and we see people in person at two locations as well as online. Whoever you choose, ask about their college, their registration and their approach. A good therapist welcomes those questions.
— Wayne Dewhurst
How to check that your therapist is qualified
A short routine takes ten minutes and prevents most problems.
- Ask for the college and registration number. A qualified practitioner can give both without hesitation. Regulated professionals are also required to identify their status when using the title.
- Look them up on the college's public register. Each of the six colleges keeps one. Check the name, status and any conditions on practice.
- Ask what their training covers. For couples, trauma or addiction work, ask about experience with that specific issue.
- Ask about supervision. If you are seeing a trainee, they should be working under a qualified supervisor, and you can ask who that is.
- Clarify fees and coverage. Our articles on how to find a therapist in Ontario and what OHIP covers for psychotherapy walk through the funding side.
If you are new to all of this, starting therapy for the first time in Ontario is less daunting than it sounds, and the first session is largely a conversation about fit.
Working with us
Our individual, couples and family psychotherapy is offered in person and online. In-person and online sessions are $175 per hour, and a mobile session is $225 per hour. A prepaid annual membership is $1,750 per year. For details on how we work with individuals, see our psychotherapy page. Couples facing infidelity, separation, or financial and sexual difficulties can read about our couples therapy. For questions about cost, our overview of therapy costs in Ontario explains what to budget.
FAQ
Is the controlled act of psychotherapy the same as all psychotherapy?
No. It is a smaller part of psychotherapy practice. It applies only when all five elements are present, including treatment of a serious disorder that may seriously impair functioning. Counselling, support and many other activities sit outside it.
Who is allowed to provide psychotherapy in Ontario?
Members of six colleges may perform the controlled act: psychotherapists, nurses, occupational therapists, physicians, psychologists or psychological associates, and social workers or social service workers. Supervised students and those completing registration requirements may do so under a qualified supervisor. Only registered members may use the title "Registered Psychotherapist".
Can I call myself a therapist in Ontario?
The protected titles are "psychotherapist" and "Registered Psychotherapist", which require registration with the CRPO or another authorized college. The general word "therapist" is not reserved in the same way. Even so, anyone using it still cannot perform the controlled act without authority.
Does the rule apply to online sessions?
Yes. It covers practitioners physically in Ontario and those elsewhere who serve clients in Ontario by video. The CRPO generally will not act against a practitioner regulated elsewhere for infrequent e-therapy to an Ontario client.
Which provinces regulate psychotherapy?
Regulation is provincial. Ontario and Quebec regulate both the title and the controlled act. Several other provinces, such as Nova Scotia, New Brunswick and Prince Edward Island, focus mainly on title protection.
Sources
- Controlled Act of Psychotherapy, CRPO
- 1.4 Controlled Acts, CRPO
- Clinical Supervision guide, CRPO
- Cross Border Therapy Tool, CRPO
- Regulated Health Professions Act, 1991
- Regulated Health Professions Act, 1991 (e-Laws search view)
- O. Reg. 474/19: Controlled Acts
- Psychotherapy, OCSWSSW
- The Profession & Regulation, Canadian Counselling and Psychotherapy Association