On 3 July 2026 the College of Nurses of Ontario published a new Aesthetic Services practice guideline. Most of the conversation about it has been clinical. The part almost nobody is talking about is the advertising section, and it changes how a lot of injectors are currently marketing themselves.
Written by Vanessa Kay, founder of The Kay Media. Seven years running digital marketing for Fortune 500 brands, then 25+ injectors and clinics scaled across Toronto and Canada, with a best client month north of $200k.
We run the marketing for injector-led practices in Ontario, so this guideline lands on our own desk before it lands on yours. Every ad, landing page and offer we operate for Ontario clients is being reviewed against it right now. What follows is what we found reading the document itself, and what we are changing because of it.
Sourced from the CNO guideline and news release directly, not from summaries. Every requirement below links to the page of the guideline it comes from, so you can check it yourself.
If you inject in Ontario, you have probably seen this guideline mentioned in a group chat by now. What follows is a plain-English read of the advertising and title sections, written from a marketing point of view rather than a clinical one, with links to the source so you can check every line yourself.
On 24 September 2026, CNO Council approved updates to two practice standards, Scope of Practice and Medication. They take effect on Monday, 1 March 2027, and they add two new accountabilities for nurses who provide aesthetic services:
The advertising rules covered in the rest of this article have not changed. CNO has said it will update the Aesthetic Services guideline to match the new standards, and we will update this article when it does. Source: CNO, Aesthetic Services: practice standards changes coming into effect on March 1, 2027.
A client-specific order comes from an authorized provider, such as a nurse practitioner or physician, after they assess that client. CNO’s FAQ says the assessment can happen in person or virtually, and that one order can cover a defined course of treatment for a set period. When that period ends the client needs a new order, and if something about the client changes before then, the provider may need to reassess them.
For your marketing, the change sits in the booking flow. A new client needs that assessment before treatment starts, so anything that promises same-day treatment to a first-time client needs a second look.
Built into the booking flow properly, the assessment becomes part of the offer rather than a hurdle. It also gives you a reason to follow up with every new lead. That is the same point the rest of this article makes about the consult: advertise the judgement, not the result.
CNO describes aesthetics as one of the fastest growing areas of practice in the profession. The new guideline sets out expectations across seven areas, and one of them is stated plainly as “using ethical advertising by nurses and employers.” That is the part with commercial consequences.
Nothing here is a new law invented by the College. Much of the advertising section points at rules that already existed, including Canada’s Food and Drugs Regulations. What the guideline does is put them in one place and make clear that nurses are accountable for them.
The guideline says advertisements must be truthful, professional and ethical, and it defines each one (guideline, Advertising, PDF page 11):
Accurate and factual. It must not mislead the audience or use sensational claims, and the information must be verifiable.
It must maintain the integrity of the profession and not erode public confidence in nurses or in nursing.
Provide all relevant information, and avoid comparative statements or guaranteeing the success of a treatment or product.
“Avoid comparative statements” is worth sitting with. A lot of aesthetic marketing is built on being better than the clinic down the road.
This is the line that has the biggest effect on how injectors currently advertise. The guideline says nurses must not reference, directly or indirectly, the therapeutic use or benefits of specific prescription drugs, and it points to Section C.01.044 of Canada’s Food and Drugs Regulations, which restricts advertising prescription drugs to consumers to name, price and quantity (guideline, PDF page 11).
The guideline then spells out what that captures:
Read that list against a typical injector’s feed. Before-and-afters, treatment videos and results testimonials are the format most accounts are built on. The restriction is tied to prescription drug promotion specifically, which is why it lands so hard in this niche.
Where images or video are used, the guideline requires the client’s informed consent, and says the media must be the result of the work of the nurse associated with the advertisement. It also states the media must not be digitally enhanced, giving photoshopping and retouching as the examples (PDF page 11). The consent section adds that a client should know the intended use of any photos or videos taken, for example whether they are for documentation or for advertising (PDF page 8).
Stock results, borrowed content and a smoothing filter are all addressed by that single sentence.
When advertising aesthetic services, the guideline says nurses must include their full name, the professional designation as noted on CNO’s public register, and their role on the care team. It adds that advertising should also include the name of the nurse’s authorizing provider or medical director, so clients can see who is accountable (PDF page 11).
The guideline is direct about job titles. Clients are entitled to know who is providing their care, and whatever a workplace calls a role, nurses must identify themselves with their full name and the designation matching their registration status. Under the Nursing Act, 1991, “nurse,” “Nurse Practitioner,” “Registered Nurse” and “Registered Practical Nurse” are the protected titles (guideline, “Care team, roles and title use”, PDF page 12).
It also flags descriptive words. The guideline gives “expert” and “master” as examples of adjectives that may mislead the public about a nurse’s level of qualification and experience (PDF page 12). Those words appear in a lot of bios and ad headlines.
The instinct will be to panic and delete everything. That is not the read. The guideline restricts a specific set of tactics, mostly the ones tied to promoting prescription drugs to consumers. Plenty of what actually drives bookings is untouched.
Our lip filler marketing guide applies these rules to one of the most advertised treatments, with a section on what you can and cannot say in Canada.
Worth noting for anyone who does not control their own marketing: the guideline recognises that some nurses are employees, and says they are still accountable to advocate for responsible advertising and to document the steps they took when they raise concerns. If the employer is a regulated health professional, nurses can also consult or report concerns to that employer’s regulator. If a nurse thinks the employer may be breaching the Food and Drugs Act, the guideline says to contact Health Canada (PDF pages 11 and 12).
The CNO guideline applies to nurses in Ontario. The rule behind its toughest line is federal, so it applies to anyone in Canada who advertises a prescription drug, whatever their profession or province. Here is what Health Canada’s own pages and the regulations say, quoted directly.
| Body | What it covers in your marketing |
|---|---|
| Health Canada | Advertising of health products, including prescription drugs and medical devices, under the Food and Drugs Act and its regulations. It applies across Canada. |
| Your college | How you, as a regulated professional, advertise: CNO in Ontario, BCCNM in British Columbia. Colleges can add rules on top of the federal ones. |
| Your province | Health Canada notes that “each province may have its own requirements for health care provider advertising which may impose additional restrictions.” |
The full text of Section C.01.044 of the Food and Drug Regulations reads: “If a person advertises a prescription drug to the general public, the person shall not make any representation other than with respect to the brand name, the proper name, the common name and the price and quantity of the drug” (Justice Laws Website).
Health Canada’s page on illegal marketing of prescription drugs uses Botox as its example. It says Botox “is an example of a prescription drug that health care providers and clinics sometimes market to consumers. No direct or indirect reference can be made to its therapeutic use and/or benefits.” It lists the issues it commonly finds:
That is the same list the CNO guideline uses, which is why the two documents read alike.
This is the part most summaries miss. On the same page, Health Canada says: “The Food and Drugs Act and its associated regulations do not apply to advertising of services.” It then adds: “If you promote specific products on your website, you must comply with the federal advertising requirements.” It also says that anyone who promotes the sale of a specific health product is subject to the legislation, and that “this includes health care providers.”
For marketing, that is the line to work from. An ad for your consultation, your assessment and your care is advertising a service. An ad that names a prescription drug and hints at what it does is advertising the drug, and C.01.044 applies.
In its guidance for drug manufacturers, Health Canada describes “reminder ads” that “are limited to the name, price and quantity of a prescription drug” and “do not include reference to a disease state.” For a clinic, the safe pattern follows the same shape: the product name, the price and the quantity, with no wording or image about what it treats or how you will look afterwards. The claims sit with the consult, which is where they belong.
Section 9(1) of the Food and Drugs Act says: “No person shall label, package, treat, process, sell or advertise any drug in a manner that is false, misleading or deceptive or is likely to create an erroneous impression regarding its character, value, quantity, composition, merit or safety” (Justice Laws Website).
Many aesthetic treatments use medical devices. Health Canada’s medical device page says Class II, III and IV devices “are authorized by Health Canada for specific indications” and “must be advertised within the scope of their authorized indications.” Its page on illegal marketing practices adds a point that catches a lot of clinic websites: “Claims of endorsement by government authorities, such as Health Canada, are not permitted.” It gives “This device is Health Canada-approved” as a prohibited statement, and “Health Canada has authorized this device for sale” as a permitted one, if the product is authorized.
The same page says testimonials and endorsements “are only acceptable if they represent the honest and current opinions of the individuals or organizations,” and must be consistent with the product’s authorized indications.
Health Canada takes complaints about health product advertising through its complaint process, and its advertising requirements page says Ad Standards and the PAAB give advisory opinions on consumer messages about prescription drugs. If you are unsure whether an ad crosses the line, those are the bodies to ask.
We market injector-led practices for a living, so this guideline lands on our desk as work rather than as commentary. Here is what is actually changing in the accounts we run, in case it is useful.
Most aesthetic ads are a result with a price attached. Take the result out and there is nothing left, which is why the guideline feels existential to so many accounts. The ads that survive it are the ones where the offer was doing the work in the first place: what happens at the consult, what it costs, what you do if it is not right for them, how quickly they can be seen.
We build the offer before we spend a dollar on traffic, and that ordering is the reason this guideline changes our creative far less than it changes most feeds. When your ad never depended on a drug’s outcome, there is not much to remove.
A testimonial about a therapeutic effect is restricted. A client describing how the consult felt, how carefully she was assessed, and how she was treated when she asked a nervous question is not. The second one converts better anyway, because the person reading it is nervous too.
So the brief changes. We stop asking clients to talk about how they look and start asking what nearly stopped them booking, and what happened instead. Grace’s story is that kind of proof. Nothing in it turns on a product.
If you cannot advertise the outcome, advertise the judgement. Who assesses you. What they check. Why they might tell you no. For an injector with real clinical standards, this rule is a gift, because it moves the competition from who has the best photo editor to who is visibly the safer pair of hands.
Practising in British Columbia? Your college is BCCNM, not CNO, and its rules work differently. Read our guide to BCCNM advertising rules for aesthetic nurses.
Most aesthetic marketing in this province leans on exactly the tactics that just got restricted. If your competitors keep running before-and-afters and results testimonials, the gap is not going to be who has the flashiest feed. It will be who can fill a calendar without them.
That is a harder marketing problem, and it is a better one to have, because it is built on the offer, the consult and the follow-up rather than on borrowed proof. It is also the problem we already solve. Vanessa Kay spent seven years in Fortune 500 marketing before building this agency around aesthetics, and the system we run for injectors was built on offers and demand rather than on results imagery, well before this guideline existed.
You can advertise your services, and you can advertise Botox itself only within narrow limits. Section C.01.044 of the Food and Drug Regulations allows a consumer ad for a prescription drug to state its brand name, proper name, common name, price and quantity, and nothing else. Health Canada says no direct or indirect reference can be made to Botox’s therapeutic use or benefits.
Not for prescription drugs. The CNO guideline and Health Canada both list before-and-after treatment pictures among the things the prescription drug rule captures. Where a nurse uses any images or videos in advertising, the guideline also requires the client’s informed consent, media from the nurse’s own work, and no digital enhancement such as photoshopping or retouching.
Testimonials about the therapeutic effects of a prescription drug are on both lists. A review about the experience, such as how the consult felt or how carefully the client was assessed, does not describe a drug’s effect. Health Canada also says endorsements and testimonials are only acceptable if they represent the honest and current opinions of the people giving them. When a review mentions a product’s results, leave it off your ads.
The nurse’s full name, professional designation as shown on CNO’s public register, and role on the care team. The guideline adds that the ad should also name the nurse’s authorizing provider or medical director.
The CNO guideline says nurses who do not control their advertising, such as employees, are still accountable to advocate for responsible advertising and should document the actions they take. They can consult or report concerns to a regulated employer’s regulator, and contact Health Canada about possible breaches of the Food and Drugs Act. Health Canada says anyone who promotes the sale of a specific health product is subject to the legislation, so an agency running the ad does not move the rule elsewhere.
The guideline gives “expert” and “master” as examples of adjectives that may mislead the public about a nurse’s level of qualification and experience. Nurses must identify themselves with their full name and the designation that reflects their registration, such as NP, RN or RPN.
Health Canada says claims of endorsement by government authorities are not permitted, and gives “This device is Health Canada-approved” as an example of a prohibited statement. If the product is authorized for sale, “Health Canada has authorized this device for sale” is the wording it gives as permitted.
Updates to CNO’s Scope of Practice and Medication standards take effect. Aesthetic services involving prescription drugs or controlled acts will need a client-specific order rather than a directive, and a nurse who delegates an aesthetic procedure involving a controlled act must be onsite for the whole procedure. The advertising rules in this article have not changed.
The CNO guideline applies to nurses registered in Ontario. Section C.01.044 and Health Canada’s advertising rules are federal and apply across Canada. Nurses in British Columbia follow BCCNM, covered in our guide to BCCNM advertising rules, and Health Canada notes that provinces may add their own requirements for health care provider advertising.
If you are rebuilding your marketing around this, that is the work we do. We help injectors and clinic owners across Ontario and Canada build the offer, run the ads and keep the calendar full, without relying on the tactics this guideline restricts.
Start here: nurse injector marketing in Toronto, med spa marketing in Toronto, or aesthetic clinic marketing. The full playbook is in our med spa marketing guide, and you can apply to work with us here.
Sources: College of Nurses of Ontario, Aesthetic Services practice guideline (published 3 July 2026) and the accompanying CNO news release; CNO, Aesthetic Services: practice standards changes and FAQs (standards approved 24 September 2026, in effect 1 March 2027). Quotations of requirements are drawn from the guideline’s Advertising and “Care team, roles and title use” sections (PDF pages 11 and 12). Health Canada, Illegal marketing of prescription drugs, Illegal marketing of medical devices, Beware of these illegal marketing practices and Regulatory Requirements for Advertising; Food and Drug Regulations, Section C.01.044 and Food and Drugs Act, Section 9 (Justice Laws Website, current to 30 September 2026; all checked 22 October 2026). This summary is written for marketing purposes and is not legal or regulatory advice.
