Can Ontario RPs practice in BC? “The Ultimate Guide to Cross‑Border Psychotherapy: Laws, Limits, and Lessons Learned”

If you’ve ever tried to offer therapy to a client who’s suddenly “just popping over to Nova Scotia for a week” or taking a spontaneous soul‑searching trip to Portugal, you already know the sinking feeling that comes next: Wait… am I even allowed to do this? Cross‑border therapy is one of those topics that sounds simple until you actually look at the rules — at which point it starts to feel like assembling IKEA furniture without the instructions. This guide is here to change that. 

Virtual care didn’t just open doors — it dissolved walls. Clients move, travel, study abroad, take remote jobs, or split time between provinces. Therapists want continuity of care. Regulators want clarity. And somewhere in the middle sits you, the clinician, Googling “Can I see a client who is in Alberta for two weeks???” at 11:47 p.m.

We’re unpacking the controlled act, protected titles, insurance traps, and the golden rule of jurisdiction (spoiler: it follows the client), all in plain language and with zero panic required. Grab a tea, settle in, and let’s make sense of the regulatory maze together.

This guide is here to help you breathe again.

Cross‑Border Therapy: It’s Like Driving in France… But With More Paperwork

One of the most common questions CRPO receives is about cross‑border therapy: Where can I practise, and what rules apply when my client is in another province or country? Many therapists are surprised to learn that CRPO cannot actually answer that question. The College only regulates psychotherapy within Ontario; it has no authority to interpret or enforce the laws of Alberta, British Columbia, Quebec, or anywhere else. Asking CRPO whether you can practise in another province is a bit like asking the Ontario Ministry of Transportation whether you’re allowed to drive in France — they can confirm your Ontario licence is valid, but they can’t tell you the speed limits in Paris or whether France requires a different permit.

To know whether you can practise elsewhere, you must check with the regulator in the jurisdiction where the client is located. And that’s the golden rule of cross‑border practice: regulation follows the client. If your client is physically sitting in a hotel room in Nova Scotia during your session, then for regulatory purposes, you are practising in Nova Scotia, even if you’re sitting in Toronto. This principle applies whether the session is virtual or in‑person — the client’s physical location determines the regulatory framework.

This is where title protection becomes especially important. “Registered Psychotherapist” (RP) is an Ontario‑specific protected title. In New Brunswick, for example, the equivalent protected title is “Licensed Counselling Therapist” (LCT). Using the wrong title in another province can trigger what’s known as a “holding out” violation — presenting yourself as a member of a regulated profession in a jurisdiction where you are not authorized to use that title.

Holding out isn’t just a technicality; it’s a legal and ethical safeguard designed to protect the public, ensure accountability, and prevent confusion about scope and oversight. So if an Ontario RP moves to New Brunswick and continues calling themselves a “Registered Psychotherapist” without registering with CCTNB, they may be seen as holding out, unintentionally implying they are regulated under New Brunswick’s framework when they are not.

Understanding these jurisdictional boundaries helps therapists navigate cross‑border work with clarity, integrity, and compliance — and helps clients understand exactly who is regulating their care.

The Controlled Act of Psychotherapy Explained (Without the Legal Headache)

In Ontario, psychotherapy includes a legally defined Controlled Act, which refers to treating serious disturbances in thought, mood, or memory that may significantly impair a person’s judgment or functioning. Only members of specific regulated colleges—such as Registered Psychotherapists, Psychologists, Social Workers, Nurses, Occupational Therapists, and Physicians—are legally permitted to perform this act. This distinction exists to ensure that individuals receiving treatment for serious mental health conditions are supported by professionals with appropriate training, oversight, and accountability.

RP Here, LCT There: Understanding Protected Titles Across Canada

Across regulated provinces, it is illegal to present yourself as a Psychotherapist unless you are formally registered with the appropriate regulatory body. This protects the public by ensuring that anyone using the title has met rigorous professional standards, including completing a recognized master’s‑level education, accumulating substantial supervised clinical hours, passing a registration exam (such as the CRPO exam), maintaining liability insurance, and adhering to a professional code of ethics. Title protection ensures clarity, safety, and trust for clients seeking psychotherapy services.

The CRPO’s Only Requirement: Standard 3.4

The CRPO has one key rule related to cross‑jurisdictional work, and it functions as a responsibility requirement rather than a permission‑granting one. Standard 3.4 (Electronic Practice) states that Registered Psychotherapists must comply with the licensing laws of the jurisdiction where the client is physically located. In practice, the CRPO’s stance is: “We won’t stop you from working with clients outside Ontario, but we will hold you accountable if you violate another province’s laws while identifying yourself as an Ontario RP.” This places the responsibility on the therapist to understand and follow the rules of the client’s location.

What to Do Instead of Calling the CRPO

Because the CRPO cannot give case‑specific approval for cross‑border practice, therapists are encouraged to use alternative, more authoritative resources. The CRPO’s Cross‑Border Therapy Tool offers a self‑assessment that helps you think through jurisdictional considerations without providing formal advice. You should also contact the regulator in the client’s province, as they are the only body that can give a definitive “yes” or “no” regarding your ability to practise there. Professional associations such as the CCPA or OSRP can also be valuable supports; as advocacy organizations rather than regulators, they can often provide more practical, cross‑country guidance. The CCPA even offers their own excellent guide on cross provincial border therapy here.

Psychotherapy regulation Canada by province

Want a brief summary of the current state of regulation in each province, as well as the contact for the regulatory body in question? See our single sheet summary here

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Therapy Without Borders (But With Rules): Understanding Their Province’s Laws

When a client receives services while physically located in another Canadian province, the therapist must follow the laws of that province, not just Ontario’s. This includes rules related to mandatory reporting, child protection, adult protection, health‑privacy, and in some cases, professional conduct. Even though the therapist is registered in Ontario, they may still be held accountable under the legislation of the province where the client is located during the session. Understanding these local laws is essential for safe, ethical, and compliant cross‑provincial practice.

Mandatory Reporting Laws Vary Across Provinces

Mandatory reporting requirements differ across Canada, and therapists must follow the rules of the province where the client is located. Provinces vary in how they define a “child,” with some using under 16 and others under 18, which affects reporting obligations for older teens. The types of concerns that must be reported also differ; some provinces require reporting risk of harm or exposure to intimate partner violence, while others require evidence of abuse or neglect. Reporting pathways vary as well, with different agencies, intake lines, or Indigenous child‑welfare authorities responsible for receiving reports. Some provinces also have mandatory reporting for vulnerable adults, while Ontario does not, except in long‑term care or retirement homes. Additionally, the duty to warn or protect is interpreted differently across provinces, with some having explicit statutory duties and others relying on common‑law principles. These variations mean therapists must understand and follow the reporting rules of the client’s temporary province.

Health‑Privacy Laws Also Differ Between Provinces

Each province has its own health‑privacy legislation governing how personal health information is collected, stored, shared, and disclosed. While the principles are similar, the details differ. Provinces vary in whether they require express or implied consent for disclosures, how quickly clients must be given access to their records, and what exceptions apply. Record‑retention periods also differ, with some provinces requiring seven years, others ten, and some using age‑of‑majority‑plus‑a‑set‑number‑of‑years formulas. Certain provinces, such as British Columbia and Nova Scotia, have stricter rules about storing health information outside Canada, while Ontario allows cloud‑based storage with appropriate safeguards. Provinces also differ in when information may be disclosed without consent, particularly in situations involving safety or collaboration with other health providers. When a client is located in another province, the therapist must ensure their privacy practices align with that province’s legislation.

Sound like a lot to consider? It is! You can see our charts comparing health privacy legislation and mandatory reporting requirements across provinces here to get an idea of how they differ.

How to Apply This in Practice

Before providing interprovincial services, therapists should identify the province where the client will be located and review that province’s child‑protection, adult‑protection, and health‑privacy laws. They should document that they have reviewed the relevant legislation and adjust consent, documentation, or session structure as needed. Therapists should also explain to clients how reporting and privacy obligations may differ while they are away. Taking these steps demonstrates responsible, ethical practice and helps protect both the client and the therapist.

Before providing interprovincial services, therapists should:

• Identify the province where the client will be located.
• Review that province’s child‑protection, adult‑protection, and health‑privacy laws.
• Document that they have reviewed the relevant legislation.
• Adjust consent forms or session structure if needed.
• Clarify with the client how reporting and privacy obligations may differ while they are away.

This due diligence demonstrates responsible, ethical practice and protects both the client and the therapist.

Contracts and Informed Consent for Electronic Practice

In Ontario, the CRPO requires therapists to establish a clear contract with clients before beginning electronic practice. This requirement is designed to address jurisdictional risks that standard consent forms often overlook, particularly when clients are located outside Ontario. If you have completed all necessary safeguards and decide to proceed with cross‑border therapy, it is wise to implement a dedicated informed‑consent policy tailored to this context. A sample policy can be adapted to fit your practice needs and ensure clients fully understand the legal and practical considerations involved. Find our sample version here.

Out‑of‑Province and Out of Office: Can Therapy Travel Too? Can I see a Client who is Temporarily Cross-Border?

The “Insignificant Connection” Concept

In provinces such as Ontario, where psychotherapy is regulated by the CRPO, the law technically requires anyone practising psychotherapy within the province to be registered there. However, a commonly referenced grey zone—often called an insignificant connection—may apply when a client who normally resides and receives therapy in your home province is temporarily travelling. This concept is generally understood to cover situations where the client is simply a visitor (for example, on a one‑week vacation or short business trip) and where the therapist is not marketing services to residents of the other province but is instead maintaining continuity of care within an existing therapeutic relationship.

Key Considerations Before Agreeing to an Out‑of‑Province Session

Duration and Intent

Therapists should first consider how long the client will be away and for what purpose. Short, transitional absences—typically 7 to 14 days—are often viewed by regulators as continuity of care. Longer stays, such as a four‑month university semester or a seasonal “snowbird” relocation, usually require the therapist to check the destination province’s registration rules before providing service.

The “Risk of Harm” Rule

If a client is experiencing significant risk—such as active suicidal ideation—providing therapy while they are out of province becomes more complex both legally and ethically. Therapists must ensure they know the local crisis resources and hospital locations in the client’s temporary location, understand how to coordinate with emergency services in that jurisdiction, and verify that their professional liability insurance covers complaints filed in the client’s current province, not just their own.

Best Practices for Registered Psychotherapists

When an RP chooses to proceed with a brief out‑of‑province session, they should document their decision‑making clearly in the clinical record. This includes the rationale for the session (for example, maintaining clinical stability during a short trip), the exact locations of both client and therapist, and confirmation of an emergency plan that includes the client’s temporary address and nearest emergency department. Therapists should also note that they reviewed the destination province’s regulatory information. When working with clients temporarily located in Quebec, therapists must specify that they are providing supportive counselling rather than the Controlled Act of Psychotherapy, unless they hold a Quebec permit.

The 3‑Hour Informal Rule (Participating Provinces)

Some provinces—particularly in the Atlantic region—have historically adopted informal agreements or Memoranda of Understanding that allow therapists from other provinces to provide brief, urgent support without full registration. These allowances are often limited to approximately three cumulative hours per year and apply only when the client is temporarily present in that jurisdiction.

Contacting the “Away” Regulator

If a client plans to be away for an extended period—for example, “I’m going to BC for a month”—the CRPO recommends contacting the regulator in that province (currently the CHCPBC). A simple script can be used:
“I am a Registered Psychotherapist in Ontario. I have an existing client who will be in your province for four weeks. I intend to provide continuity of care for two sessions. Does your College require temporary registration for this limited, non‑resident service?”
Therapists should save the regulator’s written response, as it serves as essential documentation if a complaint is ever filed.

Again, we synthesized the contact info for the local regulatory bodies on a single sheet here

When to Decline

Therapists should pause or transition care when the client is relocating permanently, when the therapist’s insurance does not cover practice in the client’s temporary jurisdiction, or when the destination province—such as Quebec—explicitly prohibits non‑members from practising without a temporary permit.

Creating a Vacation Policy

To support clarity and reduce risk, therapists can develop a formal Vacation Policy to include within their existing informed‑consent or service‑agreement documents. This policy outlines expectations and limitations before a client travels, ensuring that both parties understand the “rules of the road” well before the suitcase is packed. You can adapt the sample policy provided to suit your practice needs.

Please remember to always consult with the local regulatory body as well as the regulation status of the province in question. Find our handout here of contact information for local regulatory bodies and regulatory status, current as of December 2025. Remember to document any communication with the local body in your clinical records.

Therapy While Abroad: What Canadian Clinicians Must Know Before Clicking ‘Join Session':

Understanding the Shift From Provincial to International Risk

When a client leaves Canada, the landscape becomes more complex. Instead of navigating provincial licensing rules, therapists must consider international laws, local restrictions, and emergency‑response limitations. Some countries have no regulation of psychotherapy, while others have strict rules about foreign clinicians providing mental‑health services to individuals located within their borders. Because of this variability, international work carries more uncertainty and requires careful planning and documentation.

1. Duration and Purpose of Travel

When a client is travelling internationally, the length and purpose of their trip play a major role in determining whether therapy can continue. Short, transitional travel—typically 7 to 14 days—is often considered continuity of care, particularly for clients who are stable and seeking brief support while away. Longer stays of one to six months are no longer simple vacations; in these cases, therapists should review the destination country’s laws or professional guidelines before offering services. If the client is relocating permanently or semi‑permanently, therapy should generally be paused or transferred unless the therapist has explicit legal permission to practise in that country.

2. Local Laws and Restrictions

Each country has its own regulatory approach to mental‑health services, and therapists must consider these differences before providing international sessions. Key questions include whether the country requires foreign clinicians to hold a local licence, whether it restricts telehealth delivered from outside its borders, and whether certain professional titles or therapeutic activities are protected or prohibited. While therapists are not expected to become experts in foreign legislation, they are expected to demonstrate reasonable due diligence by reviewing publicly available information and ensuring their services do not conflict with local regulations.

3. Emergency Response Limitations

Emergency planning becomes significantly more complex when a client is outside Canada. Local emergency numbers vary—such as 112 in the EU, 999 in the UK, and 000 in Australia—and crisis services may be limited, inconsistent, or unavailable. Language barriers can complicate communication, and coordinating a wellness check from another country may be difficult or impossible. Because of these limitations, international sessions are generally not advisable when a client is experiencing any elevated level of risk. Ensuring a reliable, location‑specific emergency plan is essential before agreeing to provide care while the client is abroad.

Best Practices for International Sessions

If you decide to proceed with a brief, low‑risk international session, document the following:

Rationale

Record why the session was clinically necessary (e.g., “Client is abroad for 10 days and requested continuity of care to maintain stability.”)

Location Verification

Document:

• The client’s exact temporary location
• Your own location
• The date and time of the session

Emergency Plan

Note that you:

• Confirmed the client’s temporary address
• Identified the local emergency number
• Located the nearest hospital or emergency service
• Reviewed crisis options available in that country

Legal Due Diligence

Record that you:

• Reviewed publicly available information about the country’s telehealth or mental‑health regulations
• Contacted a professional association if needed
• Determined whether the service should be framed as “supportive counselling” rather than a regulated act, depending on the jurisdiction

When to Decline International Sessions

Therapists should pause or decline therapy when:

• The client is relocating for school, work, or long‑term stays
• The destination country has strict licensing requirements
• The client is in a high‑risk state
• You cannot establish a safe emergency plan
• The country prohibits foreign mental‑health services

In these cases, offer:

• A transition plan
• Local resources
• A temporary pause with a plan to resume when the client returns to Canada

Creating an International Travel Policy

Just like your Canadian Vacation Policy, you can develop an International Travel Policy that outlines:

• What you can and cannot do
• How long a client can be abroad before services must pause
• What information you require before agreeing to a session
• Your emergency‑planning requirements
• Any jurisdictional limitations

This can be added to your informed‑consent package so expectations are clear long before the client travels. See our sample international travel policy here. 

The Real Risk in Cross‑Border Therapy: It’s Not the College, It’s Your Insurance:

Therapist insurance Considerations  for Cross-Border Counselling

It's all about insurance

For many therapists, the "fear" is usually about the College (regulation), but the "risk" is actually with their insurance provider.

Regulation tells you if you’re allowed to practice; insurance tells you if you’re protected when something goes wrong. If a therapist is legally allowed to practice in a province but their insurance doesn't cover that province, they are one "bad session" away from financial ruin.

Many therapists assume their liability insurance automatically covers them anywhere in Canada. While most policies appear “Canada‑wide,” the fine print often contains important limitations that become highly relevant when working with clients located in other provinces. Before offering cross‑border services, therapists should review their policy carefully and, ideally, obtain written confirmation from their insurer. Key areas to examine include jurisdictional coverage, territorial limits, lawful‑practice requirements, disciplinary defence provisions, cyber liability, and how the policy defines “professional services.”

Canada‑Wide? Maybe Not. What Your PLI Really Covers Across Provinces

Insurance Red Flags for Cross‑Border Therapy

1. Jurisdictional Limits

Most PLI policies state they are valid across Canada, but some restrict coverage depending on where a lawsuit is filed. If a client located in Alberta sues an Ontario therapist, the case may be heard in an Alberta court. Certain Ontario‑based policies only cover legal defence for cases heard within Ontario, leaving the therapist exposed if the complaint is initiated elsewhere. Therapists should confirm that their policy covers legal defence in any Canadian jurisdiction where a client might file a complaint.

2. Territorial Limits

Territorial limits determine where the service must be delivered in order to be covered. Some policies only cover services provided while both therapist and client are physically located within Canada. If either party is outside the country—even temporarily—coverage may not apply. This becomes especially important when clients travel internationally or when therapists provide sessions while abroad. Therapists should verify whether their policy covers services delivered across borders or only within Canadian territory.

3. Lawful Practice Requirement

Nearly all PLI policies include a clause stating that coverage applies only when the therapist is practising in accordance with the laws of the jurisdiction where the client is located. This is the most common reason insurers deny claims. For example, if a therapist provides psychotherapy to a client in Quebec without holding a Quebec permit, they are technically practising unlawfully in that province. If the client later files a complaint or lawsuit, the insurer may void the policy on the grounds that the therapist was not practising legally in that jurisdiction. Ensuring compliance with local laws is therefore essential not only for ethics but also for insurance protection.

4. Disciplinary Defence Coverage

Many policies include a specific amount of coverage for disciplinary defence (e.g., $50,000–$100,000). However, this coverage is often tied to the therapist’s home regulatory body. If a regulator in another province—such as the NSCCT in Nova Scotia—initiates an investigation into an Ontario therapist for “holding themselves out” as a therapist in that province, the Ontario‑based policy may not cover legal fees for defending against an out‑of‑province regulator. Therapists should confirm whether disciplinary defence applies only to their primary regulator or to any Canadian regulatory body.

5. Virtual / Cyber Endorsements

Cross‑border therapy is almost always delivered virtually, which introduces additional risks. Therapists should ensure their policy includes cyber liability coverage, particularly for privacy breaches involving clients in other provinces. If a device is stolen or compromised and the personal health information of a client in Manitoba is exposed, the therapist may be required to follow Manitoba’s privacy legislation—including breach‑notification requirements. Cyber coverage should explicitly include costs associated with responding to privacy breaches in the client’s province.

6. Definition of “Professional Services”

Every PLI policy includes a definition of what counts as a covered professional service. This becomes important when therapists modify their service to comply with another province’s laws—for example, offering “supportive counselling” rather than psychotherapy in Quebec. If the service provided does not fall within the policy’s definition of covered activities, the insurer may deny the claim. Therapists should confirm that any adjusted or alternative service they provide is still covered under their policy.

7. Claims‑Made Policies

Most Canadian PLI policies are “claims‑made,” meaning coverage applies only if the policy is active at the time the claim is filed—not just when the service was delivered. This matters for cross‑border work because complaints may arise months or years after the session, and potentially in another province. Therapists should maintain continuous coverage and ensure that any change in insurer or lapse in coverage does not leave past cross‑border work unprotected.

8. Contractual Liability Exclusions

Some PLI policies exclude liability arising from contracts or service agreements. Because cross‑border therapy often requires specialized consent forms or travel‑specific agreements, therapists should ensure that these documents do not unintentionally create obligations that fall outside their policy’s coverage. Reviewing contractual‑liability exclusions helps ensure that consent forms support, rather than undermine, insurance protection.

"Never assume 'Canada-wide' means 'Everything-covered.' Insurance companies are in the business of assessing risk. If you change your risk profile by crossing borders without telling them, you might be paying for a policy that won't actually catch you if you fall."

Therapists: Don’t Travel Without This Insurance Checklist

Want to assess if your insurance has you covered? Read our list of questions to ask your broker before engaging in cross border practice here

When Your Client Roams, Your Ethics Shouldn’t

Navigating cross‑border counselling can feel complex, but the heart of it is simple: know where your client is, understand the laws that apply there, ensure safety, and document your reasoning every step of the way. This guide is meant to support thoughtful, ethical decision‑making, but it is not legal advice, and I am not a legal expert. If questions or uncertainties remain, it’s always wise to consult a lawyer familiar with health‑care regulation in the relevant jurisdiction. Many professional associations—including the CCPA—offer free or low‑cost legal consultation for members, and it’s worth taking full advantage of those services. When in doubt, seek clarification, document your process, and choose the path that protects both you and your client.

Cross‑Border Therapy: A Choose‑Your‑Own‑Compliance Adventure

Finding This a lot to digest? I get it! Let us help you navigate your decision with this one page decision making flow chart here.

As a Registered Psychotherapist (RP) in Ontario, navigating the "patchwork" of provincial laws is a complex professional task. The following disclaimer is designed to protect your professional boundaries by clarifying that this information does not constitute a legal opinion.

Legal & Professional Disclaimer

Purpose and Scope

The information provided in the charts and summaries above is for informational and educational purposes only. It is intended to offer a general overview of provincial legislation and should not be construed as legal advice, a legal opinion, or a substitute for professional legal counsel.

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