Leasing to a Veterinary Clinic in Ontario: Accreditation, Zoning and Lease Checks
In Toronto’s zoning by-law, a vet clinic is not a pet services use. Before you sign, read the by-law, the accreditation rules and the X-ray regulation, then write a use clause that fits all three.
What is a certificate of accreditation for a veterinary facility in Ontario?
Ontario’s Veterinarians Act says no one may establish or operate a veterinary facility “except under and in accordance with a certificate of accreditation” (s.15), and a facility can be a building, land or a vehicle. On its face, the certificate must show the facility’s name, its location, any terms, conditions or limitations, and the expiry date (Reg. 1093, s.15(1)). Under s.15(2) of Regulation 1093, it limits the practice at that facility to the veterinary services specified in the certificate, for the period of time specified in it.
Source: Veterinarians Act, R.S.O. 1990, c. V.3, ss.1(1) and 15; R.R.O. 1990, Reg. 1093, s.15 (as amended by O. Reg. 260/22), Ontario e-Laws (2026)
Say your unit has been a dog-grooming shop for years. The listing calls it pet services, the last tenant’s signage said pet services, and when a veterinarian asks about it, the natural assumption is that an animal business is moving out and another animal business is moving in. Toronto’s zoning by-law doesn’t see it that way. Its definition of pet services covers grooming of domestic animals and then adds, in so many words: “A veterinary hospital or a kennel are not pet services.”
I’m Arthur Zhao of AZ Real Estate Partners, and this piece is written for the owner of a commercial unit, not for the clinic. The clinic carries the licensing load, but a landlord who understands it can draft a lease that the clinic can actually operate under. What follows is general information from the statutes and by-law text I read; for your own building and your own lease, work with a lawyer.
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Document one: the zoning by-law, and two definitions that do not overlap
Start with Toronto’s Zoning By-law 569-2013 (the version read here is dated July 31, 2024, including City-wide amendments up to April 30, 2026). Chapter 800 holds the definitions, and two of them sit right next to each other in a landlord’s mind but not in the by-law.
Veterinary Hospital is definition (920): “premises used by a licensed veterinarian for the medical treatment of animals.” Pet Services is definition (565): “premises used to provide for the grooming of domestic animals. A veterinary hospital or a kennel are not pet services.”
So the question is not whether animals are already allowed in your unit. It is whether Veterinary Hospital, as its own listed use, is permitted in the zone that applies to your lot. A past grooming tenant tells you nothing about that.
Veterinary Hospital vs Pet Services in By-law 569-2013
The four zones checked for this article
I read the use tables for four zones, and in each one Veterinary Hospital appears in the plain Permitted Use list, not the Permitted Use with Conditions list:
- CR (Commercial Residential): 40.10.20.10(1)(A), the uses permitted under the letter “c” in the zone label.
- CL (Commercial Local): 30.20.20.10(1).
- CRE (Commercial Residential Employment): 50.10.20.10(1), under the letter “c” in the zone label.
- EO (Employment Industrial Office): 60.40.20.10(1), under the letter “e” in the zone label.
Two employment zones I also looked at do not list it: the use tables for E (Employment Industrial, 60.20) and EL (Employment Light Industrial, 60.10) have no Veterinary Hospital. The E zone does list Kennel, which is a different defined use.
In a CL zone there is one more line to note: 30.20.40.1(1) requires all uses to be located within a wholly enclosed building, except for outdoor sales and display, parks, parking spaces and loading spaces.
Parking is set in Table 200.5.10.1, where Veterinary Hospital sits in Tier 2. That row is written as maximums per 100 square metres of gross floor area: 0.8 in Parking Zone A, 1.0 in Parking Zone B and 3.5 in all other areas of the City.
Residential, institutional and other zone chapters were not read, and this is Toronto only. Other Ontario municipalities have their own zoning by-laws with their own definitions.
ℹ️Four zones, not the whole map. The zoning check in this article covers CR, CL, CRE and EO, where Veterinary Hospital is listed, plus E and EL, where it is not. Other zone chapters were not read. Individual properties can also carry site-specific exceptions that change what is permitted, so confirm the zoning for the specific address before you sign.
Document two: the Veterinarians Act and Regulation 1093
First, a note on timing. Ontario e-Laws prints this at the top of the Veterinarians Act: “This Act is repealed on a day to be named by proclamation of the Lieutenant Governor. (See: 2024, c. 15, Sched. 1, s. 120)”. Everything below is the law as it currently reads. When the replacement provisions come into force, section numbers and names will change, and e-Laws is the place to check.
According to the Veterinarians Act (s.15), no person shall establish or operate a veterinary facility except under and in accordance with a certificate of accreditation. The Registrar issues or renews a certificate on the application of a member of the College (a licensed veterinarian) where the applicant and the facility meet the qualifications, requirements and standards set by the regulations and by the Council (s.17(1)); the Accreditation Committee can be involved and can direct issuance with terms, conditions and limitations. The detailed premises standards are not in the regulation. Section 8(1) lets the College’s Council establish standards for veterinary facilities, and I did not read those standards for this article, so I am not describing room-by-room requirements here. Ask the tenant to show you the standards that apply to their facility.
Regulation 1093, as amended by O. Reg. 260/22, fills in the mechanics:
- Facility director (s.10): for a facility other than a temporary one, the owners of the facility or the partners in the practice designate a facility director, who oversees operation under the Act, the regulation and the Council’s standards, and whose name and contact information must be clearly and publicly displayed at the facility.
- Who applies (s.11(2)): the facility director submits the application to the College, holds a general or restricted licence consistent with the certificate sought, practises at that facility, and gives a written undertaking that only members will have responsibility for and control over the clinical and professional aspects of the services.
- Term (s.12(1)): a certificate expires five years after it is issued or renewed, unless the Registrar sets an earlier date or an event in s.12(2) ends it sooner.
- Early expiry (s.12(2), all four events): the facility, or the stationary element of a facility with a mobile element, is relocated; the facility no longer has a facility director; it no longer has any member meeting s.11(2) paragraph 3; or it no longer has any member who has given the s.11(2) paragraph 6 undertaking.
Two words are worth searching for in these texts. “Landlord” does not appear in the Act or in Regulation 1093. “Lease” appears once, in the regulation’s conflict-of-interest rules, which I come back to in the lease section. The regulation also refers to “the owners of the veterinary facility” without defining owner, so if a tenant asks you to sign anything that goes with an accreditation application, have your lawyer read it before you do.
What the certificate ties to your unit
Read the certificate rules from a landlord’s chair and three things stand out. The certificate names a location (Reg. 1093, s.15(1)). It names services and confines the practice to them (s.15(2)). And relocation is one of the events that ends it early (s.12(2)). Put together, the certificate is a document about this clinic at this address doing these things.
For a fixed facility, the holder must post the certificate visibly in the facility (s.15(3)(a)). The Act also requires the Registrar to keep directories showing each holder, the location and class of the facility, the conditions and limitations, the expiry date and any revocation or suspension (s.19(2)), and anyone may inspect those directories during normal business hours (s.19(3)).
Regulation 1093, s.13, lists six events the holder must report to the College in writing, immediately: a change to the facility’s name; a change in the type of species treated; a change in the scope of veterinary services; relocation of the facility or of a stationary element of a facility with a mobile element; a change in the identity of the facility director; and the facility no longer having any member who meets s.11(2) paragraph 3.
The College also has a way back in during the term. Under s.22 of the Act, if the Registrar has reasonable grounds to believe the facility no longer meets the requirements, is being used in contravention of the certificate’s terms, or is being used as a facility of another class, the certificate can go to the Accreditation Committee, which after a hearing may revoke it, suspend it for a stated period of not more than two years, suspend it until compliance is shown, change the class, or add conditions.
Document three: Regulation 861, the X-ray rule that does apply
A clinic with radiography raises a question that sounds like it belongs to the Healing Arts Radiation Protection Act. It doesn’t. That Act defines an X-ray machine as a device for “the irradiation of a human being” for a therapeutic or diagnostic purpose, and its registration duty in s.4(1) is framed the same way. An X-ray source used in an animal clinic is a workplace matter, covered by Reg. 861 (X-ray Safety) under the Occupational Health and Safety Act.
According to Regulation 861, s.5(1), an X-ray source shall not be used at a workplace unless the employer who has possession of it is registered with a Director. Section 6(1) adds that a source shall not be installed or used in a permanent location unless an application for review, together with plan location drawings, has been reviewed by and is acceptable to an inspector.
The drawings are where a landlord’s building shows up. Under s.6(4), they must show, among other things, the proposed location of the source, the use of rooms or areas adjacent to it both horizontally and vertically, and the type and thickness of the shielding installed or to be installed on the boundaries of that location. And under s.6(7), after installation, a change in the use of adjacent rooms or areas, or in any shielding, that may increase a worker’s exposure means the source can’t be used until an inspector has reviewed and accepted the change.
These duties sit with the employer, which is the clinic. What they mean for you is practical: shielding work is part of the tenant’s fit-out, it involves your walls and possibly your floor or ceiling, and the drawings describe your neighbouring units.
⚠️No X-ray source goes in before acceptance. Under Reg. 861, s.6, an X-ray source can’t be installed or used in a permanent location until the installation review application and plan location drawings have been reviewed and accepted by an inspector, and once accepted, it may be installed only in accordance with the accepted application and drawings. If your fit-out schedule assumes the room is finished and the equipment is in on opening day, build that review into the timeline.
Document four: the lease, read against the other three
None of the texts above tells you what to put in a lease. They do tell you which questions the lease has to answer:
- The use clause. What words describe the permitted use, and do they match the zoning term and the services on the certificate? (More on this below.)
- Accreditation as a condition. Is the lease conditional on the clinic obtaining a certificate of accreditation for your address, by what date, and what happens if it doesn’t arrive?
- Fit-out. Who designs and pays for shielding, medical gas, ventilation and sound separation; who approves the drawings that go to the X-ray inspector; and whether any of it must be removed and the unit restored at the end.
- Operations. Medical waste storage and pickup, odour, and noise from animals, especially next to residential or office neighbours.
- Term against certificate. A certificate runs for up to five years and is then renewed; how does that line up with your initial term and renewal options?
- Rent structure. If you are thinking about percentage rent, read Regulation 1093, s.42(2)(a) first. It says a member has a conflict of interest where the member, a related person, or an employee or employer of the member enters into “any agreement, including a lease of premises,” under which an amount payable is related to the member’s fees, net revenue or any other measure of financial performance. Having a conflict of interest is listed as professional misconduct in s.17(1). The exceptions in s.42(3) are for arrangements among members. Whether a given clause is caught is a question for the tenant’s lawyer and yours.
💡 My own view is that the use clause is the one line of the lease that has to speak two languages at once. The certificate confines the clinic to the services it lists (Reg. 1093, s.15(2)), and the College expects to hear when the species treated or the scope of services changes (s.13). Write the clause too narrowly, say small-animal care for cats and dogs, and a change the clinic simply reports to the College becomes a change it needs your consent for. Write it too loosely, say any animal-related use, and you may be granting something the zoning term Veterinary Hospital doesn’t cover and the certificate doesn’t allow. I’d want the clause anchored to the by-law’s defined use and to the services authorized by the clinic’s certificate as it stands from time to time, with any extra use, such as grooming or boarding, named separately and checked separately against the zoning.
Before you sign: who answers what
Sort the questions by who can actually answer them. Each one traces to a document discussed above.
- ☐Name the veterinarian who will be facility director for your address (Reg. 1093, s.10).
- ☐Show the species and services they will apply to have listed on the certificate (s.15(2)).
- ☐Share the Council standards that apply to their facility and how they plan to meet them in your unit.
- ☐Confirm whether they will install an X-ray source, and their plan for registration and the installation review under Reg. 861, ss.5–6.
- ☐If they are moving from another location, confirm they will apply for a certificate at your address, since relocation ends the old one (s.12(2)).
- ☐Confirm the zone label that applies to the lot, including the letters in it.
- ☐Confirm whether Veterinary Hospital is a permitted use in that zone at this address.
- ☐Ask whether a site-specific exception applies to the property.
- ☐Check which parking zone the lot is in, for the Table 200.5.10.1 maximums.
- ☐Draft the use clause around the zoning term and the certificate’s listed services.
- ☐Set the accreditation condition: deadline, evidence, and what happens if it is not met.
- ☐Allocate shielding, ventilation, medical gas and sound-separation work, and restoration at the end of the term.
- ☐Set rules for medical waste, odour and noise.
- ☐Have both lawyers review any percentage-rent wording against Reg. 1093, s.42(2)(a).
- ☐Decide whether the tenant must copy you on s.13 notices about species or scope changes.
- Veterinarians Act, R.S.O. 1990, c. V.3 (Ontario e-Laws, with repeal Note)
- R.R.O. 1990, Reg. 1093 (General), last amended by O. Reg. 260/22
- Healing Arts Radiation Protection Act, R.S.O. 1990, c. H.2
- R.R.O. 1990, Reg. 861 (X-ray Safety), under the Occupational Health and Safety Act
- City of Toronto Zoning By-law 569-2013, Chapters 30, 40, 50, 60, 200 and 800 (Version Date July 31, 2024, City-wide amendments up to April 30, 2026)
Renting a Unit to a Dog Daycare, Boarding Kennel or Groomer in Toronto: Zoning, Noise and the Lease Clauses to Check →Leasing to a Medical or Dental Clinic: How CPSO’s Out-of-Hospital Premises Standards Dictate Your Build-Out →Leasing Retail Space to a Pharmacy in Ontario: Accreditation, Rent Terms and Lease Clauses →First-Time Renter Guide →
Frequently Asked Questions
Does a mobile or temporary veterinary service need its own certificate?
Yes. The Veterinarians Act defines a veterinary facility as a building, land or vehicle used as a place in or from which to practise, and s.15 requires a certificate for any of them. Regulation 1093 has a separate certificate for a temporary facility (s.14), limited to the period on the certificate and no longer than 30 days (s.15(2)); a temporary or mobile facility must make its certificate available to anyone on request rather than post it (s.15(3)(b)).
What happens to the certificate if the facility director leaves?
If the clinic names a new director, the holder must notify the College in writing immediately of the change in the facility director’s identity (Reg. 1093, s.13). If the facility ends up with no facility director at all, the certificate expires early under s.12(2), paragraph 2. For a landlord, that is the moment to ask the tenant who the new director is.
How long does a certificate of accreditation last?
Up to five years from issue or renewal (Reg. 1093, s.12(1)). It can end sooner if the Registrar issued it with an earlier expiry date, or if one of the four s.12(2) events occurs: the facility is relocated, there is no facility director, or there is no longer a member who meets the licence-and-practice or undertaking requirements in s.11(2).
Can the College suspend a clinic’s certificate, and for how long?
Yes. Under s.22 of the Veterinarians Act, the Registrar can refer a certificate to the Accreditation Committee, which holds a hearing. If it finds the allegation valid, it may revoke the certificate, suspend it for a stated period not exceeding two years, suspend it until compliance with specified standards is shown, change the class of facility, or impose conditions and limitations, alone or in combination.
Is there a minimum parking requirement for a veterinary hospital in Toronto?
The Tier 2 row of Table 200.5.10.1 in By-law 569-2013, which includes Veterinary Hospital, is written as maximums only: 0.8 spaces per 100 square metres of gross floor area in Parking Zone A, 1.0 in Parking Zone B and 3.5 elsewhere in the City. Other parts of the parking chapter and any site-specific exception were not checked here, so confirm for the address.
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