Bill 67 amends Quebec’s Professional Code and related Acts to give professional orders new tools to manage access to professions and to broaden certain activities in health and social services. Key changes let orders issue special permits (limited-authority licences) and allow the minister to authorize orders to issue special authorizations during declared emergencies; the bill also permits professionals to practise within non-profit legal persons, creates pilot-project authority, and revises who may diagnose mental disorders.
The Pharmacy Act is amended to expand pharmacists’ activities—including an explicit power to prescribe—and to assign new advisory and inquiry duties to the Ordre des pharmaciens.
These changes reallocate discretion from blanket statutory restrictions to order-specific rules and ministerial directions. For employers, professional orders, insurers and health institutions this means new regulatory design work (regulations, training, oversight), potential changes to service delivery models (non-profit practice sites, pharmacist prescribing), and transitional uncertainty while implementing regulations and pilot projects.
At a Glance
What It Does
The bill authorizes professional orders to issue temporary restrictive and special permits that can limit scope, title and conditions of practice; authorizes ministerial emergency orders allowing orders to issue special authorizations; permits professionals to practise within non-profit legal persons under new regulatory conditions; and expands scope for several health professions by replacing many statutory references from “assess” to “diagnose.” It also adds pharmacist prescribing and new Ordre des pharmaciens powers.
Who It Affects
Professional orders (notably pharmacists, nurses, psychologists, speech therapists, sexologists, regulators for advocates and notaries), non-profit service providers and health institutions, the Office des professions, insurers and provincial ministries that oversee health regulation and program coverage.
Why It Matters
The bill shifts how Quebec controls access and delegation of professional activities—from uniform statutory bans toward order-level permits and emergency authorizations—creating faster, more flexible workforce options but requiring significant regulatory work, training standards and oversight to manage risks and insurer/program adjustments.
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What This Bill Actually Does
Bill 67 gives professional orders new, granular tools to control who performs which professional activities. Boards can now issue “special permits for certain professional activities” to candidates who cannot or will not meet all standard conditions; those permits can limit which activities the holder may perform, set titles and initials the holder may use, and be modified after the holder completes training.
Separately, the Code clarifies that the Commissioner for Admission and designated staff cannot be compelled to testify about information obtained in the exercise of their duties, and extends immunity protections to the Commissioner and arbitration councils.
The legislation creates an emergency fast-track: during a declared emergency the Minister may authorize an order to issue special authorizations to categories of persons to perform activities normally reserved to order members, and those ministerial orders come into force immediately without the usual publication requirements. It also authorizes government-run pilot projects for up to two years (extendable one year) where the Government can set standards that prevail over inconsistent statutory or regulatory provisions, and requires an Office des professions evaluation within six months of project end.A major structural change allows professional practice inside non-profit legal persons.
The Code now treats non-profits alongside partnerships and companies for governance, membership proportions, director composition and transfer restrictions; it also requires that professional fees charged within such non-profits not exceed a “moderate cost.” For joint-stock companies and non-profits the Code gives orders authority to set proportions of voting shares or members who must be order members and to regulate transfer and voting restrictions tied to membership status.On clinical scope, the bill systematically replaces statutory language about “assessment” with “diagnosis” across multiple professions and regulations (psychologists, speech-language pathologists, career counsellors, sexologists and nurses), and explicitly authorizes pharmacists to prescribe medications while revising their defined field of practice. The Ordre des pharmaciens gains a duty to advise Ministers or Santé Québec and to conduct inquiries into pharmaceutical care in institutional centres.
Finally, the bill contains multiple transitional rules and expedited regulatory approval mechanisms to bring the new pharmacist activities and non-profit practice model into force quickly.
The Five Things You Need to Know
Boards of professional orders may issue a special permit that limits what activities a permit-holder can perform and prescribe titles, abbreviations and conditions for those activities.
In an emergency, the Minister may authorize an order to issue special authorizations to categories of persons; such ministerial orders take effect immediately and are exempt from the Regulations Act publication and timing rules.
The Government may authorize pilot projects for up to two years, extendable by one year, and set standards for pilots that override inconsistent provisions of existing Acts or regulations; the Office des professions must report within six months after a pilot ends.
The Pharmacy Act now expressly allows pharmacists to prescribe medications and directs the Ordre des pharmaciens to advise the Minister or Santé Québec and to conduct inquiries into pharmaceutical care in institutional centres.
Professionals practising within non-profit legal persons are now regulated: orders can set required proportions of members and directors, restrict transfers/voting, and a member must not charge fees that together exceed a ‘moderate cost’ for services delivered in such entities.
Section-by-Section Breakdown
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Commissioner confidentiality and testimonial protection
The bill adds an explicit bar preventing the Commissioner for Admission — and persons the Commissioner designates — from being compelled to testify about information obtained while performing admission duties, and from producing documents containing that information. Practically, this shields admission investigations and sensitive materials from court disclosure. It shortens avenues for third parties seeking evidence from that office and centralizes sensitive information within the administrative process.
Special permits and emergency special authorizations
These provisions authorize boards to issue special permits to applicants who do not meet standard criteria but renounce certain conditions the order considers valid; boards define the scope, conditions and titles attached to those permits and may later expand permitted activities when the holder completes training. Separately, section 42.5 gives the Minister the power, during an emergency, to permit orders to issue special authorizations to categories of persons; those ministerial authorizations bypass normal publication requirements, creating a fast-track delegation mechanism designed to expand workforce capacity quickly in crises.
Non-profit legal person framework for professional practice
The Code is amended to treat non-profit legal persons like partnerships and companies for the purpose of practising professions. Orders can now make regulations fixing the proportion of members and directors who must belong to the order, conditions on share transfers or membership rights, and governance rules for non-profits hosting professional activity. This moves the law from ad-hoc by-laws to a consistent regulatory framework and imposes membership/composition requirements that non-profits must meet to host professional services.
Fee limitation inside non-profit legal persons
A new provision requires members who practise inside a non-profit legal person not to allow professional fees or costs charged to clients to exceed a ‘moderate cost’ in aggregate, though disbursements may be reimbursed. This is a novel, statutory pricing constraint aimed at preserving affordability in non-profit settings but leaves ‘moderate cost’ undefined, placing the onus on orders or regulations to clarify measurement and enforcement.
From assessing to diagnosing: expanded diagnostic authority
The bill systematically replaces statutory language about ‘assessment’ with ‘diagnosis’ in multiple profession-specific provisions and regulations (career counsellors, psychologists, speech-language pathologists, sexologists, nurses). For nurses, the change is explicit: where they could previously ‘assess’ mental disorders (except intellectual disabilities), they may now ‘diagnose’ them subject to regulatory conditions and supervision. That semantic shift raises the substantive bar for training, documentation and professional liability tied to diagnostic authority.
Expanded pharmacist scope and board duties
The Pharmacy Act’s definition of pharmacy practice is revised to emphasize assessing health and medication management, and the list of activities reserved to pharmacists now includes prescribing medication, substituting medications, administering medications where regulated, and renewing prescriptions under conditions set by regulation. The Ordre des pharmaciens gains an explicit duty to advise the Minister or Santé Québec proactively and to conduct inquiries into pharmaceutical care in institution-run centres, increasing its oversight role over publicly funded settings.
Pilot-project authority and transitional/regulatory fast-tracks
The Government can now authorize pilot projects that override inconsistent statutory or regulatory provisions for up to two years (plus a one-year extension) and set standards and obligations for those pilots; the Office des professions must evaluate pilots and report to the Minister. Transitional provisions also expedite approval and coming-into-force for regulations tied to pharmacist activities and non-profit practice, including special drafting and publication timing rules that shorten normal regulatory scrutiny windows and affect how existing regulations are referenced until new rules are in place.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Patients and community service users — will likely see faster access to certain services when orders use special permits, emergency authorizations, pharmacists prescribe, and professionals practise in community non-profits.
- Professional orders — gain flexible tools to manage workforce shortages and tailor permitted activities through special permits, ministerial emergency authorizations and rules for non-profit practice.
- Non-profit service providers and community clinics — can host regulated professionals under a clear legal framework, enabling alternative delivery models and potential partnerships with orders and institutions.
- Pharmacists and trained allied health professionals — receive expanded procedural authority (prescribing, substitution, diagnosis for certain professions) that can broaden their clinical role and revenue lines.
- Government health programs — gain a legal mechanism (pilot projects and emergency authorizations) to test or scale workforce innovations rapidly during crises or reform initiatives.
Who Bears the Cost
- Professional orders — must draft new regulations, set training and oversight conditions for special permits, govern non-profit engagement rules and enforce the ‘moderate cost’ fee limit, increasing regulatory and operational workload.
- Health institutions and insurers — need to update coverage policies, billing rules and liability frameworks to reflect pharmacist prescribing, redistributed diagnostic authorities and services provided within non-profits.
- Individual professionals — face new competency, documentation and liability expectations when diagnosing or prescribing; professionals using special permits will operate under narrower scopes and oversight.
- Office des professions and Ministries — will absorb evaluation, consultation and expedited approval duties for pilot projects and regulatory changes, adding administrative and review obligations.
- Small non-profits — must meet membership, governance and director-composition thresholds set by orders, and reconcile the statutory ‘moderate cost’ rule with operating budgets and funding models.
Key Issues
The Core Tension
The bill trades centralized, uniform statutory limits for decentralized, faster tools (special permits, ministerial emergency powers and pilot projects) designed to increase workforce flexibility and access to care—but doing so concentrates implementation power with professional orders and the executive, creating a dilemma between rapid service expansion and the need for clear, uniform safeguards on competence, accountability and patient safety.
The bill increases regulatory flexibility but shifts several critical choices to orders, ministers and later regulations. That approach speeds adaptation to workforce needs but leaves crucial details — training standards, definitions (for example, what counts as a ‘moderate cost’), supervision requirements and liability rules — to subordinate instruments.
The most consequential operational issues therefore depend on how orders and the Government use their new authorities: a permissive regulatory response could broaden access quickly but raise safety and insurance costs; a conservative approach could blunt the bill’s intended expansion benefits.
Emergency authorizations and pilot projects override normal publication and some regulatory safeguards, creating accountability and transparency challenges. Immediate entry into force for emergency orders and the Government’s power to set pilot standards that prevail over statutes reduce the usual opportunity for stakeholder input and judicial review during those periods.
Meanwhile, extending testimonial immunity to the Commissioner and arbitration councils protects internal processes but narrows external oversight avenues, which could frustrate parties seeking discovery for civil claims. Finally, the conceptual shift from “assessment” to “diagnosis” is not merely semantic: diagnosing has higher training and liability implications and will require clear alignment between curricula, clinical supervision, regulatory standards and malpractice coverage.
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