The Medical Profession Amendment Act, 2026 expands the College of Physicians’ enforcement toolkit: it makes it an offence to practise or “profess” to practise medicine (and certain allied roles) unless registered or practising through a registered professional corporation, creates new injunction and court-ordered information powers, increases monetary penalties and makes corporate officers criminally accountable for corporate offences. The Act also explicitly allows the college to prosecute offences and permits the provincial government to contribute to enforcement costs.
The bill matters because it shifts enforcement from internal disciplinary processes toward civil and quasi-criminal court remedies, broadens the executive power to define what counts as ‘practising medicine,’ and moves financial penalties and fines into the college’s control (via related amendments to The Regulated Health Professions Act). That combination raises practical questions for regulated practitioners, professional corporations, and entities offering overlapping health services about compliance risk, exposure to injunctions, and potential provincial support for litigation costs.
At a Glance
What It Does
The Act prohibits practising or professing to practise medicine, podiatric surgery or physician assistant work unless registered or operating through a registered professional corporation, and creates sections authorizing injunctions, court orders compelling information, and steeper fines with officer liability. It also authorizes the Lieutenant Governor in Council to make broad regulations that can define or exclude activities from ‘practising medicine.’
Who It Affects
Licensed physicians, physician assistants, podiatric surgeons, professional corporations, unlicensed providers offering overlapping services (including non-physician clinicians and digital health vendors), and the College of Physicians which gains new prosecutorial and enforcement authority. Courts and legal counsel will also see more applications from the college.
Why It Matters
The bill centralizes enforcement power with the college and the courts, increases financial exposure for individuals and corporations, and gives government broad regulatory delegation to define scope and exemptions—potentially reshaping how non-physician care is delivered and policed in Saskatchewan.
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What This Bill Actually Does
The Act tightens the definition of unauthorized practice and makes it actionable in court. It requires that anyone who practises or even ‘professes’ to practise medicine, or who offers services as a podiatric surgeon or physician assistant, must be either individually registered and licensed by the college or practising through a professional corporation that is itself registered and permitted under the Act.
That means non-registered individuals and unregistered corporate arrangements can be targeted directly by the regulator through court remedies.
To enforce those rules the bill gives the college a civil toolbox: it can seek injunctions (including interim relief) to stop people from practising without proper credentials, and the court may enjoin conduct that breaches the Act or the college’s bylaws and standards—even where those breaches might otherwise attract only disciplinary penalties. The Act also allows the court, on application by the college and on terms it decides, to compel a person to produce records or to attend and answer questions; those applications can be made without notice or on short notice.The penalties for contravention are significantly increased and clarified.
The Act sets maximum summary fines for individuals and corporations (with higher amounts for repeat offences), and it makes corporate officers and directors criminally liable where they directed or acquiesced in an offending corporation’s conduct. The college may itself prosecute offences under the Act, and the government may contribute financially to investigation and application costs.
The bill also changes limitation rules: prosecutions for the new offences must be started within two years of discovery, with special rules for continuing offences and a transitional one-year bar for pre-amendment contraventions.Finally, the Lieutenant Governor in Council gains express regulatory authority to define or limit the meaning of terms in the Act and to carve out exemptions from what counts as ‘practising medicine’ or an offence under the Act. Parallel amendments to The Regulated Health Professions Act make fines and penalties the property of the college, add similar court-ordered evidence powers, raise maximum fines for health professional corporations, and authorize colleges to prosecute under that statute as well.
The Five Things You Need to Know
Section 79.1 makes it an offence to practise or ‘profess to practise’ medicine, or to practise as a podiatric surgeon or physician assistant, unless individually licensed by the college or practising through a registered professional corporation under section 37.4.
Section 79.2 lets the college seek injunctions (including interim injunctions) to stop unlicensed practice and to enjoin conduct that contravenes the Act, bylaws, code of ethics or standards, even where disciplinary penalties also apply.
Section 79.3 allows courts, on application by the college (including without notice), to order persons to produce records or attend and answer questions when those records or answers are necessary for an investigation or enforcement application.
Subsection 80(1) sets summary-fine ceilings: individuals face up to $25,000 for a first offence and $50,000 for repeat offences; corporations face up to $50,000 for a first offence and $100,000 thereafter; officers who directed or acquiesced can be convicted and fined under the same individual penalty scheme.
The Act authorizes the college to prosecute offences (section 80.1), permits the government to contribute to enforcement costs, and (via Part 3 changes) makes all fines and penalties levied by a college the college’s property and raises comparable fine ceilings in The Regulated Health Professions Act.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Unauthorized practice prohibition, injunctions, and compelled information orders
Section 79.1 states the core prohibition: no one may practise or profess to practise medicine, or practise as a podiatric surgeon or physician assistant, unless individually registered and licensed or operating through a registered professional corporation. Section 79.2 gives the college access to the courts to seek injunctions to stop such conduct and to enjoin acts that breach the Act or the college’s bylaws and standards. Section 79.3 lets a court, on the college’s application and on terms it sets, order production of records and compel an interview or attendance to answer questions; the application can be made without notice. Practically, these provisions let the college move from administrative discipline to civil court remedies and to obtain evidence through court orders designed to support enforcement or litigation.
Standards for what counts as practising and expanded offence language
Amendments to section 79 replace the phraseology about ‘holding oneself out’ with ‘professing to be,’ broadening the scope of prohibited representations. Section 80 is revised to qualify certain prohibitions as ‘subject to the regulations’ (enabling later carve-outs) and to explicitly criminalize practising in contravention of section 79.1, updating pronouns for clarity and replacing prior penalty language with explicit maximum fines and repeat-offence escalators for individuals and corporations. Operationally, the office-holder and corporate liability language increases the practical risk profile for corporate entities and their directors.
College prosecution powers, evidentiary standard and limitation rules
Section 80.1 authorizes the college or its designate to prosecute offences under the Act and allows the government to subsidize investigation and court application costs. Section 80.2 lowers the proof hurdle by permitting a single act of unauthorized practice to establish an offence. The replacement section 81 limits prosecutions to within two years of discovery, defines ‘discovery’ for the college, treats ongoing offences as daily contraventions, and includes a transitional one-year limit for contraventions that occurred prior to Part 2 coming into force. Together, these changes shorten and clarify temporal exposure while enabling relatively low-threshold proof and delegated prosecutorial action.
Broad regulation‑making power to define or exempt practice
Section 96.1 authorizes the Lieutenant Governor in Council to define, enlarge, limit or exempt terms used in the Act, specifically permitting exemptions from the meaning of ‘to practise medicine’ and from conduct constituting an offence. This grants the executive wide discretion to calibrate the Act’s reach—potentially excluding specific allied practices, technologies, or settings from the statutory prohibition—but leaves those choices to regulation rather than statute, shifting key scope decisions to the government’s regulatory process.
Parallel enforcement changes for other regulated professions and financial control of fines
The Regulated Health Professions Act is amended so that all fees, fines and penalties levied by a college become the college’s property, and colleges gain the explicit ability to obtain injunctions, interim relief and compelled information orders similar to those in the medical‑profession amendments. The Act raises penalty ceilings for health professional corporations and mirrors officer liability language; it also authorizes colleges to prosecute offences under that Act. These changes align enforcement across regulated professions and centralize fine revenue with the colleges.
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Explore this topic in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Registered physicians and regulated practitioners — they gain stronger legal tools to stop unlicensed competitors and clearer statutory protection for titles and restricted acts.
- The College of Physicians (and other colleges under the Regulated Health Professions Act) — receives new injunctive and information‑gathering powers, prosecutorial authority, and ownership of fines, increasing its ability to enforce standards and to fund enforcement.
- Patients and patient‑safety advocates — benefit from stronger mechanisms to remove or halt unregulated or misrepresenting providers quickly through court orders.
Who Bears the Cost
- Unlicensed providers and businesses offering overlapping health services (including some digital health vendors and alternative practitioners) — face immediate legal risk of injunctions, evidence orders and heavy fines if their services fall within the expanded definitions.
- Professional corporations and their officers/directors — face higher fines and personal liability exposure where officers directed or acquiesced in offending corporate conduct, increasing compliance and governance costs.
- Small practices and allied health professionals working in interdisciplinary settings — risk inadvertent entanglement if the executive defines ‘practising medicine’ broadly, creating compliance burden and possible chilling of collaborative models.
Key Issues
The Core Tension
The bill balances two legitimate aims—protecting patients by aggressively stopping unlicensed or unsafe practice and preserving access to innovative, non‑physician care—but does so by giving the regulator and executive broad tools that can shut down borderline or novel services quickly; the central dilemma is how to empower rapid enforcement without creating regulatory overreach, procedural unfairness, or chilling effects on lawful health delivery.
The Act deliberately shifts enforcement from internal discipline to judicial relief, which speeds shutdowns of suspected unauthorized practice but also increases the risk of preemptive court action. Because courts can grant injunctions and compel evidence on applications made without notice, there is a real risk of surprise orders that disrupt lawful activity pending litigation.
The bill attempts to mitigate stale prosecutions with a two‑year discovery rule, but treats continuing offences as daily contraventions—exposing ongoing operators to repeated daily enforcement actions and cumulative liability.
The Lieutenant Governor in Council’s authority to define or exempt the meaning of ‘practise medicine’ delegates a pivotal substantive decision to regulation. That delegation allows flexible, technology‑sensitive policymaking, but it also creates uncertainty for non‑physician providers who must await regulatory clarification.
The college’s new power to both investigate and prosecute raises institutional questions: regulators acting as prosecutors may face perceived conflicts between public protection and institutional incentives (now reinforced by retaining fine revenue). Finally, officer liability and steep corporate fines will push entities to tighten governance, but could also deter innovative care models or drive services out of province unless regulations and guidance clearly delineate lawful practices.
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