Offering Botox® or dermal fillers in your dental practice is no longer unusual. Across Canada, more dentists are pursuing certification and integrating these services into comprehensive oral and maxillofacial treatment plans. But there is a dimension of compliance that often gets far less attention than the clinical training itself: the documentation and photography requirements that regulatory bodies expect you to maintain — and be able to produce on demand.
We reviewed the published standards from dental regulatory authorities in nine provinces — British Columbia, Alberta, Saskatchewan, Manitoba, New Brunswick, Nova Scotia, Newfoundland and Labrador, Ontario and Quebec — and read every page. The picture that emerges is consistent in its intent but surprisingly varied in its specifics. Some of these details are genuinely easy to miss, and missing them can put your certification at risk.
Here is what each province requires, including the details that don’t always make it into the summary version.
The universal baseline: what every province expects
Most provinces requires these core items in your patient chart for any neuromodulator or dermal filler treatment:
- Complete medical history and clinical examination
- Documented review of patient motivation and expectations
- Informed consent (risks, benefits, complications, alternatives)
- A comprehensive treatment plan
- Product type, dosage, and specific anatomical injection sites
- Pre-operative and post-operative photographs
- Any adverse reactions or unexpected events
That list is the floor, not the ceiling. What each province adds on top of it is where practitioners need to pay close attention.
That last item – photographs – appears in most of the documents we reviewed. But calling it a “requirement” understates how seriously some provinces take it, and how specifically they define it.
“Records, such as pre and post-treatment photographs, which are above and beyond usual diagnostic records, are mandatory when providing these levels of treatment.”
That language comes directly from Alberta’s Standard of Practice. It’s a notable framing: photographs aren’t incidental documentation — they’re a distinct mandatory category that goes beyond your usual clinical records.
How Botox® record requirements differ across provinces
While the core list is consistent, the details vary — sometimes significantly. Here’s how each jurisdiction approaches records and photography compliance.
British Columbia (The BC College of Oral Health Professionals)
While BCCOHP outlines general expectations around safe, ethical, and competent patient care, the college does not currently publish specific Botox® or facial injectable treatment guidelines for dentists.
Alberta (College of Dental Surgeons of Alberta) – updated May 2026
- Pre & post photos mandatory at all levels
- 20 documented treatments on different patients required before advancing levels, with pre/post photos for each, completed over a minimum six-month period at each level
- Multiple treatments on the same patient count toward the 20-case minimum, provided they are separated by at least three months
- Patient identifiers and treatment start/end dates must be maintained in personal records for each 20-case set
- All patient records available at all times on CDSA’s request
- Dentists treating patients in temporary settings (spas, salons, private residences, etc.) must carry emergency drugs including hyaluronidase for dermal filler cases, ensure an AED is on site, and have their registration and FETAP certificates physically present at the treatment location
Saskatchewan (College of Dental Surgeons of Saskatchewan)
- Pre-treatment photos mandatory for cosmetic cases; therapeutic cases at dentist’s discretion
- Specific injection sites documented with site-specific dose records for every injection point
- Specific neuromodulator brand name, lot number, and expiry date recorded for every case
- Informed consent must include estimated costs (unique requirement)
- All records available at all times on CDSS request
- Unique: cost disclosure + lot/expiry
Manitoba (Manitoba Dental Association)
- Separate contemporaneous log required beyond the patient chart
- Neuromodulator log: patient name, purpose, product type and dosage
- Dermal filler log: patient name, purpose, filler type, concentration, and specific anatomical locations administered
- Log available to Registrar on request at any time
- Pre & post-operative photographs in patient chart
- Unique: separate log required
Ontario (Royal College of Dental Surgeons of Ontario)
The RCDSO does not publish Botox specific patient record-keeping requirements. Instead, dentists providing botulinum toxin treatments are expected to comply with the College’s broader dental record-keeping guidelines.
Quebec (Ordre des dentistes du Québec)
- Calibrated photography required for all aesthetic treatments (standardized equipment, controlled lighting, calibrated markers, frontal/profile/three-quarter angles)
- Product name, lot number, expiry date, concentration, needle gauge, and dose per injection site recorded
- Written consent for publication of patient photographs for teaching purposes (if applicable)
- Training declared in ODQ continuing education portal
- Course plans and attestations retained for professional inspection
- Structured 13-section file template required
- Minimum 20 patients treated before advancing levels
- Most detailed requirements in Canada
New Brunswick (New Brunswick Dental Society)
- Separate contemporaneous log required beyond the patient chart
- Neuromodulator log: patient name, purpose, product type and dosage
- Dermal filler log: patient name, purpose, filler type, concentration, and specific anatomical locations
- Informed consent must include estimated costs
- Appropriate antidotes must be present when performing injections
- Log and competency evidence available to Registrar on request
- Unique: antidotes on-site required
Nova Scotia (Provincial Dental Board of Nova Scotia)
- Pre & post photos mandatory; records subject to random audit from Level 2 onward
- 20 documented Level 2 cases (including the 6 from training) before advancing to Level 3
- 20 documented Level 3 cases before advancing to Level 4
- Records available at any time; random audits may occur
- Random audit: explicit
Newfoundland & Labrador (Newfoundland & Labrador Dental Board)
- Pre & post photos mandatory; records subject to random audit at Levels 2, 3, and 4
- 20 case minimum at Level 2 (including 6 from training) before Level 3
- 20 case minimum at Level 3 before Level 4
- Licensed dental assistants may assist with formulating/dispensing agents under direct supervision
- Random audit: explicit
Quebec’s calibrated photography standard: the most detailed in Canada
Quebec stands apart in one specific area: the Ordre des dentistes du Québec’s guide is the only document that defines exactly what “photographs” means. The term used is calibrated photography, and it comes with a protocol:
- Standardized camera and fixed focal length
- Controlled, consistent lighting conditions
- Calibrated markers (measurement scales or reference points)
- Fixed patient positioning
- Multiple angles — frontal, profile, and three-quarter view
The intent is clear: photographs must be reproducible and consistent enough to serve as a genuine clinical reference for before-and-after comparison, ongoing follow-up, and regulatory review. An ad hoc smartphone photo taken in variable lighting doesn’t meet this standard.
While other provinces don’t use the term “calibrated,” the underlying expectation is the same — your photos need to be good enough to demonstrate treatment outcomes and support your records in the event of a complaint or audit.
The separate log requirement: Manitoba and New Brunswick
Two provinces go a step further than simply requiring good patient charts. Both Manitoba and New Brunswick require dentists to maintain a separate contemporaneous log of all neuromodulator and dermal filler treatments — distinct from and in addition to the patient chart itself. This log must include the patient’s name, the purpose of the treatment, and the product type and dosage used, and it must be available to the Registrar on request at any time.
A separate log is not just an administrative formality — it’s a population-level record of your neuromodulator practice that regulators can review independently of individual patient charts. If your log and your charts don’t tell the same story, that discrepancy itself becomes a compliance issue.
Random audits and the audit readiness mindset
Nova Scotia and Newfoundland both state explicitly in their standards that practitioners holding certificates under these standards may be subject to random audit by the dental board. The language is direct: holders must maintain accurate treatment records and may be reviewed at any time.
Alberta and Saskatchewan frame the same expectation slightly differently — records must be available whenever requested by the regulatory body — but the practical implication is identical. You cannot reconstruct records when an audit request arrives. Everything must be current, complete, and accessible before you need it.
This is not a theoretical risk. As these services become more common in dental practices, regulatory bodies have more reason — and more capacity — to conduct oversight. The dentists best positioned for scrutiny are those who never had to scramble to find a photo or piece together a treatment timeline.
The 20-case requirement and what documentation actually supports it
Several provinces — Alberta, Nova Scotia, and Newfoundland prominently among them — require dentists to document at least 20 Botox® treatments before advancing from one certification level to more advanced levels. In Alberta, this must be completed over a minimum six-month period at each level. Multiple treatments on the same patient count toward the minimum, but only if they are separated by at least three months — meaning genuine clinical breadth across your patient base is still required. The documentation must include pre- and post-treatment photographs for each case.
In practice, this means your records aren’t just a compliance obligation — they’re your evidence of clinical experience. A dentist who treated 20 patients but kept only cursory notes and inconsistent photos cannot adequately demonstrate the competency that advancing to the next level requires. The regulatory body reviewing the application will be looking at the quality of your documentation as a proxy for the quality of your practice.
What good compliance infrastructure looks like in practice
Taken together, what these provincial standards describe is a documentation ecosystem that needs to work seamlessly across your entire Botox® and injectable practice: standardized pre- and post-treatment photography, detailed per-treatment records tied to specific patients, a separate searchable log of all treatments, product traceability (brand, lot number, expiry), and ongoing CE tracking — all available on demand, at any time, for any regulator who asks.
Managing that across a paper chart system, a separate spreadsheet log, a folder of photos, and a binder of CE certificates is possible. It’s also exactly the kind of fragmented system that creates gaps — a photo missing from one patient’s file, a log entry that doesn’t match the chart, a record that can’t be located when an audit request arrives.
The practices that navigate compliance most confidently are those where this infrastructure is built into how they work — not assembled after the fact. When your clinical workflow automatically captures what regulators require, in the format they expect, and stores it somewhere accessible and organized, compliance stops being a burden and becomes simply how you practice.
That’s exactly the kind of seamless, purpose-built experience that Facetec is designed to deliver — so that meeting your regulatory obligations and delivering excellent patient care are the same thing, not competing demands on your time.
Ready to see how Facetec helps you exceed regulatory compliance from day one? Book a demo online here.
