When a complaint arrives from the College of Veterinarians of Ontario, veterinarians face one of the most stressful moments in their professional careers. The College receives, investigates, and acts upon complaints made against licensed veterinarians, and anyone who believes a veterinarian has not acted or treated them professionally can submit a complaint.
At Greenwood Law, our employment lawyers understand that CVO investigations carry profound implications for veterinarians’ licences, livelihoods, and reputations.
As employment lawyers who regularly advise veterinary practices and individual veterinarians, we know that regulatory investigations often intersect with workplace issues, employment disputes, and business operations. Whether you’re a practice owner managing an investigation involving an associate veterinarian, or an individual veterinarian facing allegations, strategic legal counsel from experienced workplace defence lawyers is essential from the moment that first letter arrives.
Critical Insight: A veterinarian’s written response is their best opportunity to mitigate the potential adverse effects of a complaint. Early intervention by workplace defence lawyers who understand both professional regulation and employment law dynamics can mean the difference between a file closure and a referral to the Discipline Committee.
Understanding the CVO’s Investigation Process
The College oversees the professional conduct of Ontario’s veterinarians as it responds to concerns and investigates complaints about veterinarians licensed to practice veterinary medicine in Ontario. As workplace lawyers advising veterinary practices and individual veterinarians, we recognize that the CVO’s regulatory authority creates unique employment law considerations that many veterinarians don’t anticipate.
The New Legislative Framework
Ontario’s veterinary regulatory landscape is undergoing significant modernization. The Veterinary Professionals Act received Royal Assent on June 6, 2024, representing the biggest update to the regulation of veterinary medicine in Ontario in over 30 years. While the legislation is now law, it is not yet in full effect, with the earliest the new model could be in place currently estimated to be January 2026, veterinarians should understand the changes coming.
The Veterinary Professionals Act introduces new committees that replace and supplement previous ones, with the Investigations and Resolutions Committee notably replacing the Complaints Committee.
The Investigation Timeline and Your Response
When a complaint is made, the veterinarian is notified of the complaint and given at least 14 days to respond in writing. From our experience as employment lawyers who defend professionals across regulatory proceedings, these 14 days are critical.
What the College Requires
The initial letter from the CVO typically arrives marked “Personal and Confidential.” Once the written response has been finalized, it should be submitted to the College’s investigator along with the complete records pertaining to the matter, which includes communication notes, surgery anaesthetic log, laboratory reports, controlled drug log, x-ray log, x-rays, invoices and electronic record audit trails.
Investigation Procedures
The CVO investigation may include the gathering of relevant documents and taking statements from witnesses. Where additional investigation is conducted, the veterinarian is usually given an opportunity to submit a further response.
The College provides the complainant with a copy of the veterinarian’s response and an opportunity to respond to the veterinarian’s explanation. This creates a back-and-forth that can expand the scope of allegations or introduce new claims.
Complaints Committee Review and Outcomes
The Complaints Committee consists of up to 10 members, including nine veterinarians and one public member appointed by the provincial government, with usually five or six members meeting as a panel to review complaints.
Critical procedural limitation: Because the Complaints Committee is a screening committee, it only considers a paper record and cannot make credibility assessments. There is no right to make oral submissions or for a lawyer to cross-examine the complainant or other witnesses.
This paper-only review makes the quality of the written response absolutely essential.
Possible Outcomes
After reviewing the case, the Committee may decide it has no concerns with the member’s conduct and will take no further action; has some concerns and provides advice and/or education; has very serious concerns and refers the case for a hearing with the Discipline Committee; or views the complaint as frivolous, vexatious, made in bad faith or otherwise an abuse of process.
Understanding each outcome:
- File closure with no action represents the best outcome, the College finds no basis for concern.
- Advice or education identifies minor concerns requiring guidance. While not formal discipline, this creates a record that can affect future complaints.
- Undertaking or remediation: The Committee may ask the veterinarian to sign an undertaking agreeing to a remediation program, such as coursework or mentoring.
- Referral to Discipline Committee is the most serious disposition, triggering a formal hearing process with significant professional and reputational consequences.
Mediation as an Alternative
Each complaint is reviewed by College staff and, when appropriate, attempts may be made to resolve the concerns through mediation. The CVO’s Mediated Resolution Program offers an alternative path for certain complaints.
More minor complaints, such as miscommunication or minor standards issues, may be referred by the CVO to the Mediated Resolutions Program. However, Mediated Resolution Programs are not appropriate in cases involving misuse of controlled drugs, fraud, animal abuse, misrepresentation, sexual impropriety or falsification of records.
The Right to Appeal: HPARB Review
With the exception of decisions to refer a complaint to the Discipline Committee or to the Registrar, a decision of the Complaints Committee may be appealed by either the complainant or the veterinarian to the Health Professions Appeal and Review Board (HPARB). The appeal must be brought within 30 days of the issuance of the decision.
HPARB’s authority is limited to considering the adequacy of the committee’s investigation or the reasonableness of its decision or both. If the investigation is deemed inadequate or the decision unreasonable, the matter may be sent back to the Complaints Committee with recommendations and/or directions.
Employment Law Implications for Veterinary Practices
As employment lawyers serving the veterinary sector, we recognize that CVO investigations create complex workplace implications.
When Employees File Complaints
Veterinary associates, registered veterinary technicians, or other staff members sometimes file CVO complaints during or after employment disputes. These situations require coordinated legal strategy addressing both the regulatory investigation and the underlying employment matter.
Key considerations:
- Does the complaint arise from legitimate concerns or retaliatory intent?
- Are there concurrent wrongful dismissal claims or human rights complaints?
- What are the practice’s investigation and workplace safety obligations?
- How should the practice respond to the CVO while protecting against employment liability?
Impact on Employment Relationships
When a veterinarian faces a CVO investigation, employment relationships often suffer:
For associate veterinarians, investigations can affect current employment status, partnership opportunities, restrictive covenant enforcement, professional liability insurance, and ability to secure new employment.
For practice owners, investigations involving employed veterinarians trigger duty to investigate workplace concerns, potential vicarious liability, decisions about continued employment, obligations to other employees and clients, and risk to clinic accreditation.
Just Cause Considerations
Practice owners often ask employment lawyers whether a CVO complaint or adverse finding constitutes just cause for termination. The answer is highly fact-specific, unproven allegations alone rarely justify summary dismissal, while licence suspension or revocation typically constitutes frustration of contract.
The Discipline Hearing Process
Following the formal investigation of a complaint, the Complaints Committee or Executive Committee may make a referral to the Discipline Committee, the most serious disposition the Committee can make.
A discipline hearing is a formal, adversarial process similar to a trial, with a veterinarian and the CVO each presenting their side of the case. The CVO prosecutor will have the burden of proving the allegations.
Potential Penalties
Where the veterinarian is found guilty of professional misconduct or serious neglect, the Discipline Committee may order reprimands, fines up to $5,000 payable to the Treasurer of Ontario, terms, conditions, or limitations on a certificate of registration, suspension or withdrawal of specialist status, or required courses or counselling. The Discipline Committee may also order a veterinarian to pay all or part of the CVO’s costs and expenses.
Timeframes and Reputational Impact
The wheels turn slowly once a complaint is lodged with the CVO. Unfortunately, at this time, a complaint may take two years to be resolved.
CVO hearings and discipline proceedings are open to the public, putting the veterinarian’s reputation at risk. The result of the proceedings will be published online and may show up in online searches for the veterinarian’s name or practice.
From our experience as employment lawyers, reputational damage often exceeds formal penalties, affecting client relationships, employment opportunities, partnership prospects, and professional referral networks.
Why Early Legal Intervention Matters
Responding to a complaint is a nuanced and difficult task that requires persuasive writing, careful analysis, and an understanding of how the CVO is likely to respond.
Critical early steps employment lawyers take:
- Immediate case assessment evaluates allegations, identifies defences, and develops response strategy within the short 14-day window.
- Comprehensive response preparation drafts written submissions that address allegations directly while positioning the veterinarian favourably.
- Evidence organization ensures all supporting documentation is complete and presents the strongest possible case.
- Employment coordination addresses workplace implications if the complaint involves employment relationships or practice operations.
The Greenwood Law Advantage
At Greenwood Law, we bring a unique combination of expertise to CVO investigations:
- Regulatory defence experience: With appearances at all court levels and experience serving in regulatory adjudicative roles, our employment lawyers understand administrative and professional regulatory proceedings from both advocacy and decision-making perspectives. This comprehensive experience allows us to anticipate issues and craft responses that resonate with regulatory decision-makers.
- Employment law integration: We recognize that CVO investigations rarely occur in isolation from workplace issues. Our employment lawyers coordinate regulatory defence with employment law strategy.
- Veterinary sector knowledge: We regularly advise veterinary practices on employment matters, workplace investigations, and professional regulatory issues, giving us sector-specific insight.
- Strategic, results-driven approach: Our workplace defence lawyers focus on achieving the best possible outcomes through proactive risk mitigation, strategic response, and when necessary, aggressive advocacy.
Taking Action: Next Steps for Veterinarians
If you’ve received notification of a CVO complaint or investigation:
- Act immediately: The 14-day response window is short. Contact employment counsel experienced in professional regulatory defence without delay.
- Preserve evidence: Secure all relevant records, communications, and documentation before preparing your response.
- Don’t respond alone: The written response is your most critical opportunity to influence the outcome. Professional legal assistance dramatically improves results.
- Consider the broader context: If workplace issues or employment disputes contributed to the complaint, address these strategically alongside the regulatory matter.
Conclusion
CVO investigations represent high-stakes proceedings with profound implications for veterinarians’ professional licences, employment relationships, and reputations. Whether you’re a veterinary practice owner managing an investigation affecting your clinic, or an individual veterinarian facing allegations, strategic legal counsel from experienced workplace defence lawyers is essential from the moment that initial letter arrives.
At Greenwood Law, our employment lawyers understand the unique intersection of professional regulation, workplace law, and veterinary practice operations. We provide comprehensive representation that protects your professional standing, employment interests, and business operations through every stage of CVO proceedings.
Contact Greenwood Law for a confidential consultation. Our workplace defence lawyers will assess your situation, identify risks and defences, and develop a strategic response that protects both your regulatory position and your professional future.
Disclaimer
This article provides general information about CVO investigations and related employment law matters. It does not constitute legal advice. Professional regulation and employment law are complex and fact-specific areas. For advice tailored to your specific situation, contact Greenwood Law for a confidential consultation with an experienced employment lawyer.
Sources & References
Legislation
- Veterinary Professionals Act, 2024, SO 2024, c 15 https://www.ontario.ca/laws/statute/24v15
- Veterinarians Act, RSO 1990, c V.3 https://www.ontario.ca/laws/statute/90v03
- Regulated Health Professions Act, 1991, SO 1991, c 18 https://www.ontario.ca/laws/statute/91r18
- Ministry of Health and Long-Term Care Appeal and Review Boards Act, 1998, SO 1998, c 18, Sched H https://www.canlii.org/en/on/laws/stat/so-1998-c-18-sch-h/latest/so-1998-c-18-sch-h.html
Regulatory Bodies
- College of Veterinarians of Ontario, “Complaints Process” (2025) https://www.cvo.org/investigations-and-hearings/complaints-process
- College of Veterinarians of Ontario, “Veterinary Professionals Act” (2025) https://www.cvo.org/about/strategic-plan/modernized-legislation/veterinary-professionals-act
- Health Professions Appeal and Review Board (2025), https://www.hparb.on.ca/
Government Resources
- Legislative Assembly of Ontario, Bill 171, Enhancing Professional Care for Animals Act, 2024, 1st Sess, 43rd Leg, Ontario, 2024 https://www.ola.org/en/legislative-business/bills/parliament-43/session-1/bill-171
- Ontario Ministry of Agriculture, Food and Agribusiness, “Consultation: Veterinarians Act, Ontario” (2025) https://www.ontario.ca/page/consultation-veterinarians-act-ontario
