Navigating Mandatory Reporting Under CRPO: Clarity on Therapist Obligations in 2025
Providing psychotherapy in Ontario means more than creating a safe and confidential space—it also requires you to navigate legal obligations that sometimes override confidentiality. The College of Registered Psychotherapists of Ontario (CRPO) expects registrants to understand when they must report information to outside authorities. Mandatory reporting isn’t simply a bureaucratic chore; it’s an ethical duty that protects clients and the public. Ignoring these duties can lead to discipline orders such as suspensions, remedial courses and mandated clinical supervision, as seen in recent tribunal decisions[1]. This article unpacks the mandatory reporting obligations for 2025, drawing on CRPO’s standards, policy documents and discipline rulings. It also highlights how CRPO supervision, whether through group supervision or dyad clinical supervision, helps therapists apply these rules in practice.
Why confidentiality has limits
Confidentiality is the cornerstone of psychotherapy, but CRPO makes it clear that other duties can override it[2]. Registrants must periodically review applicable reporting laws, document potential reports and maintain client confidentiality unless disclosure is permitted or required by law[3]. Several statutes impose mandatory reporting duties, including the Child, Youth and Family Services Act, 2017, the Long‑Term Care Homes Act, 2007 and the Health Professions Procedural Code[2]. Moreover, the Personal Health Information Protection Act (PHIPA) allows disclosure without consent if it is necessary to eliminate or reduce a significant risk of serious bodily harm[4]. In other words, therapists sometimes must break confidentiality to protect a client or the public.
CRPO’s Standard 1.3 (Mandatory Reporting) emphasizes that registrants are responsible for familiarising themselves with these obligations and using judgment to decide whether and what to report[5]. Reports should be grounded in reasonable grounds—concerns that go beyond rumours or speculation[6]—and registrants should seek consultation when uncertain[7]. Because mandatory reports can damage the therapeutic relationship, CRPO notes that registrants need not investigate extensively; they only need reasonable grounds to suspect an event may be occurring[8]. In many cases, supervision provides a space to process these decisions before acting.
What must be reported?
CRPO’s April 2025 update on mandatory reporting breaks down the kinds of situations where psychotherapists in Ontario have a legal duty to act.
One of the most familiar areas is child protection. If you have reasonable grounds to suspect that a child is being abused or neglected, you must immediately contact a children’s aid society. This isn’t optional. The Child, Youth and Family Services Act makes it very clear that protecting children takes priority over confidentiality.
Another important area is long-term care and retirement homes. If you believe that a resident is experiencing abuse, neglect, unlawful conduct, or even financial exploitation, you are legally required to make a report to the Director of the Long-Term Care Inspections Branch or to the Registrar of the Retirement Homes Regulatory Authority. The Long-Term Care Homes Act and the Retirement Homes Act put these duties into law so that vulnerable residents are protected.
Sexual abuse by a regulated health professional is a particularly sensitive reporting duty. If you learn, in your role as a therapist, that another regulated professional has sexually abused a client, you must file a written report with the registrar of that professional’s College. The Health Professions Procedural Code requires you to do this within thirty days. You’re also expected to make best efforts to tell the client about your obligation before you file, and you must not include the client’s name in the report unless they have given written consent.
There are also duties for people who operate facilities where regulated professionals practise. If you are in this position and you have reason to believe that a professional is incompetent, incapacitated, or has engaged in sexual abuse, you must report it to the registrar. This is spelled out in the Health Professions Procedural Code.
Employers and professional partners have similar obligations when it comes to termination or resignation for professional misconduct. If a regulated professional is terminated, suspended, or restricted in their practice because of incompetence, incapacity, or misconduct, the employer or partner must file a report with the registrar within thirty days. Even if the person resigns before action can be taken, the law requires that a report still be filed under section 85.5 of the Health Professions Procedural Code.
Finally, psychotherapists themselves must act if they become aware of unsafe practice by another registered psychotherapist. If you have reasonable grounds to believe that another member is practising unsafely, you are required to report it promptly. The Professional Misconduct Regulation makes it clear that failing to report unsafe practice is itself professional misconduct.
Sexual abuse reports: key details
Reporting sexual abuse is a particularly sensitive obligation. The Health Professions Procedural Code requires a regulated health professional who learns of sexual abuse during practice to file a written report with the alleged abuser’s regulatory body[12]. The report must contain the reporter’s name, the alleged abuser’s name and an explanation of the alleged abuse[17]. Importantly:
· Thirty‑day deadline: The report must be filed within 30 days after the obligation arises[18]. If the registrant believes the abuser will continue to abuse or harm others, the report must be filed immediately[19].
· Advise the client: When the obligation arises from information obtained from a patient, the registrant must use “best efforts” to advise the patient of the requirement to file the report before doing so[20].
· Protect client confidentiality: The patient’s name must not be included in the report unless the patient—or their representative if incapable—consents in writing[21]. This ensures that mandatory reporting balances transparency with client privacy.
When confidentiality yields to preventing harm
Mandatory reporting is not the only exception to confidentiality. PHIPA allows health information custodians to disclose personal health information without consent if disclosure is necessary to eliminate or reduce a significant risk of serious bodily harm[22]. CRPO’s Disclosing Information to Prevent Harm guideline reminds registrants that they can be held accountable for failing to take steps to prevent harm[23]. The guideline explains key concepts:
· Reasonable grounds: A concern based on more than mere suspicion[6].
· Necessary: Disclosure is necessary if there is no other reasonable way (e.g., continuing therapy) to prevent the risk, and only the minimal information required is disclosed[24].
· Significant risk & serious bodily harm: A case‑by‑case evaluation is required; harm may be physical or psychological and must be substantial[25].
The guideline emphasises professional judgment, consultation and documentation. Registrants should consult supervisors, colleagues or legal advisors early—long before harm becomes imminent[26]. Decisions should be documented, including consultations and actions taken[27]. Working with high‑risk clients can be emotionally taxing; the guideline encourages self‑care and ongoing supervision to maintain resilience[28]. Group supervision and dyad clinical supervision sessions are ideal settings to explore these dilemmas, practise decision‑making and support each other’s well‑being.
Lessons from the discipline tribunal
CRPO’s discipline decisions reveal the consequences of failing to meet mandatory reporting obligations. In College of Registered Psychotherapists v. La Rose (2025), a client disclosed sexual abuse by a massage therapist during a session. The registrant knew he was legally obligated to report the abuse to the College of Massage Therapists of Ontario and even looked up the reporting requirements[29]. However, he never filed the report and ignored repeated requests from the client and the other College[30]. The tribunal found professional misconduct and imposed a one‑month suspension, remedial terms (including clinical supervision and therapy), and costs[31]. This case illustrates that knowing about a duty is not enough; therapists must follow through and document their compliance.
Other discipline decisions from 2025 also highlight the gravity of reporting failures. In September 2025 a registrant was reprimanded and suspended for at least four months for practising while suspended and failing to respond to the College[32]. Earlier cases have censured registrants for using restricted titles or failing to maintain confidentiality[33]. While these cases involve various forms of misconduct, they underscore that the College takes regulatory obligations seriously and that discipline can lead to costly suspensions, remedial education and mandatory CRPO clinical supervision.
Making decisions in practice: steps for therapists and supervisors
Navigating mandatory reporting is complex, but a structured approach can help. Consider the following steps when faced with a potential reporting scenario:
1. Assess the situation: Determine whether the client’s disclosure triggers a mandatory report (e.g., sexual abuse by a regulated professional, child abuse, harm in a care home). Use the definitions of reasonable grounds and significant risk to guide your judgment[34].
2. Consult and document: When in doubt, consult a clinical supervisor, a colleague or CRPO’s Practice Advisory Service[35]. Document the facts, consultations and your decision‑making process[26][27].
3. Inform the client: If a mandatory report is required, advise the client (to the extent permitted and safe) before filing[36]. Explain why the report must be made and how you will protect their identity[21].
4. File promptly: Submit the report in writing to the appropriate authority within the time frame specified by law—often within 30 days for sexual abuse reports[37]. Ensure you include your name, the alleged abuser’s name and relevant details, but omit the client’s name unless you have written consent[38].
5. Follow up in supervision: Use group supervision or dyad clinical supervision sessions to debrief the process, reflect on the emotional impact and refine your understanding of reporting obligations. Supervisors can help supervisees integrate legal requirements with therapeutic practice, balancing client care with public protection.
Integrating mandatory reporting into CRPO supervision
Mandatory reporting can feel daunting, especially for newer therapists. CRPO supervision—whether through dyad clinical supervision or group supervision—provides a structured space to explore case examples, practise conversations with clients and review documentation. Supervisors can model how to navigate competing duties, assess risk and consult appropriately. For Registered Psychotherapists (Qualifying), this process reinforces Standard 1.3 and helps them build competence in ethical decision‑making.
Supervision sessions might include:
· Case vignettes: Reviewing anonymised scenarios of potential child abuse, elder neglect or sexual abuse by another professional. Discussing whether mandatory reporting applies and what steps to take.
· Role‑plays: Practising how to inform clients about reporting obligations while maintaining rapport.
· Documentation reviews: Checking that progress notes and reporting documents include necessary details and consultations without violating confidentiality.
· Self‑care strategies: Recognising the emotional toll of mandatory reporting and building resilience[28].
Effective supervision not only reduces the risk of professional misconduct but also builds a culture of ethical practice where therapists support each other in making hard decisions.
Conclusion: from obligation to opportunity
Mandatory reporting is not a box to tick; it’s a serious ethical obligation that protects clients and upholds public trust. Understanding the legal requirements—child protection, reporting sexual abuse by regulated professionals, facility and termination reports—is crucial. CRPO’s standards and guidelines emphasise balancing confidentiality with the duty to prevent harm[2][23]. Discipline cases show that failing to report has real consequences[1], while robust CRPO supervision provides therapists with the tools to navigate these obligations confidently. By integrating mandatory reporting discussions into clinical supervision, group supervision and dyad clinical supervision, Ontario therapists can transform a legal duty into an opportunity for professional growth and client protection.
References
1. CRPO. Mandatory Reporting Obligations for Registered Psychotherapists – Updated April 22 2025. This document summarises legal duties such as child‑protection reports, sexual‑abuse reports and facility or termination reports[9][12][14].
2. CRPO. Standard 1.3: Mandatory Reporting. The practice standard emphasises reviewing reporting obligations, documenting potential reports, maintaining confidentiality unless disclosure is required by law, and consulting supervisors or the College[39].
3. CRPO. Guideline: Disclosing Information to Prevent Harm. This guideline explains PHIPA’s duty to warn and defines key terms like reasonable grounds, necessary, significant risk and serious bodily harm[4][34]. It encourages consultation, documentation and self‑care[26][40].
4. College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v. La Rose (2025 ONRPDT 3). Tribunal decision illustrating professional misconduct for failing to file a mandatory report despite knowing the obligation; penalties included suspension and remedial supervision[1][31].
5. CRPO. Staying Up‑to‑Date With CRPO: What Therapists Need to Know (Fall 2025). Blog post summarising 2025 CRPO communications and discipline cases, including the importance of mandatory reporting and supervision[33].
[1] [29] [30] [31] CRPO v. La Rose, 2025 ONRPDT 3
[2] [3] [5] [7] [8] [35] [39] Mandatory Reporting
https://crpo.ca/practice-standards/professional-conduct/mandatory-reporting/
[4] [6] [22] [23] [24] [25] [26] [27] [28] [34] [40] Guideline-Disclosing-Information-to-Prevent-Harm-Jun1020.pdf
[9] [10] [11] [12] [13] [14] [15] [16] [17] [18] [19] [20] [21] [36] [37] [38] Mandatory-Reporting-Obligations-for-Registered-Psychotherapists-Apr2225.pdf
