When a Client Files a Complaint: What Actually Happens and How to Prepare
Registered psychotherapists are often adept at managing clinical issues yet are less familiar with what happens when a client files a complaint with the College of Registered Psychotherapists of Ontario (CRPO). Complaints—ranging from minor practice issues to allegations of serious misconduct—can feel frightening, yet they are part of being a regulated professional. Understanding the process and preparing ahead of time can protect the public and your practice. This article synthesizes CRPO resources with evidence‑based risk‑management literature to show what actually happens after a complaint is filed, what clients tend to complain about and how you, as a clinician or clinical supervisor, can reduce risk through psychotherapy supervision, documentation and ethical practice.
Common Triggers: Why Clients Complain
Although every therapeutic relationship is unique, research shows patterns in complaints across jurisdictions. A national liability insurer identified sexual misconduct, failure to maintain professional standards, breach of confidentiality, inappropriate reporting to third parties and practising beyond one’s competence as the most frequent grounds for complaints against counsellors and psychotherapists. CRPO’s jurisprudence manual similarly lists sexual abuse, failure to maintain professional boundaries (e.g., employing a client), inadequate record‑keeping, breaching confidentiality, fraudulent billing and disregarding restrictions on one’s certificate of registration as examples of professional misconduct. Complaints may also arise when registrants do not obtain or document informed consent, do not respect confidentiality or cross personal boundaries.
Many “low‑level” complaints are about communication—clients feeling unheard or believing the therapist was dismissive, did not explain risks/benefits or was inaccessible between sessions. Poor documentation makes it difficult to defend those decisions. In contrast, more serious complaints often involve sexual contact, harassment, fraud or actions that place clients at risk, which CRPO treats as professional misconduct and may refer to a discipline hearing.
Understanding the CRPO Complaint Process
Knowing what happens when a complaint is filed helps demystify the process and allows clinicians to respond ethically.
Filing and Notice
Members of the public may submit a complaint to CRPO using a formal form. If the complaint meets jurisdictional requirements, CRPO staff send the registrant a copy of the complaint within 14 days and ask for a written response. A registrar may assign an investigator to interview witnesses and collect documentation; the investigator gathers information but does not make decisions.
Investigation and the ICRC
The Inquiries, Complaints and Reports Committee (ICRC)—composed of registrants and public members—reviews the investigation and the registrant’s response. Possible outcomes, in order of increasing seriousness, include:
Take no action – if the investigation identifies minimal risk.
Written advice – guidance on practice improvements for low‑risk issues.
Remedial agreement – self‑directed learning with reflective assignments.
Specified continuing education or remediation program (SCERP) – a structured educational program when deficiencies pose moderate risk.
Oral caution – a formal in‑person warning for concerns of moderate risk.
Undertakings – voluntary restrictions on practice or resignation in medium‑ to high‑risk situations.
Referral to the Discipline Committee – for allegations of serious misconduct or incompetence when evidence warrants a formal hearing.
CRPO notes that approximately one‑third of complaints result in no action, while most others result in educational outcomes; only a small fraction progress to a discipline hearing. The average time from receipt of complaint to written decision is about 270 days, though complexity, responsiveness and other factors can extend timelines. During this period, information remains confidential, and both parties receive status updates.
Registrant Obligations
The Information for Registrants document reminds registrants of their obligations during an investigation: they must cooperate fully with CRPO, respond appropriately within 30 days to written requests and comply with professional practice standards. While registrants are not required to retain a lawyer, CRPO encourages them to seek legal counsel through their professional liability insurer because the outcome can significantly impact their practice. Registrants are advised that their written response may be shared with the complainant if needed and that the investigation cannot order financial compensation or employment remedies.
Appeals and Public Record
Both complainants and registrants may request a review of the ICRC’s decision by the Health Professions Appeal and Review Board (HPARB), and discipline decisions can be appealed to the Divisional Court. Certain outcomes—such as SCERPs, cautions, undertakings and discipline referrals—result in a notation on the public register.
Types of Complaints and Professional Misconduct
CRPO’s jurisprudence manual clarifies that professional misconduct is behavior falling below the profession’s minimum standards and may lead to remediation, suspension or revocation of registration. The manual offers concrete examples:
Sexual abuse (sexual touching or remarks).
Boundary violations, such as employing or befriending a client, or accepting significant gifts.
Inadequate record‑keeping, e.g., failing to retain emails or securely store records.
Breaching confidentiality, such as identifying a client to a family member without consent.
Fraudulent billing, including misrepresenting supervision or services for insurance reimbursement.
Practising beyond competence, e.g., delivering therapy without proper training or clinical supervision.
Professional misconduct also includes inappropriate conduct toward CRPO, such as publicly challenging the College’s integrity, breaching undertakings, failing to participate in the quality assurance program or obstructing investigations.
In contrast, incompetence involves lack of knowledge, skill or judgment; severe cases can lead to intensive supervision, course requirements or suspension. Incapacity relates to health conditions (e.g., substance use disorder) that prevent safe practice; these cases may result in treatment requirements or practice restrictions. Recognizing the difference between misconduct, incompetence and incapacity is essential when guiding supervisees or assessing practice risks.
Preparing and Preventing Complaints
Avoiding complaints is not about practicing defensively; it is about ethical, evidence‑based practice. Risk‑management scholars emphasise that informed consent, thorough documentation and ongoing consultation/supervision form the foundation of effective risk management. These strategies align with CRPO’s standards and help clinicians serve clients while protecting the public and themselves.
1 Informed Consent
CRPO’s consent standard requires registrants to assess capacity, ensure consent is voluntary and specific, and provide sufficient information about the therapy process, risks, alternatives and implications of not receiving treatment. Consent must be obtained continuously, not just at intake, and therapists must document conversations about consent, including dates, options discussed and whether consent was verbal or written. Therapists must obtain express consent before using physical touch.
Risk‑management literature echoes this view: informed consent is a collaborative process that engages clients in decision‑making and goes beyond a signed form. To be valid, consent must be voluntary, the client must be competent, therapists must actively ensure understanding and the process must be both written and verbal. Consent should be revisited whenever the therapy plan changes. Good consent includes explaining limits of confidentiality, fees, record‑keeping processes, treatment course, communications between sessions and emergency procedures.
2 Documentation and Record‑Keeping
Accurate and comprehensive records are critical for continuity of care and for defending clinical decisions. CRPO notes that effective record‑keeping allows registrants to track progress, make adjustments and explain and defend what was done. Records must include clinical, appointment and financial information and comply with the Personal Health Information Protection Act (PHIPA). Clients have the right to correct inaccuracies and file complaints if they believe records are mishandled.
Risk‑management research reinforces that good documentation serves both clinician and client. It should record assessments, decisions, informed‑consent discussions, consultations, risk assessments and the rationale behind interventions. All consultations and referrals, communications with clients outside sessions and recommendations should be documented. Solid records not only refresh the clinician’s memory and support treatment planning but also serve as evidence in the event of a complaint.
3 Consultation, Peer Support and Clinical Supervision
Consultation and psychotherapy clinical supervision are essential in high‑risk or complex situations. CRPO’s standards emphasise that supervisees must seek supervision when needed and that supervisors are responsible for providing adequate supervision. Cases where a clinical supervisor fails to act after learning of a supervisee’s boundary violation illustrate that supervisors share liability. Supervisors must also have backup plans for emergencies and must not restrict access to consultation for financial reasons. Additionally, supervisors hold power and therefore must avoid inappropriate boundary violations—such as borrowing money from a supervisee—which are considered misconduct.
Risk‑management authors note that no clinician can know everything; consultation provides new perspectives, helps identify blind spots and supports ethical decision‑making. Clinicians should seek consultation when facing challenging cases, ethical dilemmas or when unsure of their competence. On‑going peer consultation is valuable even for seasoned professionals. Consultation should be documented and approached with openness, not as a sign of weakness.
4 Boundaries and Dual Relationships
Boundaries protect clients and therapists. CRPO defines a boundary as the edge of appropriate professional behaviour; crossing it involves deviating from the strict professional role. Boundary crossings can be harmless but become violations when they place clients at risk. Maintaining boundaries is always the therapist’s responsibility. Examples include self‑disclosure beyond therapeutic benefit, gift exchanges, meeting clients outside the office, or physical touch, all of which require careful consideration and documentation. CRPO’s professional conduct standards prohibit sexual relations with clients and caution therapists to avoid dual relationships and undue influence.
5 Confidentiality and Privacy
Protecting client information builds trust and complies with PHIPA. CRPO instructs that registrants must not collect, use or disclose information without informed consent except as permitted by law, and they must familiarize themselves with privacy legislation. Therapists should explain confidentiality and its limits to clients and document consent for disclosure. They must only collect information necessary for treatment, train staff in privacy practices and use secure communication methods. Therapists should notify clients when disclosure is legally required or when a breach occurs.
6 Professional Competence and Self‑Care
Complaints sometimes stem from practising outside one’s competence or working while burned out. CRPO reminds registrants to practise only in areas for which they have sufficient knowledge, skill and judgment and to seek referrals when necessary. In the jurisprudence manual, clinicians whose health condition impairs judgment may be deemed incapacitated and ordered to receive treatment or supervision. Maintaining competence through ongoing education, supervision and self‑care helps protect clients and reduces risk.
Case Scenarios: Learning Through Examples
To illustrate how complaints may unfold and how preparation can make a difference, consider the following fictionalized scenarios.
Case 1 – Documentation Saves the Day (Low‑Level Complaint)
Scenario: A client complains that their psychotherapist, Laura (RP), misrepresented their statements in a court report, claiming that the client’s mother neglected them. Laura receives notice of the complaint and worries about her professional reputation.
Analysis: In her response, Laura provides detailed session notes and supervision consultation records that show the client spontaneously reported these concerns during therapy. She also provides evidence that she consulted her clinical supervisor about whether to notify child‑protection services and that the supervisor advised reporting, consistent with mandatory reporting obligations. Because Laura accurately documented the facts and sought supervision, the ICRC concludes that she met professional standards and takes no action (similar to the CRPO case study where the panel found that the registrant accurately communicated what was discussed and had reasonable grounds to report to CAS). The client may still be dissatisfied, but the complaint demonstrates the value of meticulous notes and consultation.
Takeaway: Good documentation and supervision can turn a potentially serious allegation into a no‑action outcome.
Case 2 – Boundary Blurring (Moderate Complaint)
Scenario: Jordan (RP Qualifying) begins texting a client socially and accepts a large holiday gift. The client becomes uncomfortable and files a complaint, saying the therapist made them feel pressured to continue therapy.
Analysis: Boundary crossings like social texting and gift acceptance can become violations when they confuse the professional relationship. The clinical supervisor failed to intervene when the client raised concerns, which is also problematic. The ICRC orders specified continuing education (SCERP) for Jordan on professional boundaries and issues an oral caution to the supervisor for not addressing the behaviour. This case illustrates that moderate boundary issues usually lead to educational outcomes rather than discipline hearings, but they still result in public notations.
Takeaway: Maintain clear boundaries, document any deviations (e.g., gifts), seek supervision when unsure and address supervisees’ boundary issues promptly.
Case 3 – Practising Beyond Competence (Serious Complaint)
Scenario: Amira, a registered psychotherapist, begins offering psychedelic‑assisted psychotherapy without proper training. A client experiences a traumatic reaction and files a complaint alleging negligence.
Analysis: Practising a controlled act without adequate training or clinical supervision is an example of professional misconduct. CRPO’s jurisprudence manual notes that incompetent practice may lead to restrictions, intensive supervision or revocation of registration. The ICRC refers Amira to the discipline committee. After a hearing, her certificate of registration is suspended pending completion of approved training, and a notation appears on the public register. In addition, the discipline committee orders her to practise under psychotherapy supervision for two years upon reinstatement.
Takeaway: Always work within your competence, pursue proper training and supervision before expanding your scope and consult when uncertain. Serious allegations, especially involving client safety, may lead to suspension or revocation.
What to Do When You Receive a Complaint
Receiving a complaint triggers a range of emotions, but staying calm and informed helps. Consider these steps:
Do not ignore the notice. CRPO requires registrants to respond appropriately and within 30 days to requests for information. Failure to do so may itself constitute misconduct.
Contact your professional liability insurer and legal counsel. CRPO recommends consulting a lawyer because the outcome can significantly impact your career. Your insurer often provides legal representation.
Review your records. Gather documentation (clinical notes, consent forms, supervision notes) and ensure they are thorough and accurate. Do not alter or back‑date records.
Consult your clinical supervisor or peers. Discuss the case, seek guidance and document the consultation. Supervision is both a learning process and a risk‑management strategy.
Provide a thoughtful written response. Address the allegations factually, cite evidence from your records and outline your clinical reasoning. Avoid defensiveness; show your commitment to ethical practice.
Maintain confidentiality. Only share information necessary for the investigation and obtain express consent for disclosure.
Practice self‑care. Complaints can be stressful; seek support from trusted colleagues or personal therapy. Use the experience as an opportunity to reflect on your practice and strengthen ethical foundations.
Conclusion
Complaints can feel daunting, but they are part of the accountability that comes with being a regulated health professional. Most complaints are resolved through education and remediation, and only a small percentage lead to discipline hearings. By understanding how the process works, knowing what clients commonly complain about and implementing robust **risk‑management practices—namely informed consent, comprehensive documentation, regular consultation and CRPO clinical supervision—you can protect your clients and your career. Ethical practice is not just about avoiding complaints; it is about providing high‑quality care that respects clients’ rights, boundaries and autonomy.
References
Barnett, J., & Grammatico, J. (2023). Risk management and clinical excellence for psychotherapists. Psychotherapy Bulletin, 58(2–3), 30–36. Retrieved from [Society for the Advancement of Psychotherapy website].
College of Registered Psychotherapists of Ontario (CRPO). (2025). Professional practice and jurisprudence for registered psychotherapists [Manual]. Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026a). Standard 3.1: Confidentiality (Practice Standards). Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026b). Standard 3.2: Consent (Practice Standards). Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026c). Standard 3.6: Complaints Process (Practice Standards). Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026d). Filing a complaint about a registered psychotherapist (Complaints & Reports). Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026e). Information for registrants—complaints [PDF]. Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026f). Record‑keeping & documentation (Practice Standards). Retrieved from [CRPO website].
College of Registered Psychotherapists of Ontario (CRPO). (2026g). Clinical supervision information (Registrant Information). Retrieved from [CRPO website].
Missigman, M. E. (n.d.). Top 5 reasons professional counselors and psychotherapists receive complaints against their licenses; What to do to prevent it. The Health Law Firm. Retrieved from [The Health Law Firm website].
