By Mari-Len De Guzman
British Columbia is implementing its most significant shift in the province’s health professional regulations in over 30 years. Bill 36, the Health Professions and Occupations Act (HOPA), will come into force on April 1, 2026, and replace the long-standing Health Professions Act.
For primary care providers, understanding these sweeping changes and how they impact their practice is essential, as the province moves from a model of professional self-regulation to a more centralized, government-led oversight system.
What’s changing?
The HPOA introduces structural and administrative shifts that directly affect primary care providers.
Terminology: Doctors in B.C. are now legally a “licensee” rather than a “registrant.
Government-appointed Boards: The College of Physicians and Surgeons of BC (CPSBC) will no longer have elected physician board members. All members are now appointed by the Minister of Health, based on merit and competency recommendations. In addition, the CPSBC is now governed by the newly created Health Professions and Occupations Regulatory Oversight Office.
Independent Discipline Tribunal: While the CPSBC still investigates complaints, the final adjudication of serious disciplinary matters has moved to the new Health Professions Discipline Tribunal (HPDT). The HPDT is composed of government-appointed members.
Restricted Appeal Rights: A critical change under the HPOA is the removal of the statutory right to appeal disciplinary decisions to the B.C. Supreme Court. While an internal review within the Tribunal is possible, the automatic right to a full judicial appeal has been removed.
Duty to Report Discrimination: The Act creates a legal duty for all licensees to report conduct they believe constitutes discrimination, particularly Indigenous-specific racism.
Public Registry Transparency: All disciplinary actions, including minor ones, must be published in a mandatory public registry. Complaints that have been dismissed or do not result in discipline remain private but may be disclosed if requested.
Why these changes matter: Doctors of BC position
While supporting the goals of modernizing the legislation and improving cultural safety, Doctors of BC (DoBC) has expressed concerns about certain aspects of the new legislation, including the lack of physician consultation on the HPOA.
The Appeal Gap: Doctors of BC has highlighted that the removal of the statutory right to appeal disciplinary decisions to the Supreme Court raises concerns about fairness for physicians.
Political Oversight: The elimination of elected board members, shifting to fully appointed boards, raises concerns about potential political interference in clinical standards and professional ethics. Similarly, investigative and disciplinary actions will be conducted by a government-appointed body, which raises concerns about fairness and political influence.
Public Disclosures: The DoBC maintains this public disclosure, as well as the provision that allows disclosure of dismissed or unpursued complaints if requested, may potentially cause undue harm to physician’s reputation.
Here are additional resources for further reading and specific guidance:
CPSBC’s HPOA Resource Page: One-stop resource page that includes an overview of the legislation and frequently asked questions.
HPOA Advocacy Hub: The central source for policy papers, member updates, and the association’s ongoing dialogue with the Ministry.
HPOA One-Pager Summary: A concise guide on what the association values versus their specific concerns.
Webinar: Understanding the HPDT: A recording of the March 2026 session featuring representatives from the new Discipline Tribunal.
What’s next?
The transition to the full implementation of the HPOA will be undertaken in phases:
Bylaw Compliance: The CPSBC is finalizing new bylaws. Physicians should watch their email for updated professional standards that align with the new Act.
Cultural Safety Training: New mandatory continuing education requirements focused on anti-discrimination and cultural humility will be integrated into the next licensing cycle.
Expanded Regulation: By November 29, 2027, the CPSBC will begin regulating additional professions, including respiratory therapists and medical laboratory technologists. Physician assistants are also expected to transition to licensee status shortly thereafter.