HST on ABA therapy is one of the most misunderstood tax issues for Ontario behaviour analysts. Many practitioners either charge 13% HST when they do not have to — passing an unnecessary cost to families — or fail to analyze their position at all and run the risk of CRA liability. The good news: the CRA has issued specific guidance on ABA and autism therapy in GI-113, and most direct ABA therapy for autism qualifies for HST exemption. Here is what that actually means for your practice.
The CRA's Specific Exemption: GI-113 and Autism Training
The CRA published GST/HST Info Sheet GI-113 specifically addressing ABA and Intensive Behavioural Intervention (IBI) therapy for autism. Under Section 14 of Part II of Schedule V of the Excise Tax Act, supplies of training services specially designed to assist individuals with autism are exempt from HST.
Critically, the exemption does not require the provider to be a physician, psychologist, or any specific regulated health professional. BCBAs and ABA practitioners can qualify.
- Legal basis: Section 14, Part II, Schedule V of the Excise Tax Act
- What qualifies: training specially designed to assist individuals with autism in coping with or alleviating the effects of autism
- Provider requirement: none — does not need to be a regulated health professional
- Scope: covers the entire package of services — therapy, assessment, program development, and supervision are treated as one supply
Key rule: The training must not be similar to training ordinarily given to persons who do not have autism. Standard educational or recreational programming does not qualify — ABA/IBI designed specifically for autism does.
The Three Pathways to HST Exemption
To claim the exemption, one of three conditions must be satisfied. Most ABA practices will qualify through at least one of these pathways — and OAP-funded practices often qualify automatically through the third.
- Pathway 1 — Professional certification: A practitioner, medical practitioner, social worker, or registered nurse certifies in writing that the ABA training is appropriate for the individual. BCBAs can certify as practitioners.
- Pathway 2 — Prescribed person certification: A prescribed person or class member certifies appropriateness under prescribed conditions.
- Pathway 3 — Government funding evidence: The provider receives satisfactory evidence that payment comes from a government or organization administering a disability assistance program. OAP funding qualifies here.
OAP-funded practices: If your revenue comes from OAP funding, Pathway 3 applies — the government funding itself is satisfactory evidence of the exemption. This means OAP-funded ABA therapy is HST-exempt without needing any additional written certification.
What Is Included in the Exempt Supply
A key ruling from the CRA is that the entire package of ABA services — not just direct therapy hours — is treated as a single supply for HST purposes. This means ancillary elements are also exempt when the main service qualifies.
- Direct ABA therapy sessions: exempt (core service)
- Assessments and program development: exempt (part of the single supply)
- Clinical supervision of the therapy program: exempt (part of the single supply)
- Additional fees for ancillary services within the program: exempt as part of the service consideration
Practical implication: You do not need to split your invoice into "exempt therapy" and "taxable supervision." The CRA treats it all as one supply — if the conditions are met for the therapy, the whole invoice is exempt.
What Remains Taxable at 13% HST
Not all services provided by an ABA practitioner are exempt. The exemption is specific to training for individuals with autism (or their personal caregivers). Other ABA-adjacent services fall outside the exemption.
- Professional consultation billed to another ABA provider or school board: taxable
- Staff training and RBT supervision billed to an employer (not a client): taxable
- ABA services for conditions other than autism: taxable (GI-113 is autism-specific)
- Corporate training or workplace behavior consulting: taxable
- Training provided to professional caregivers (as opposed to personal caregivers): taxable
Mixed practice: If your practice provides both exempt ABA services (for autism clients) and taxable services (staff training, consultation), you have a mixed-supply situation. You must apportion input tax credits between exempt and taxable activities. A CPA should set up this tracking from the start.
What This Means for HST Registration and Invoicing
If all or most of your revenue is from exempt ABA therapy for autism, you may not need to register for HST at all — even if revenues exceed $30,000. Exempt suppliers do not charge HST, but they also cannot claim input tax credits on their business expenses.
- Primarily exempt revenue: likely no HST registration required; no HST charged to clients
- No ITCs available on expenses related to exempt supplies (equipment, software, rent proportionate to exempt services)
- Mixed exempt and taxable revenue: register for HST, charge on taxable services only, apportion ITCs
- Invoices for exempt services: do not include HST — show $0 HST or note "HST exempt under Schedule V"
We handle HST position analysis for ABA practices across a range of structures — OAP-only, private pay only, and mixed. We determine whether registration is required, set up your invoicing correctly, and ensure your position is defensible if CRA ever reviews it.
Key Takeaways
The CRA has specifically addressed ABA and autism therapy in GI-113 — and the answer is more favourable than most practitioners realize. Direct ABA therapy for autism is exempt from HST under three clear pathways, OAP funding automatically satisfies the government evidence pathway, and the entire service package (therapy, assessments, supervision) is treated as one exempt supply. Understanding this correctly saves your clients money and keeps your practice compliant.
Get Your ABA Practice HST Position Right
Adapt Business Solutions analyzes HST for Ontario ABA practices — OAP-funded, private pay, and mixed. We give you a clear, defensible position and set up your invoicing correctly. Book a free consultation.
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