A report released on Monday found the counsellor breached professional boundaries and abused trust in her position towards two clients.
The Deputy Health and Disability Commissioner has referred the woman to the Director of Investigators to decide if she should be taken to court.
Both clients complained to the Addiction Practitioners' Association of Aotearoa NZ (DAPAANZ) about the counsellors conduct.
Since then, the counsellor has been de-registered and had her membership revoked.
Dr Vanessa Caldwell found the woman, who was the director, breached the code for not operating services that met professional and ethical standards.
There were several breaches, including the counsellor sending them images of her recent breast augmentation.
She also asked for multiple favours such as asking one woman to provide and serve drinks at her wedding and another client to house-sit for her.
There were numerous personal interactions between the counsellor and one women outside the therapeutic relationship, the report said.
Her husband, another director and counsellor, also breached the code for not providing ethical or professional services.
The counsellor also did not keep records of her treatment or provide treatment plans for the two women.
Her husband was found to have sent inappropriate messages on social media to one of his clients when he discovered she complained to DAPAANZ.
Dr Caldwell said all relationships between patients and health professionals, especially when people are vulnerable, involves trust.
"[The counsellor] held a position of trust, and there was a substantial power imbalance in her relationship with Ms B. Mrs C grossly abused this position of trust when she took advantage of Ms B for her own gain," Caldwell said.
Dr Caldwell has made a number of recommendations including both directors apologise to the women and for them both to undertake supervision.
She wanted updates from her supervisor each six months for two years to ensure the counsellors were performing at an ethical standard.
She also recommended for the counselling service to develop a complaints policy to be approved by independent DAPAANZ approved practitioners.
