Special emergency measures, put in place on April 1, 2021, have been lifted in the Capitale-Nationale Region but continue to apply in some municipalities in Chaudière-Appalaches, Estrie and Outaouais and now apply in some municipalities of Bas-St. Laurent. These measures include a curfew of 8 p.m. and closure of non-essential businesses.

Montréal and Laval curfews which became 8 p.m. on April 11, 2021, have been returned to 9:30 p.m.

As of April 19, 2021, Interprovincial travel by land between Quebec and Ontario is restricted (with checkpoints at the border). More information is here. Travel, except for essential travel, is also now prohibited within Quebec to Yellow zones and to the Côte-Nord. More information is here.

This article highlights current and upcoming restrictions on business and how they build on those that were previously in effect (see our prior article) and is regularly updated as Québec's pandemic response develops. Note that only restrictions on business are covered here. For complete details of restrictions on other activities such as private gatherings, education and sports activities (and others), see here.

Since October 2020 the Government of Québec has continuously renewed the public health emergency declared in the province and tightened and loosened restrictions on businesses as the Covid-19 cases increased and diminished. Like most other provinces, Québec implements many of its restrictions on a regional basis, with a four-level colour-coded scheme that ranges from Red (most restrictive) to Green (least restrictive).

Most of the restrictions in Level 4 (Red zones) for businesses continue, including curfew restrictions and closure of businesses such as restaurants, bars and indoor entertainment venues except that cinemas, museums and theatres have been permitted to reopen with restrictions. Measures remain respecting the number of clients, obligatory sanitary measures and mask-wearing and, for shopping centres, supervision of common areas.

In Level 3 (Orange zones), the curfew remains in effect but restaurants and spas, among others, have been permitted to reopen.

Québec regions are now classified as follows:

  • Red with special emergency measures:
    • Bas-Saint-Laurent for Kamouraska, Les Basques, Rimouski-Neigette, Rivière-du-Loup and Témiscouata;
    • Chaudière-Appalaches for MRC Beauce-Sartigan; MRC des Etchemins; and MRC Robert-Cliché;
    • Estrie for le Granit;
    • Outaouais for Gatineau; MRC des Collines-de-l'Outaouais; and Pontiac;
  • Red zones: Capitale-Nationale Region; Bas-Saint-Laurent; Chaudière-Appalaches; Estrie; Lanaudière; Laurentides, Laval, Montérégie; Montréal, and Outaouais;
  • Orange zones: Côte-Nord; Mauricie–Centre-du-Québec; and Saguenay-Lac-Saint-Jean;
  • Yellow zones: Abitibi-Témiscamingue; Gaspésie–Îles-de-la-Madeleine and Nord-du-Québec;
  • Green zones: Nunavik and Terres-cries-de-la-Baie-James (special measures also in force)

In regions now classified as Orange, Yellow or Green zones, restaurants, cinemas, museums, libraries, performing arts venues, spas and gyms, among others, are permitted to reopen with certain restrictions.

Québec's public health state of emergency continues to be extended (currently to May 14, 2021) by the Québec Minister of Health and Social Services, who is thereby empowered to take measures necessary to protect public health.

Mandatory Mask-wearing

As of April 8, 2021, the Commission des normes, de l'équité, de la santé et de la sécurité du travail requires that medical masks be continuously worn indoors in workplaces throughout Quebec. See our related article for more information.

Special emergency measures in parts of Bas-Saint-Laurent, Chaudière-Appalaches, Estrie and Outaouais : Restrictions on business

The special emergency restrictions applicable to businesses in Kamouraska, Les Basques, Rimouski-Neigette, Rivière-du-Loup; Témiscouata; MRC Beauce-Sartigan; MRC des Etchemins; MRC Robert-Cliché; le Granit; Gatineau; MRC des Collines-de-l'Outaouais and Pontiac.

Only essential businesses to remain open

Retail stores and personal and beauty care enterprise must cease their operations, except for:

  • grocery stores and other food stores;
  • drugstores but only for everyday essentials;
  • hardware stores but only for products required to carry out exterior maintenance, repairs, or construction;
  • service stations;
  • animal feed and supply stores;
  • work-related safety and protective equipment stores;
  • commercial enterprises that sell products, parts, and other material necessary for transportation and logistics services and vehicle repair or maintenance, including vehicle repair and maintenance centres, but excluding the sale of vehicles;
  • big-box stores and other sales areas offering customers a wide variety of categories of products, including food, drugstore, and hardware products but only for the products usually sold in one of the stores mentioned above, which excludes toys, clothing, books, electronic devices, decorative items, cookware, and electric household appliances;
  • convenience stores (including tobacco stores that are not specialized tobacco sales outlets);
  • florists;
  • farm product stores;
  • medical, orthopaedic, and eye care supply stores;
  • specialized janitorial and building product stores;
  • stores offering computer and electronic equipment repair service but only for such services;
  • stores offering sports and outdoor recreational equipment repair and rental but only for such services;
  • the Société des alcools du Québec; and
  • the Société québécoise du cannabis;

Healthcare and social services (dentists, optometrists, physiotherapists, massage therapists, osteopaths, etc.) can continue to provide their services.

All businesses, except drugstores and service stations, must close not later than 7:30 p.m. to comply with the 8 p.m. curfew and continue to comply with the restrictions in force concerning the number of people allowed in the stores.

Working remotely ("teleworking") is mandatory for all workers, except those who must be physically present to permit the organization (public or private) to pursue its activities.

For non-priority businesses, it is possible to purchase products online or by telephone and have them delivered or pick them up on site if pickup occurs outside the premises.

Curfew

Between 8 p.m. and 5 a.m., Quebeckers must not leave their homes except in cases that justify travel. Such cases include travel for work if the person's physical presence in the workplace is required, medical and humanitarian reasons, returning from a trip abroad and accompaniment of children in specified cases.

Employers of individuals who must travel during the curfew hours because of their work should complete the "Attestation de l'employeur – Déplacement durant le couvre-feu décrété par le gouvernement du Québec" to permit these workers to prove that they are legitimately outside their homes during the curfew. The form can be downloaded on this page.

Police officers are to ensure compliance by intervening when individuals are outside their homes during curfew hours without a valid reason. Offenders are liable to fines ranging from $1,000 to $6,000 if they are unable to adequately justify why they are outside their homes.

Level 4 (Red zones): Restrictions on business

The following are now Level 4 (Red zones):

  • Montréal;
  • Capitale-Nationale;
  • Bas-Saint-Laurent (special emergency measures in some municipalities);
  • Chaudière-Appalaches (special emergency measures in some municipalities);
  • Estrie (special emergency measures in le Granit);
  • Lanaudière;
  • Laurentides;
  • Laval;
  • Montérégie; and
  • Outaouais (special emergency measures in some municipalities).

The Level 4 restrictions applicable to businesses in the Red zones include the following.

Certain businesses to remain closed

The following must remain closed:

  • restaurants, and food courts in shopping centres and food stores, except for deliveries, take-outs or drive-through orders;
  • bars and discotheques;
  • microbreweries and distilleries in respect of their services relating to the consumption of food or beverages on their premises;
  • casinos and gaming houses;
  • arcades and, with respect to their indoor activities, thematic sites, amusement centres and parks, recreational centres and water parks;
  • youth hostels; and
  • any indoor place used for an event-based or social activity or for games such as bowling, darts, billiards and the like, other than a private residence.

No one is permitted to be present in a place where activities have been suspended unless he or she is there to engage in permitted activities.

Other restrictions on business

  • No loitering: shopping centres must take measures to ensure that no-one loiters in their common areas.
  • Curfew: All open businesses, except drugstores and service stations, must close their doors to the public not later 9 p.m. to comply with the 9:30 p.m. curfew and restrictions remain in force concerning the number of people allowed in the stores as set out below. During the curfew period, pharmacies and service stations may maintain their usual opening hours. However, pharmacies may only sell medication, and essential products such as pharmaceutical, hygiene or health products and service stations may only sell products such as food, non-alcoholic beverages and products for vehicles. Service stations may not sell tobacco or alcoholic beverages between 9:30 p.m. and 5 a.m.
  • Hotels and other tourist accommodation: only occupants of the same residence or of the tourist home are permitted in a unit, with limited exceptions for persons providing service or support to another; and a visitor for those living alone.
  • Limits on number of customers: Québec commercial establishments that engage in retail sales of products to the public are required to restrict the number of customers allowed inside. The permitted number is a function of the floor area of the premises that is accessible to customers (the Government has provided information on how to perform the necessary calculations). A sign indicating the number of persons allowed in the premises must be displayed in the store (with the French language versions being predominant). Store operators must also take measures to manage customer traffic within the store to ensure physical distancing.
  • Teleworking: Working remotely ("teleworking") is mandatory for all workers, except those who must be physically present to permit the organization (public or private) to pursue its activities.
  • Working on-site: For businesses whose employees are returning to the workplace, there is a maximum occupancy rate of 25% for premises in office buildings. Measures to protect the health and safety of workers continue in force and can be found here.
  • Manufacturers and construction companies: Manufacturing, primary processing and construction industry enterprises must reduce their activities to those that are necessary to fulfil their commitments. Working remotely is to be favoured when possible and shifts are to be adjusted to limit the number of staff present at any one time on production and construction sites.
  • Mandatory mask-wearing: see above.

Curfew

Between 9:30 p.m. and 5 a.m., Quebeckers must not leave their homes except in cases that justify travel. Such cases include travel for work if the person's physical presence in the workplace is required, medical and humanitarian reasons, returning from a trip abroad and accompaniment of children in specified cases.

Employers of individuals who must travel during the curfew hours because of their work should complete the "Attestation de l'employeur – Déplacement durant le couvre-feu décrété par le gouvernement du Québec" to permit these workers to prove that they are legitimately outside their homes during the curfew. The form can be downloaded on this page.

Police officers are being asked to intervene when individuals are outside their homes during curfew hours without a valid reason. Offenders are liable to fines ranging from $1,000 to $6,000 if they are unable to adequately justify why they are outside their homes.

Level 3 (Orange zone): Restrictions on business

The following health regions are now classified as Level 3 (Orange zone):

  • Côte-Nord;
  • Mauricie–Centre-du-Québec; and
  • Saguenay-Lac-Saint-Jean.

Certain businesses to remain closed

The following businesses must remain closed:

  • bars and discotheques;
  • microbreweries and distilleries in respect of their services permitting consumption of food or beverages on the premises;
  • casinos and gaming houses;
  • arcades and, for their indoor activities, thematic sites, amusement centres and parks, recreational centres and water parks;
  • youth hostels; and
  • any indoor place used for an event-based or social activity or for games such as bowling, darts, billiards and the like, other than a private residence.

Other restrictions on business

  • No loitering: same as for Red zones.
  • Curfew: same as for Red zones.
  • Hotels and other tourist accommodation: same as for Red zones.
  • Limits on number of customers: same as for Red zones.
  • Teleworking: same as for Red zones.
  • Working on-site: same as for Red zones.
  • Manufacturers and construction companies: same as for Red zones.
  • Cinemas, performing arts venues, and establishments offering indoor recreational or sports activities organized in a public place: Certain restrictions as set out here including restrictions on meals being served in performing arts venues except for hotels which offer performances that may be viewed from a guest's room balcony.
  • Restaurants, food courts in a shopping centre or food stores: A maximum of two persons from different addresses, accompanied by their minor children, and, if required, a person providing a necessary service or support may be seated at the same table. Operators of restaurants must verify that customers have a proof of residence in a region with the same alert level, limit customers to those with a reservation or their guests (other than fast food) and keep a register of their customers. The information in the register may only be disclosed to the public health authority for epidemiological purposes and is to be destroyed after 30 days. Delivery only is permitted during curfew hours.

Level 2/1 (Yellow/Green) Restrictions

The following health regions are at Level 2 and Level 1 (Yellow/Green zones) with special measures also in force in the Green zones:

Yellow zones:

  • Abitibi-Témiscamingue;
  • Gaspésie–Îles-de-la-Madeleine; and
  • Nord-du-Québec;

Green zones:

  • Nunavik and
  • Terres-cries-de-la-Baie-James.

While businesses are now permitted to re-open, certain restrictions on the number of customers or patrons remain in place as set out here.

For information about the measures in force in Nunavik and Terres-cries-de-la-Baie-James., consult the websites of the Nunavik Regional Board of Health and Social Services and the Cree Board of Health and Social Services of James Bay.

Other recommendations

The Government of Québec continues to recommend that residents of one region not travel to regions at a different level, or outside of Québec.

Fines

Those failing to respect the rules on social distancing, face coverings and gatherings (among others) may be fined up to $1,000 while those breaking curfew may be fined from $1,000 to $6,000.

Going Forward

Restrictions and closings may be re-imposed in regions where they have been loosened if the Government of Québec is unsatisfied with the province's progress in fighting the pandemic. We will keep you posted.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.