Québec Announces Regional and Province-wide Restrictions in Response to COVID-19 Resurgence

October 23, 2020

In October 2020, a sharp increase in positive tests for COVID-19 in Quebec has led the Government of Québec to (i) renew the province’s public health emergency and (ii) reimpose some restrictions that had previously been lifted. The new measures, the severity of which varies from region to region, relate to certain private gatherings as well as to the operations of restaurants, bars, microbreweries, tourist accommodation, casinos, museums, amusement centres, libraries, movie theatres, places of worship, residential and long-term care centres, rented halls and many others. The new restrictions are to remain in force until November 23, 2020. 

This article highlights some of these additional restrictions and how they build on those that were previously in effect (see our prior article). It was originally published on October 7, 2020 and is regularly updated as Québec’s pandemic response develops. Recent revisions to the restrictions reflect the elevation to Level 4/Red of most parts of the Quebec-Montreal corridor plus Montérégie, Centre-du-Québec and the Capitale-Nationale health regions. The latest changes were passed on October 21 and 22, 2020 to take effect on October 22, 23, 24 and 26, 2020. 

Public Health Emergency Extended

 Ministerial Order 1000-2020 , dated September 29, 2020, renewed Québec’s public health emergency. The Minister of Health and Social Services continues to be empowered to take measures to protect public health.

Québec-wide Restrictions

Certain restrictions are identical in all regions of Québec.

With respect to holders of bar permits, under Ministerial Order 2020-063 dated September 11, 2020 and Ministerial Order 2020-064 dated September 17, 2020, the following requirements have been implemented:

  • A requirement to maintain specific registers and their patrons are required to furnish the information necessary for the purposes of the register, which has to be destroyed 30 days after being entered in the register; and
  • A prohibition against admitting, in each room and on each terrace of the establishment where the permit is used, more than 50% of the number of persons that may be admitted under its permit.

With Ministerial Order 2020-064 dated September 17, 2020 private seniors' residences are now required to maintain specific registers for every visitor admitted to the residence as well as registers of entry and exits by residents and staff members. Everyone is required to furnish the required information (which must be destroyed 30 days after being entered).

Restrictions in Less Affected Regions

As of October 1, 2020, those areas of Québec that are less seriously affected – i.e. those not in the Level 3/Orange or Level 4/Red areas (as provided in Ministerial Order 2020-068 dated September 20, 2020 and Ministerial Order 1020-2020 dated September 30, 2020) – are subject to the following restriction:

A maximum of 10 people can be present in a private residence or tourist accommodation unless they are members of the same residence or equivalent.

Exception: A person who performs a service or support may be present even though he or she is not an occupant of the residence or tourist establishment.

The September 30, 2020 Order, as amended,provides a list of what will constitute a service or support which includes, among other things:

  • service/support required for a person’s health or safety, for personal care, for commercial purposes, for childcare or education, and for domestic help (among others);
  • a maintenance, repair or residential renovation service;
  • a visit for the sale or lease of a residence; and
  • other services or support of the same nature.

A maximum of 250 persons may gather in places where it is customary to sit relatively still and speak little, e.g. cinemas, theatres and audio-visual recording studios, halls rented for meetings and places of worship. A maximum of 50 persons may gather in a hall rented for any other purpose.

A person’s right to peacefully demonstrate is recognized but he or she must wear a face covering and maintain a two-metre distance from others except if he or she is providing a service or support). Persons gathering in an outdoor public place must also maintain a two-metre distance from each other unless they occupy the same private residence or one of them provides a service or support to the other.

Restrictions in Level 3 (Orange) Regions

As indicated on the government site, Ministerial Order 1020-2020 dated September 30, 2020, as amended, brings the following health regions to Level 3 (orange) with its additional restrictions :

  • Bas-Saint Laurent;
  • Estrie;
  • Outaouais (except Ville de Gatineau and MRC of Les Collines-de-l’Outaouais);
  • Gaspésie—Îles-de-la-Madeleine (except the municipalities of Maria, Carleton-sur-Mer and Nouvelle);
  • Lanaudière and Laurentides (except Ville de Mirabel, MRC of Thérèse-De Blainville, MRC of Les Moulins, MRC of La Rivière-du-Nord, MRC of L’Assomption, MRC of Deux-Montagnes for the territories that are part of the Montreal Metropolitan Community and MRCs of Joliette and D’Autray (the latter two in effect on October 22 and 23, 2020);
  • Saguenay-Lac-Saint-Jean; and
  • Chaudière-Appalaches (only Les Etchemins, Montmagny and L’Islet).

The Level 3 restrictions applicable in these “orange” areas include the following:

Private residences and tourist accommodation

In private residences (or the like), hotels and other tourist accommodation in these areas, gatherings (whether within such places or on their grounds) are reduced to a maximum of 6 persons (down from 10) unless the persons are occupants of a maximum of 2 private residences (as opposed to the previous “recommendation” of no more than three households) or their equivalent.

From a business perspective, there is also an important exception for a person who is receiving a service or support from another.

Organized Indoor and Outdoor gatherings: Halls, places of worship, cinemas, theatres, public venues, etc.

In Level 3 areas, a maximum of 250 people can be in attendance at a place of worship or concert halls, cinemas, theatres, etc.

A maximum of 25 people can be gathered for indoor or outdoor organized activities such as marriages, family or workplace celebrations, picnics, etc. in outdoor public settings or in a rented or community hall (exceptions for certain recreational and sports activities and public venues covered by the previous rule)..  

Restaurants, bars, food courts and casinos

The following limit applies with respect to a restaurant, a food court in a shopping centre or food store, at casino or gaming house tables, in a bar or in any other room used for the purposes of restaurant services or the consumption of alcohol in these areas:

A maximum of 6 persons may be seated at the same table (down from 10) unless the persons are occupants of a single private residence (or its equivalent) or if one person is receiving from another person a service or support.

The holders of bar permits for these areas can sell alcohol only from 8 a.m. to 11 p.m. (previously, midnight). No consumption of alcoholic beverages is permitted in such establishments after midnight (previously, 1 a.m.).  

Residential and long-term care centres

Visits are now limited to those (i) for humanitarian purposes or to obtain care or services required by their state of health; or (ii) by a family caregiver who provides significant aid to the user or resident.

Restrictions in Level 4 (Red) Regions

Level 4 “Maximum Alert” restrictions apply in Québec’s two major metropolitan areas as well as in several additional health regions, as follows:

  • Montréal (including all municipalities in the Communauté métropolitaine de Montréal);
  • Ville de Québec (including all the Capitale-Nationale health region);
  • Mauricie (certain measures in effect on October 24 and 26, 2020) and Centre-du-Québec;
  • Montérégie;
  • Chaudière-Appalaches (except Les Etchemins, Montmagny and L’Islet);
  • Ville de Mirabel;
  • MRC of Thérèse-De Blainville and La Rivière-du-Nord;
  • MRC of Les Moulins;
  • MRCs of Joliette and D’Autray;
  • Ville de Gatineau;
  • MRC of Les Collines-de-l’Outaouais; and
  • Municipalities of Maria, Carleton-sur-Mer and Nouvelle.

Private residence and tourist accommodation: guests now strictly limited

In private residences (or the like) and hotels and other tourist accommodation in Level 4 areas, only occupants of the same residence or of the tourist home are now permitted, with the following limited exceptions for:

  • a person providing service or support to another; and
  • if the person lives alone, one person from another household.

Funerals and places of worship: limit of 25 persons

A maximum of 25 persons may attend a funeral or a place of worship. In the case of a funeral, the organizer must maintain specific registers and patrons are required to furnish the information necessary for the purposes of the register (such information must be destroyed after 30 days).

Restaurants, bars, food courts and casinos closed

Activities in the following are suspended in Level 4 areas:

  • 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 permitting consumption of food or beverages on the premises;
  • casinos and gaming houses;
  • museums, biodomes, planetariums, insectariums, botanical gardens, aquariums and zoos;
  • arcades, amusement centres and parks as well as water parks;
  • saunas and spas, except personal care provided therein;
  • libraries other than those in educational institutions, except lending desks;
  • movie theatres and rooms in which performing arts are presented, including venues where the arts are broadcast;
  • youth hostels;
  • physical training rooms; and
  • any indoor place used for an event-based or social activity, other than a private residence.

Indoor gatherings

The public is forbidden from attending indoor productions and recording sessions, training sessions and amateur sports events. No one may gather in a rented hall or community hall unless the activities are part of the mission of a community organization.

Outdoor gatherings

In the outdoor public places referred to in Order in Council 817-2020 (August 5, 2020), that is, any outdoor location other than the land of a private residence or its equivalent, outdoor gatherings are now prohibited except in certain school-related contexts. As noted above, masks are mandatory for demonstrations. Persons from an area in which this prohibition applies may not gather in an outdoor public place in another area except to study, work or practice their profession.

Residential and long-term care centres

Visits are now limited to those (i) for humanitarian purposes or to obtain care or services required by their state of health; or (ii) by a family caregiver who provides significant aid to the user or resident.


Those failing to respect social distancing rules or holding illegal private parties may be fined up to $1,000.

Other recommendations

The Minister of Health and Social Services continues to recommend that a resident of a Level 4 area not travel to another region which is at Level 3 or below, or outside of Québec.

Going Forward

Additional restrictions and closings may be imposed in other regions if the Government of Québec is unsatisfied with the province’s progress in fighting the pandemic. We will keep you posted.

DISCLAIMER: This publication is intended to convey general information about legal issues and developments as of the indicated date. It does not constitute legal advice and must not be treated or relied on as such. Please read our full disclaimer at www.stikeman.com/legal-notice.

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