On January 6, 2021, the Quebec government announced extended shutdowns and tightened restrictions to prevent the spread of COVID-19, including a curfew. The measures will be in effect from January 9 to February 8. The official order or decree related to the shutdown is not yet available at the time of posting. It is possible that the information provided below, which is based solely on the government's press conference held on January 6, differs or omits certain details from the official government order or decree once issued.
The retail closures and work-from-home order that were announced on December 15, 2020, have been extended and will remain in effect until February 8, 2021. Details of the retail closures and work-from-home order are outlined in our previous blog post here.
- Pickup of items that have been purchased remotely will be permitted for all businesses, including businesses that are not authorized to remain physically open to the public, starting on January 9. The government has not yet clarified whether this authorization applies only to curbside pickup, or to both curbside and in-store pickup. Under the measures enforced for the holiday season, pickup was only permitted for enterprises authorized to remain open, and only for items that those enterprises were authorized to sell. This restriction will no longer apply as of January 9.
The curfew will require that people not be outside without a reason between the hours of 8:00 pm and 5:00 am. Police can stop anyone outside after curfew and question them. The curfew will be in effect from January 9 to February 8.
- Grocery stores and convenience stores will have to close around 7:00 pm – 7:30 p.m. in order to give its employees time to get home before the curfew. Convenience stores that operate within a service station will be permitted to remain open after 8:00 p.m.
- Pharmacies will be permitted to remain open after 8:00 pm.
- The government has not yet issued guidance with respect to whether other priority commercial enterprises and businesses will be permitted to continue operations after 8:00 pm.
- Reasons to justify being outside after curfew were described generally at the press conference as being health reasons, humanitarian reasons, or for commuting to and from work. We expect this will be further clarified in the official order or decree.
- Employers do not have an obligation to provide employees working late shifts with a document attesting to that fact, though the government explained that they are working on providing a template that employers can use. Providing employees with this type of document may be advisable since it would help employees justify being outside after curfew in the event they are stopped by police officers.
- The curfew will be enforced by fines ranging from $1,000 to $6,000.
The government is asking the manufacturing and construction sectors to postpone non-essential production. It is not clear whether this will be mandated by an official order, or whether it is a request and will not be mandatory. The official order or decree will give us an indication as to the enforceability of this request. Our understanding from the press conference is that it is a non-mandatory request, but operators in these sectors should wait for official guidance from the government.
Restaurants, theaters, gyms, movie theaters, personal care services and beauty services will remain closed. Certain other activities will continue to be authorized, such as individual skiing, other individual outdoor sports, and filming for movies and television.
The Minister of Public Security is expected to hold a press conference regarding the curfew on January 7, and the Minister of Education will discuss schools and daycares at a press conference on January 8.
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.