Québec Modifies Restrictions as of January 17 and 24, 2022: No Curfew, No Sunday Closures but Vaccine Passport extended to SAQs, SQDCs, Big Box Stores

Stikeman Elliott LLP

Stikeman Elliott LLP


In December, 2021, Québec ordered a number of businesses to suspend their activities (including restaurant dining rooms), imposed capacity limits on businesses permitted to remain open, forbade non-essential stores from opening on Sundays and imposed a curfew.

Some of these restrictions will be lifted over the next few weeks and a few new requirements imposed.

The government provided a chart summarizing the December restrictions here which has not yet been modified to take into account the latest changes.

January 2022 Developments

As the order bringing into force the new measures is not yet available, the information set out here is based upon the Government’s summary of the restrictions here.

Québec has required a vaccination passport for non-essential activities and businesses since September 1, 2021. As of January 18, 2022, the vaccination passport will also be required to enter

  • Société des alcools du Québec (SAQ) stores (liquor stores);
  • Société québécoise du cannabis (SQDC) stores (cannabis stores).

As of January 24, 2022, the vaccination passport will also be required to enter commercial establishments with an area greater than 1500 m2, with the exception of those whose main activity is the sale of groceries or pharmacy products.

Detailed Information

Since October 2020, the Government of Québec has tightened and loosened restrictions on businesses as COVID-19 cases increased and diminished. Most of the restrictions on businesses were lifted in November 2021 month throughout Québec (with continuing special measures in force in Terres-cries-de-la-Baie-James and in Nunavik). Certain restrictions were reimposed in December.

Québec’s public health state of emergency continues to be extended (currently to January 21, 2022) by the Québec Minister of Health and Social Services, who is empowered under this order to take measures necessary to protect public health.

The Commission des normes, de l’équité, de la santé et de la sécurité du travail has modified the recommended measures for workplaces throughout Québec (for a summary in French, see here).

Rapid antigen tests for personal use are being made available at no cost with limits on the number of tests each person may obtain. For more information on rapid antigen tests, see here.

This post highlights the restrictions on business and will be updated as Québec’s pandemic response evolves. For the Government summary of the restrictions on other activities such as education, sports and meetings (and others), see here (click on headings on the left).

Vaccine Passports

Since September 1, 2021, Québec has required a vaccination passport to gain access to non-essential activities and businesses. The vaccination passport is mandatory for everyone 13 and older. Québec has now decided to extend the vaccination passport requirement to liquor stores and cannabis stores (January 17, 2022) as well as stores with surface areas over 1500 m2 (January 24, 2022), except grocery stores and pharmacies.

The vaccine passport indicates that a person is “adequately protected” against COVID-19 and allows those aged 13 and up to gain admittance to certain locations and non-essential activities where the risk of transmission is considered to be higher. Photo ID is required. The full list of places and activities which will require the vaccine passport is available here.

The passport is not required for access to essential services such as education (primary, secondary or post-secondary). It is also not required for museums and libraries.

For more information on the vaccine passport and how to obtain it, see here.


The curfew imposed in December 2021 will end on January 17, 2022.

Until January 17, 2022, between 10 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 as set out here.

Employers of individuals who must travel during the curfew hours because of their work are asked to complete the “Attestation de l’employeur – Déplacement durant le couvre-feu décrété par le gouvernement du Québec” to permit these workers to prove that their breaking the curfew is legitimate. The form can be accessed here.

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. Young people 14 years of age and over may be fined $500.

Restrictions on Businesses: See the Government Summary of all the Restrictions here (click through to subject areas covered).

Closed (activities suspended)

  • stores and boutiques on Sundays (until January 17, 2022), except for convenience stores, gas stations, and drugstores. Companies that offer services such as plumbers and veterinarians can remain open on Sunday;
  • restaurant dining rooms;
  • arcades and, for their indoor activities, biodomes, planetariums, insectariums, botanical gardens, aquariums, zoos, thematic sites, amusement centres and parks, recreational centres and water parks;
  • bars and discotheques;
  • casinos and gaming houses;
  • movie theaters and rooms or halls in which performing arts are presented, including broadcast venues;
  • microbreweries and distilleries, only for services in connection with consumption of beverages on the premises;
  • food counters and food courts in any place where recreational or sports activities are carried on;
  • physical training rooms;
  • saunas and spas, except for personal care provided in the sauna or spa;
  • any indoor place, other than a private residence or its equivalent, when being used for games of bowling, darts, billiards or other similar games.

Open (capacity limits and mandatory face coverings for those 10 years and older)

  • Stores and commercial establishments
    • capacity limits: 50% of capacity allowing 1 client per 20 m2 of sales area applicable in stores, traffic areas and food courts;
    • personal care services such as hairdressers, massage therapists, etc.: customer traffic limited to 50% capacity.
  • Museums and libraries
    • physical distancing to be maintained.
  • Drive-ins
    • maximum 5,000 people per show;
    • cars spaced so a distance of 1 metre between people laterally may be maintained.

Remote working is mandatory whenever possible with distancing and masks mandatory for those working on-site.

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

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.

Going Forward

As set out here, the Government of Québec has modified restrictions and will continue to monitor the situation closely. This post is updated regularly when the Government rules are modified.

Written by:

Stikeman Elliott LLP

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