Quebec Government Update - March 30 to April 7, 2020

09 April 2020

Quebec government measures 

The Government of Quebec announced the launch of two new provincial programs to support businesses affected by COVID-19 and low-income essential services workers.

  • PACME (The Concerted Action Program for Maintaining Employment, officially the Programme d'actions concertées pour le maintien en emploi): This program aims to provide a budget envelope of $100 million to promote employee training, prepare for faster economic recovery and reduce the impact that the economic downturn could have on businesses. In this regard, the PACME grants subsidies to employers in order to cover expenses associated with the wages of workers in training and thus supports employment continuity. Reimbursement for business training projects will be limited to 100% to cover training expenses, related costs and costs pertaining to human resources management activities. For more details on this program, please consult our publication on the PACME program (available in French).
  • IPREW (Incentive Program to Retain Essential Workers): In order to compensate low-income workers in priority sectors, the Québec government is introducing this new financial assistance program. To benefit from the IPREW, workers must receive gross wages of $550 or less per week and an annual income between $5,000 and $28,600 for 2020. Eligible workers will be able to receive $100 per week retroactively to March 15, 2020, for a maximum period of 16 weeks. The first payment is scheduled for May 27, 2020.

Priority Services

The provincial government announced that the closure of non-priority businesses and services has been extended to May 4.

The list of priority services was originally enacted by Decree No. 223-2020 on March 24, 2020. It should be noted that the initial list was modified by Ministerial Orders 2020-011, 2020-013, 2020-014 and 2020 015. An unofficial list of priority services is available on the internet (link available here), but it does not replace the official text of the various decrees. In case of uncertainty, our professionals can advise your company regarding the interpretation of the list of priority businesses.

One of the most frequently asked questions relates to the obligations of businesses that provide, in whole or in part, goods or services to companies carrying out priority activities. This issue must be analyzed on a case-by-case basis.

Recently, all commercial retail establishments were asked to close to the public on Sundays, with some exceptions. As of April 4, 2020, Ministerial Order 2020-015 provided for the following exceptions:

  • Pharmacies, convenience stores, gas stations;
  • Restaurants for car orders, take-out and delivery;
  • Grocery stores for online or telephone orders, pick-up and delivery; and
  • Pharmacies located in areas outside shopping centres for online or telephone orders and for the delivery of medication and pharmaceutical, hygienic and sanitary products.

Furthermore, considering the extension of the containment measures, the Premier announced that the resumption of activities will be gradual and could be organized by geographic region or industry sector. The Government of Québec will give priority to sectors of activity that can respect physical distancing measures and to regions least affected by the spread of COVID-19. At the April 7 press conference, the Premier confirmed that the construction sector will be one of the first to resume its activities.

Travel restrictions

On March 28, 2020, the Minister of Health and Social Services adopted Decree No. 2020-11, which added travel restrictions to eight "health regions" on top of the various Quebec containment measures, and two other decrees further extended this list of health regions. As of April 4, there are 13 health regions affected in whole or in part by these measures.

These regions are as follows:

1) Entire region: Bas-Saint-Laurent, Saguenay-Lac-Saint-Jean, Abitibi-Témiscamingue, Côte-Nord, Nord-du-Québec, Gaspésie-Îles-de-la-Madeleine, Nunavik and Cree Territory of James Bay; and

2) Partial region: Outaouais, and the Laurentides, Lanaudière, Maurici, Centre-du-Québec, and the Capitale-Nationale regions.

There are several circumstances under which someone is allowed to travel to one of the 13 health administration regions. Such travel is permitted only:

  • For individuals whose principal residence is located in one of the regions;
  • For the shipment of goods in order to ensure the continuity of activities in priority services as set out in the decree of March 24;
  • For travel necessary for humanitarian purposes;
  • For travel necessary to obtain required health care or to provide such health care;
  • For people in the practice of professions in these regions that are also covered by the decree of  March 24 relating to priority activities, and any changes to it;
  • For individuals required to comply with an order contained in a judgment rendered by a court (or to exercise parental custody or access rights contained in an agreement);
  • For people arriving directly from an area to which access is limited;
  • For federal public service employees whose place of work is located in one of these regions;
  • For persons transporting goods through Quebec for a company or organization.

It should also be noted that additional restrictions apply to residents of the cities of Rouyn-Noranda and Gatineau.

Decree 2020-015 finally provides that the national public health director and any public health director is authorized to order a person who does not comply with government orders to self-isolate for a maximum of 14 days. Such a directive may be issued without a court order if: the person shows COVID-19 related symptoms; returns from travel; resides in a particularly targeted area; or is in an environment where there is a greater risk of COVID-19 transmission.

The Court of Québec or the municipal courts may terminate an isolation order.

Penalties and Sanctions

The law provides for penalties ranging from $1,000 to $6,000 for persons who refuse to obey a ministerial order issued following a health emergency announcement. These fines are applicable to each day on which the offence is committed.

You can read our article on the consequences of non-compliance with the various orders by clicking here.

Since early April, the Premier has been encouraging and supporting the imposition of fines on non-abiding citizens. The Director of Criminal and Penal Prosecutions has authorized the Service de police de la Ville de Montréal (SPVM) and the Sûreté du Québec (SQ) to issue abridged statements of offence. For example, several $1,000 tickets were issued to citizens who did not follow instructions and who continued to participate in indoor or outdoor gatherings. The Premier hopes these fines will have a deterrent effect on people who do not live in the same household and on businesses that do not comply with the closure of non-priority activities.


NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.