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November 24, 2020 - By Elia Associates

COVID-19 Bulletin No. 29: COVID-19 Restrictions In Ontario

Updated on November 23, 2020

An outline of Ontario’s new tiered/zoned system:

  1. Green Zone - Prevent (standard measures) – restrictions reflect the broadest allowance of activities in Stage 3; the highest risk settings remained closed. This stage focuses on education and awareness of public health and workplace safety measures.
  2. Yellow Zone – Protect (strengthened measures) – enhanced targeted enforcement, fines and enhanced education to limit further transmission. Public health measures are applied in high-risk settings.
  3. Orange Zone – Restrict (intermediate measures) – enhanced measures, restrictions and enforcement are implemented.
  4. Red Zone – Control (stringent measures) – broader-scale measures and restrictions across multiple sectors to control transmission are implemented (return to modified stage 2). Restrictions in this zone are the most severe available before widescale business or organizational closure.
  5. Grey Zone – Lockdown (maximum measures) – Widescale measures and restrictions including closures are implemented.

Please click here and here for more information regarding Ontario’s new COVID-19 zoning system.

What Zone is my Region in? (Correct as of Monday, November 23, 2020)

The following Regions are in Lockdown: Toronto and Peel Region.

The following Regions are in the “Red” Zone: Durham, Hamilton, Halton, Waterloo and York Region.

The following Regions are in the “Orange” Zone: Brant, Huron, Niagara, Ottawa, Simcoe Muskoka, Southwestern, Wellington-Dufferin-Guelph and Windsor-Essex.

The following Regions are in the “Yellow” Zone: Chatham-Kent, Eastern Ontario, Grey Bruce, Haldimand-Norfolk, Middlesex-London, Peterborough, Sudbury, Thunder Bay, Kingston, Frontenac and Lennox and Addington.

All other Regions remain in the “Green” Zone of Stage 3.



Yellow (Strengthened Measures)

Orange (Intermediate Measures)

Red (Stringent Measures)

Grey/Lockdown (Maximum Measures)

Public Gatherings

Unstaffed events:

10 people indoors and 25 people outdoors


Staffed events:

50 people indoors and 100 people outdoors

Same as yellow

5 people indoors and 25 people outdoors

No indoor events and 10 people outdoors


50 people indoors and 100 outdoors


At least 3m between patrons


Max 10 people per room indoors and 25 outdoors.


Reservation required


Safety Plan required

Measures same as yellow and:


Screening patrons is required


Patrons may only be in the facility for 90 minutes.


No spectators

10 people indoors and 25 people outdoors


Pools may remain open; however, saunas and steam rooms must be closed.

All indoor facilities, including pools must be closed.

Real Estate – Open Houses

Permitted providing event is not exceeding 50 people and physical distance can be maintained.

Same as yellow.

Prohibited; properties can be shown by appointment only.


What businesses are deemed essential and may continue operating when a Region is placed into lockdown?

O. Reg. 654/20 mandates the closure of all non-essential businesses and places.  Businesses and places that are deemed essential must operate under strict restrictions.

The following businesses may be applicable to condominiums:

What if my condominium is in the “green” zone? Do I still need to wear a mask?

The provincial rule on masks remains unchanged. Unless you are exempt from wearing a mask, one must be worn while in an indoor area of any organization.

O. Reg. 364/20 provides that a face covering must be worn in a manner that covers the mouth, nose and chin in any common areas of the premises in which a person is unable to maintain a physical distance of at least two meters from another person. In essence, you do not have to wear a mask if you can maintain a physical distance.

It is important to note that your municipality or condominium corporation may have adopted a stricter rule. For example, the City of Toronto has adopted By-law 541-2020, making it a mandatory requirement to wear a face covering while in all indoor public spaces and in common areas within a condominium building, even if physical distance can be maintained between persons.

Can a Condominium Corporation pass a Mask Policy if the municipality does not have a mask by-law in place?

Yes, a condominium corporation can implement a temporary policy that can be passed by way of Board resolution. Some municipalities, such as Toronto, have made it mandatory for condominiums to adopt such a policy. Please see our COVID-19 Bulletin No. 27 regarding mandatory face mask policies in Toronto.

A mandatory face mask policy must outline its rational and enforcement. The policy will be in place until further notice following the guidance of Public Health Authorities. There must be exceptions for those not required to wear a mask (e.g. those who are exempt due to specific health conditions or children under the age of 2). We recommend seeking legal advice if you are considering implementation of a mandatory mask policy in your condominium.

Please also see here for more information about face coverings and face masks in Ontario.

Should residents be health screened when entering a condominium?

As of September 26th 2020, employers are required to conduct daily health screenings on their employees. Accordingly, it is recommended that condominium corporations screen workers that enter the premises to reduce the risk of transmission of COVID-19 within the condominium community. Screening should include a temperature-taking, self-screening protocol, as well as the requirement to execute a COVID-19 questionnaire to confirm the individual is not at high risk for transmitting the virus. This recommendation applies whether the individuals are permanent employees or contract workers. In addition to the screening of employees and agents of the Corporation, we strongly recommend that condominium corporations require all parties who enter on the premises, including suppliers, be required to execute a COVID-19 questionnaire upon entry. This is even more critical in condominiums which have a more senior and therefore, high risk, community.

In this regard, please refer to our previous COVID-19 Bulletins on proper protocols and procedures to be implemented and followed by condominium corporations.

Please also ensure that you speak with your legal counsel if you do not already have COVID-19 protocols and policies in place to help manage the risk of transmission of the virus within your condominium community and require assistance with respect to drafting and/or implementing the same.

If you have any questions, please do not hesitate to contact anyone on our team:

Richard Elia

1-866-446-0811 ext. 801

Patricia Elia

1-866-446-0811 ext. 802

Antoni Casalinuovo

1-866-446-0811 ext. 808

Ashley Winberg

1-866-446-0811 ext. 806

Megan Molloy

1-866-446-0811 ext. 805

Victor Yee

1-866-446-0811 ext. 810

Jonathan Wright

1-866-446-0811 ext. 603

Julia White

1-866-446-0811 ext. 824

All of the information contained in this article is of a general nature for informational purposes only, and is not intended to represent the definitive opinion of the firm of Elia Associates on any particular matter. Although every effort is made to ensure that the information contained in this newsletter is accurate and up-to-date, the reader should not act upon it without obtaining appropriate professional advice and assistance.

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