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Ontario’s Cautious Reopening Plan

As the US, the UK, Israel and much of Europe reopen, clients are emailing me with expectations that life is returning to normal in Canada and, specifically in Ontario. Often, I am the first person to tell international clients of Ontario’s Reopening Plan.


The very first thing I must make clear, is that there is currently no exemption to the 14 days quarantine requirement upon entering Canada for those who have been fully vaccinated. Thankfully there are now numerous media reports that this may soon change.


Regarding Ontario, the most recent Stay at Home Order ended on June 2, 2021. However, plans for reopening in Toronto and in Ontario remain cautious. On May 30, 2021, the Government of Ontario, released its Roadmap to Reopen, a 3-step plan to gradually lift public health measures. The 3 steps are based on:

  • the province-wide vaccination rate; and

  • improvements in key public health indicators, such as

    • hospitalizations;

    • ICU occupancy; and

    • new admissions and case rates.

Ontario is to remain in each of the 3 steps for at least 21 days. If at the end of each 21-day period, if residents have met vaccination thresholds and case trends are acceptable, then the province will move to the next step.


Step 1 focuses on outdoor activities allowing small groupings and limited retail. Step 1 is to begin after 60% of Ontario’s adults are vaccinated with at least one dose of a Covid-19 vaccine and there are acceptable public health indicators. The province was to enter Step 1 the week of June 14, 2021. However, current vaccination rates are already over 70% for the first dose, thus, the province has changed its plan before implementing it. Ontario will now enter Step 1 on Friday, June 11, 2021.


Step 1 will allow:

  • Outdoor dining with up to 4 people per table;

  • Outdoor fitness classes, personal training and sports training up to 10 people;

  • Non-essential retail at 15% capacity;

  • Outdoor religious services, rites and ceremonies with capacity limited to permit physical distancing of 2 meters;

  • Outdoor pools and wading pools with capacity limited to permit physical distancing of 2 meters;

  • Outdoor zoos, landmarks, historic sites, and botanical gardens with capacity limits; and

  • Campsites, campgrounds, and short-term rentals, and overnight camping at Ontario Parks.

According to the plan, Ontario must remain in Step 1 for at least 21 days. If at the end of 21 days, 70% of eligible adults are vaccinated with one dose ( this is already the case) and 20% of adults with two doses, and there are public health indicators are positive, Ontario will move to Step 2.


Step 2 will focus on expanding outdoor activities and allowing indoor services with small numbers of people wearing face coverings. This will include:

  • Outdoor gatherings of up to 25 people;

  • Indoor gatherings of up to 5 people and other restrictions;

  • Outdoor dining up to 6 people per table;

  • Outdoor sports and leagues;

  • Non-essential retail at 25 percent capacity, essential retail at 50 percent capacity;

  • Personal care services where face coverings can be worn and with capacity limits;

  • Indoor religious services, rites or ceremony gatherings at 15 percent capacity; and

  • Outdoor waterparks and amusement parks with capacity limits; and

  • Fairs and rural exhibitions with capacity limits.

Again, Ontario is to remain in Step 2 for at least 21 days. If at the end of 21 days, the province has vaccinated 70% to 80% of adults with one dose (it already has) and 25% with two doses, and public health indicators are positive, Ontario will move to Step 3.


Step 3 is to focus on expanding but still restricting access to indoor settings. As indoor dining is not contemplated until Step 3 it seems that we will be limited to restaurant patios for some time. Fortunately, outside dining should coincide with warmer summer weather.


Given the recent success rate of the first dose, one might ask: Why are Canadians not getting their second dose? The answer is that provincial governments have delayed administering second doses by as much as 4 months. With more vaccines arriving, the growing expectation is that lengthy wait periods will shorten. In sum, Canadians appear very willing to vaccinate; the low rate of second dose vaccination, at least to this point, is due to a lack of supply, not demand.


Given that single dose vaccine rates in Ontario are already at that required for Step 3, Ontario’s Roadmap targets seem very achievable. But this assumes sufficient vaccine supply for second doses and that new variants do not upset health indicators. I am reasonably confident, nonetheless, that Canada will, in time, be among the countries of the world with the highest rate of vaccination.


Lastly, I want to point out that Ontario’s Roadmap is, to my knowledge, the most restrictive of all Canadian provinces. People residing in many parts of the country - British Columbia, Alberta and Quebec, to name a few, are subject to far fewer Covid-19 related restrictions. As for Ontario, given the discrepancies between the Roadmap and the reality from the onset, I think our Covid-19 recovery will be both cautious and unpredictable. It is therefore imperative that you to check current federal and provincial restrictions and requirements before you make your own plans!


This update has been compiled with the latest available information for the general information of Border Law clients and other interested parties. This Update is not comprehensive and should not be relied upon without appropriate legal advice.

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