May 7, 2020

Illinois Starts the Process of Reopening

Alert | Corporate, Tax & Transactional Alert

On May 5, 2020, Illinois Govern J.B. Pritzker issued a multi-phase approach to reopening the State of Illinois in light of the COVID-19 pandemic. This document, titled “Restore Illinois,” is a comprehensive approach to restoring business operations and public gatherings in Illinois in accordance with public health and safety guidelines. The document can be found here.

Essentially, Illinois will undergo a five-phase approach to reopening.  Each phase is intended to occur at different times depending on the distinct region of the state. For purposes of the reopening, Illinois is divided into four separate regions: Northeast; North-Central, Central and Southern. Both the Northeast and North-Central regions are broken down into smaller, sub-regions. The COVID-19 conditions in each region will inform when each region or sub-region will move through the five phases and is intended to apply as follows:

Phase   Description of Reopening Requirement to Move to Next Phase

   • Only essential businesses open
   • Strictest stay-at-home requirements

   • Slowing of new cases
   • Surge hospital capacity
   • 10,000 COVID-19 tests conducted per day
   • Routine COVID-19 testing for first responders and healthcare workers


   • Curb-side pick-up and deliveries for non-essential businesses
   • Outdoor activities are allowed with social distancing and wearing mask

   • Routine COVID-19 testing patients, healthcare workers and at-risk residents
   • Begin contact tracing within 24-hours of diagnosis
   • Meeting certain hospital and positive COVID-19 case benchmarks


   • Manufacturers, retail business, salons and offices reopen with strict guidelines and safety protocols, including capacity limits
   • Continue use of face masks and social distancing
   • Gatherings of 10 people or less allowed

   • Meeting certain hospital and positive COVID-19 case benchmarks
   • COVID-19 testing available regardless of symptoms or risk factors
   • Contact tracing within 24-hours of diagnosis for 90% of cases


   • Reopening of restaurants, bars, childcare centers and schools pursuant to public health guidance
   • Travel resumes under guidance
   • Gatherings of 50 or less allowed
   • Continue use of face masks and social distancing

   • Pandemic resolved
   • Vaccine available or effective and readily available treatment
   •No new COVID-19 cases over a period of time


   • Large events and gatherings allowed pursuant to certain guidelines
   • Economy fully reopens with continued safety measures

   • N/A

Currently, every Illinois region is in some degree of Phase 2, with some regions closer to moving toward phase 3 than others. As data and circumstances are assessed, a region or sub-region could be moved back to a prior phase.

Both Illinois businesses and residents will find these guidelines to reopening useful in preparing for a return to work and restoring business operations. The region and sub-region approach is thoughtful, as it allows each area to reopen at a pace that makes sense for that area’s COVID-19 cases and resources. In this regard, areas of Cook County and its collar counties that have significantly less reported COVID-19 cases and are less densely populated (making social distancing more attainable) do not have to wait for the challenges attendant to fighting COVID-19 in more urban areas are resolved. 

The attorneys at Roetzel & Andress and here to assist your business through this unprecedented time. Please contact a Roetzel attorney for practical advice and real solutions.

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