COVID-19 Updated Restrictions for Churches

Over the past few months, Queensland has continued to enjoy success in containing the spread of COVID-19. With less than 10 active cases as of 17 June 2020, Queenslanders are beginning to experience life in a ‘COVID-safe Australia’, and the State Government has been taking steps to reduce the restrictions on Queensland Businesses. This article talks about how the updated restrictions will apply to Churches.

New Restrictions

On 15 June, Queensland’s Chief Health Officer Dr Jeanette Young posted the Restrictions on Businesses, Activities and Undertaking Direction (No.2) (‘the Directions’) to update the current COVID-19 restrictions. This update has several implications for Churches.

Churches can now host gatherings of up to 20 people. Live-streaming services may continue to be conducted with less than 20 people. Churches wishing to host small group gatherings of under 20 people again are permitted to do so as well.

It must be noted that these gatherings must comply with both social distancing and contact tracing requirements. Churches must ensure that social distancing is observed to the extent possible which requires no more than one person per 4 square meters.

Contract tracing on the other hand requires churches to keep the contact information of all who attend these gatherings for up to 56 days. The information must include the name, address, phone number, and the date/time period in which they have attended. This information must be securely stored and must not be used for purposes other than contact tracing.

As Queensland continues to move into Stage 3 of the Roadmap to easing restrictions, churches may begin to plan the details of how their services and gatherings will operate in the future. Stage 3 is purported to commence on 10 July 2020 (subject to change) and will allow gatherings of up to 100 people.

Industry COVID Safe Plan

The Industry COVID Safe Plan for Places of Worship (‘the Plan’) offers an alternative option for Churches wishing to host larger gatherings. It outlines the guidelines and requirements for church compliance. If the Plan has been complied with, churches are permitted to go beyond the prescribed 20 persons limit up to 100 persons[1] subject to the ‘4m2 rule’[2]. In complying with the Plan, several guidelines should be observed.

Preparations before gathering 

Prior to any larger gatherings, churches should:

  • Complete the Statement of Compliancewhich is a statement declaring compliance with the Plan – and display it in a visible place on the church’s premises;
  • Complete the Checklist[3] and display it on the church’s premises;
  • Nominate COVID Safe Warden who monitors and enforces compliance with COVID safe practices;
  • Clearly display information about COVID-19 symptoms, physical distancing and hygiene requirements which can be found here;
  • Set up chairs and tables complying with social distancing requirements;
  • Clearly set up separate entrance and exit points;
  • Erect signs on lifts and meeting rooms to ensure maximum safe capacity is not exceeded; and
  • Provide markers on floor complying with the 1.5 metre social distancing requirement at locations where queues are likely (e.g. Toilets, Kitchens).   


Churches should also provide training for volunteer and paid workers. The training should:

  • Ensure that they are aware and follow the requirements of the Plan;
  • Instruct them to report to Church authorities if anyone develops symptoms, or have tested for COVID-19 and who they have been in contact with; and
  • Treat the congregation’s personal information with care.

Health and Safety Considerations

The Plan also provided several health and safety considerations that should be observed.

  • Make appropriate hand sanitizers available at the entrance and within the church’s venue;
  • Toilet facilities are to be cleaned at least twice per day, ensuring that soap, running water, and paper towels or a hand dryer are always available; 
  • Maintain adequate ventilation;
  • Develop a checklist to maintain recommended physical distancing measures at washing facilities; 
  • Limit the sharing of communal items such as bibles and pens;
  • Prepare face masks for persons displaying symptoms – then isolate them – and arrange for them to go home or to health facility; and
  • Ensure that there is no communal food being shared together.


The Plan further provides guidance on cleaning practices. Churches should:

  • Ensure that any areas of regular use are cleaned at least daily with a disinfectant or detergent;
  • Instruct volunteers or paid workers to wear gloves when cleaning and to use soap or alcohol-based hand sanitizer to wash their hands prior and after wearing gloves;
  • Clean commonly touched areas and surfaces throughout the day such as:
    • Elevator buttons;  
  • Light switches;
  • Air conditioning controls & TV remotes;
  • Handrails;
  • Tables and counter tops;
  • Doorknobs and handles;
  • Sinks;
  • Computer keyboards & mice; and
  • Chair backs. 


When taking offering, churches should recommend electronic payment or other non-touch options. However, if this cannot be done, anyone who handles money should wear disposable gloves.

In stronger language, the plan states Do not accept physical offerings such as food, flowers, etc.

Holy Communion

Receiving Holy Communion is described under the plan as a potentially “high-risk practice” for the transmission of COVID-19.

Church leaders are encouraged to “Consider modifying religious rites or rituals to avoid direct physical contact where practical. Where this is not practical, limit contact to hands. Ensure participants’ hands are washed with soap and water or hand sanitiser before and after each interaction”.

Additionally, in stronger language, the plan statesDo not use communal trays, vessels, icons, or similar.

Contact tracing requirements

In addition to all these requirements, churches must also comply with contact tracing requirements (as above).

Reporting obligations 

Persons who have a probable or confirmed case of COVID-19 must notify the church. Upon receipt of this information, the church must notify Workplace Health and Safety Queensland of each confirmed case and keep a record of each incident for at least 5 years.

Capacity management

In managing the number of people gathering at services or groups, there are several recommendations. It may be useful to set up a pre-booking system to avoid rejections at the door. Churches can also run multiple services based on the regular number of attendances. Churches should also have a system to track the number of people attending at any given time.


If there is to be singing during the service, a restriction stricter than the 4m2 rule applies to the attendees.

Singing is only permitted if there is an average of 1 individual per 7m2.

In choirs, there must be 1.5 metres between each choir singer.

Other Potential Questions

Does the Plan carry over into Stage 3?

The plan does carry over into Stage 3 with potential for revision where required.

Are Youth Groups, Sunday School, and other church related social/faith-based activities required to comply with the Plan? 

Churches wishing to operate Youth Groups or other church related social/faith-based activities must also comply with the Plan.

What about churches that run a coffee/book shop? 

Churches running coffee/book shops are required to comply with other relevant Industry COVID-safe plans in order to increase their capacity. Other plans can be found here.

Still have questions about the updated restrictions?

Contact our Client Engagement Team for an appointment with our COVID Response Team.

Authors: James Tan & Ervin Hii (student placement).


[1] Note that once stage 3 has commenced (currently scheduled for 10 July 2020), Churches in compliance with the Plan can host as many people as possible subject to the 4 square meter rule.

[2] The 4m2 rule requires that there may only be 1 person per every 4 square meter. For example, if a building is 72m2, it can only host up to 18 people.[2] If a building is 400m2 it can host up to 50 people. This limits the number of persons allowed to gather based on the size of the building. 

[3] Can be found under Appendix 1 Checklist, at page 15 – 16.

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