Rahman v. Canada (Citizenship and Immigration), 2026 FC 1106 : Quebec Investor Class Applicants Must Provide Sufficient Evidence of a Genuine Intention to Reside in Quebec

In Rahman v. Canada (Citizenship and Immigration), 2026 FC 1106, the Federal Court considered whether a visa officer reasonably refused a permanent residence application under the Quebec Investor Class because the Applicant had failed to establish a genuine intention to reside in Quebec. Although the Applicant had obtained a Quebec Selection Certificate (CSQ), the Court confirmed that obtaining a CSQ does not, by itself, establish the separate requirement of intending to reside in Quebec. The Officer was entitled to assess the Applicant’s past conduct, present circumstances, and future plans, including his preparation for relocation, proposed business, knowledge of Quebec, and efforts concerning housing, schooling and French.

Key Principle

An applicant under the Quebec Investor Class must independently demonstrate an intention to reside in Quebec. The assessment of intention is inherently subjective, but officers may consider all available indicia, including past conduct, present circumstances, and future plans. Where an applicant is repeatedly advised of the evidence required to establish that intention, the burden remains on the applicant to provide meaningful and supporting evidence. A vague business plan, minimal preparation for relocation, limited knowledge of Quebec, and unsupported assertions may reasonably lead an officer to conclude that the required intention has not been established.

Background

Mr. Rahman, a citizen of Bangladesh, obtained a CSQ in July 2023 and applied for permanent residence under the Quebec Investor Class in December 2023. He proposed to relocate his family to Quebec and establish a ready-made garment manufacturing and retail business.

In May 2024, the Officer requested evidence concerning his relocation preparations, including housing and school searches, French studies, divestment of assets, previous travel to Quebec, a settlement plan and detailed business plans. Mr. Rahman provided limited documentation. He had visited Quebec only once, for one day, in 2022, and had made little effort to investigate housing, schools or French-language training. He also provided a brief support letter from a friend in Quebec.

The Officer later interviewed Mr. Rahman and again advised him of the need to demonstrate his intention to reside in Quebec. Following the interview, the Officer refused the application.

Court Findings

• Intention to Reside in Quebec Is a Separate Requirement

The Court confirmed that receiving a CSQ does not automatically establish the intention-to-reside requirement. The Officer was required to make an independent assessment of whether Mr. Rahman genuinely intended to settle in Quebec.

• The Officer Properly Considered the Available Indicia

The Officer reasonably considered Mr. Rahman’s lack of concrete preparations, limited knowledge of Quebec, minimal travel to the province, lack of French preparation, limited housing and school research, and inadequate business planning.

• The Business Plan Was Reasonably Found to Be Vague

The proposed business plan provided little information concerning the garments to be produced, intended market, projected revenues or operational details. Mr. Rahman’s answers during the interview also demonstrated limited knowledge concerning wages, staffing and the proposed business location.

• Unsupported Assertions Were Insufficient

Mr. Rahman claimed to have divested substantial assets, but provided no documentary evidence. Similarly, an email relied upon to establish that he had investigated a prospective business location did not demonstrate that the meeting concerned a business location.

• More Was Reasonably Expected for a Major Relocation

The Court held that relocating an entire family and establishing a new business in Quebec is a major life-changing event. While applicants may reasonably delay some preparations, they cannot simply do nothing while their application is pending. Some meaningful engagement with the proposed relocation was reasonably expected.

Outcome

The Federal Court dismissed the application for judicial review. The Court found that the Officer reasonably concluded that Mr. Rahman had failed to establish a genuine intention to reside in Quebec. No question was certified.

Case Citation:

Rahman v. Canada (Citizenship and Immigration), 2026 FC 1106