No. The reduced level depends on a qualifying targeted employment area or infrastructure investment under the applicable rules. Regional-centre participation by itself does not establish that the lower capital threshold applies.
Ask for the category evidence
Identify the project’s claimed basis and request the documents supporting it. Counsel should review the relevant location, enterprise and project facts, including the applicable filing date. Your municipality in Ontario does not change the requirement.
Do not commit based solely on an advertised minimum or assume that additional fees count toward any missing qualifying capital. Put the request in writing and address it to the party holding the answer. The issuer holds the offering documents and the economic report.
The regional centre holds its designation materials and its relationship to the project. Your counsel holds nothing until you obtain those and pass them on, which is the step most often skipped. Hypothetical example: an offering for a warehouse robotics facility relies on an area designation prepared some time before the subscription is signed.
Ask when the analysis was prepared, what it relied on, and whether it still applies at the date your petition would be filed. Confirm the underlying conditions separately: capital at risk in a new commercial enterprise, the required job creation, and the investor’s own engagement in that enterprise.