The Order 2025-004 of the Minister of Higher Education under the University Investments Act, establishes the Regulation respecting university investments for which no subsidies are allocated. This regulatory framework applies specifically to university establishments and investment projects that are undertaken without direct government subsidies. Its purpose is to ensure that such investment initiatives are conducted in a manner that supports the institutions’ missions, maintains financial viability, and protects overall financial health.

Under the regulation, any university planning an investment project must provide the Minister with details about the timing of the project, the proportion of public and private funding involved, and the sources of these funds. The regulation specifies thresholds for mandatory ministerial authorization. Projects requiring approval include construction or asset maintenance projects with institutional financial commitments of $5,000,000 or more, acquisitions of immovable property with commitments of $1,000,000 or more, and agreements of emphyteusis with commitments of $1,000,000 or more. Authorization must be obtained before preparatory work begins, such as the creation of plans and specifications, or before executing sale or emphyteusis agreements.

In seeking authorization, the university must demonstrate that the project aligns with its mission, is viable, and does not threaten the institution’s financial stability. Applications must be submitted in writing and accompanied by a range of supporting documents. These include a detailed project description, an explanation of how the project furthers the institution’s mission, a certified resolution of the board of directors approving the project, an outline of costs and timelines, intended uses of spaces and surface areas, the funding structure, and an assessment of financial impacts. For real estate acquisitions or emphyteusis agreements, additional documentation is required, such as justification for the project, draft legal acts, due diligence records, and an analysis of the institution’s capacity to meet its financial obligations.

Once a project is authorized, the university is required to notify the Minister promptly of any cost variations exceeding 10 percent of the initially approved budget during execution. Furthermore, within six months of project completion, a comprehensive report must be submitted detailing the final costs, start and completion dates, and the surface areas involved. The report must also explain any significant deviations from the original cost estimate.

The regulation provisions are designed to balance institutional autonomy with accountability, ensuring that substantial investments are aligned with strategic objectives and that financial risks are carefully managed. Overall, the regulation reinforces disciplined investment practices in the higher education sector, promoting responsible stewardship of university resources while supporting the growth and development of academic infrastructure and capabilities.

Quebec (04/2025) October 21, 2025
Disclaimer: Insights are for informational purposes only and do not reflect RRI’s official position or constitute legal opinion.