Not by itself. Franchisees own the enterprise, take the risk and run daily operations. The file should attach the agreement and describe the decisions the investor makes, rather than hoping the point is not raised.
Ownership and operations, not unlimited discretion
The requirement is directed at passivity, not at commercial constraint. An investor who owns the company, hires the staff, manages the cash, signs the lease and answers for the losses is developing and directing the enterprise even though a brand agreement dictates signage, systems and prices. What causes difficulty is a structure where somebody else in fact runs the business, whether a hired general manager with full authority and an absentee owner, or an arrangement so heavily managed by the franchisor that the buyer supplies capital and little else. Read the agreement with that distinction in mind and be ready to point to the clauses that leave hiring, staffing, purchasing and cash management with the franchisee. Where the shares are held jointly by spouses, identify which of them is the applicant.
Hypothetical example: a pet-grooming business is purchased by a Canadian owner who intends to hire a manager and visit monthly. A first review produces a control map: ownership documents, bank-signing authority, employment decisions and the applicant's own operating role. Those records settle whether she will develop and direct the enterprise. If the manager holds every practical power and the owner has no defined executive function, the structure may not support the route. She must either take an authentic management role or choose a business model that fits her intended level of involvement.