R&D Tax Credit Notification Rules: Are You Compliant?

In 2021, the government launched an investigation into fraud and error in the R&D tax relief schemes and established an estimate for a cost to the taxpayer of £1.13 billion. This level of error is unacceptable, and HMRC launched an in-depth review of the processes leading to ineligible claims being approved and how to stop them.

Alongside increased compliance checks and the staff working on them, the government recognised the risks posed by unscrupulous R&D tax advisors and fraudulent agents submitting claims for companies without their knowledge.

New rules and regulations were introduced to combat these dishonest claims, including the requirement for an Additional Information Form (AIF) to be submitted with every claim. With these new measures, HMRC introduced the claim notification form (sometimes referred to as “pre-notification”).

What is the claim notification form?

The claim notification form is an online form that companies fill in to let HMRC know that their company will be making a claim for R&D tax relief/expenditure credit. It is a requirement for first-time claimants and for those who have not claimed in the last three years. Eligible businesses need to notify HMRC by submitting a claim notification form.

It can be submitted by a representative of the company or an agent acting on behalf of the company. The claim notification form requires basic company information and project information.

If you have previously filed a Company Tax Return on paper, you should submit a claim notification form to prevent any issues or delays when HMRC processes your claim.

What information do you need to provide in a claim notification form?

• Unique Taxpayer Reference (UTR)
• Contact details of the main senior internal R&D contact responsible for the claim
• Contact details of any agent involved in the R&D claim (e.g., R&D tax consultant who helped prepare or advise on the claim or accountant who helped make the claim)
• Accounting period start and end date for which you’re claiming R&D tax relief/expenditure credit
• Period of account start and end date
• High-level summary of the planned R&D activities

Free Resources: Streamline Your R&D Tax Relief Claims

Navigating R&D tax credit requirements can be challenging, especially with new forms like the claim notification form. To make the process easier, we’re offering two free resources:

• Schedule of Qualifying Projects Template – This template helps you organise and evaluate each project’s eligibility, saving you time and reducing risk.
• R&D Activities Boundary Diagram – A visual guide to clarify the boundaries of claimable activities, helping you avoid common pitfalls.

Download both tools for free to ensure your R&D claim is comprehensive and compliant with HMRC’s latest requirements.

Do you need to submit a claim notification form?

It’s important to establish this clearly, as your claim may be deemed invalid without your claim notification form or if it is filled incorrectly.

1. Which accounting period are you claiming for?

This requirement only applies to accounting periods beginning on or after 1 April 2023. Any claims for accounting periods before this can be submitted without a claim notification form.

2. Has your company claimed for R&D activity before?

Companies claiming for the first time for periods beginning on or after 1 April 2023 must submit a claim notification form. First-time R&D tax claimants with claims before this period do not need to submit a claim notification form.

3. Was your last R&D claim in any of the previous three years?

Claimants who have claimed for R&D tax credits before will need to submit a claim notification form if the last claim was made more than 3 years before the last date of the claim notification period.

Those who have made more recent claims need not submit the claim notification form.

When is the deadline to submit the claim notification form?

The claim notification period is six months after the end of the period of account that you are claiming.

The company can notify HMRC of its intention to claim for this accounting period at any time during the claim notification window.

12-month periods of account

For most companies with a 12-month accounting period, the claim notification period is 18 months from the first day of the accounting period.

For example, a company's accounting period and period of account run from 1 April 2025 to 31 March 2026. This means the period of account and the accounting period are the same 12-month period.

The claim notification window starts on the first day of the accounting period; in this instance, 1 April 2025.

The claim notification window ends six months after the end of the period of account in which the accounting period containing the claim falls, in this instance, 30 September 2026.

Longer periods of account

Claims which cover a longer period of account (e.g., 1 January 2024 to 31 March 2025) cover two different account periods (1 January 2024 to 31 December 2024 and 1 January 2025 to 31 March 2025).

In this instance, the window to submit the claim notification form is between 1 January 2024 and 30 September 2025, i.e., 6 months after the end of the period of account.

Accounting period vs period of account

An accounting period must be equal to or less than 12 months, as it is the period covered by a Company Tax Return (CT600). A period of account can exceed 12 months; it is the period for which a company prepares its accounts and can be extended.

In the vast majority of cases, a company's accounting period is the same as its period of account.

What if you are making multiple claims?

Companies may claim for an earlier accounting period after the last date of the claim notification window for the current period. For example, a company making a claim for a period ending 31 December 2024 after the last date of the claim notification period (30 June 2026) for the current period (period ending 31 December 2025). This claim would not be considered part of the 3-year exemption, and the company would have to submit a new claim notification for the current year's claim to be valid.

However, the company may be able to claim through the long period of account exemption. If the company has a long period of account that covers both the earlier period and the current period, then a separate claim notification for the current period would not be required. This is because the claim notification covers the whole of the period of account.

If you have any questions or need assistance with your R&D tax credit claim, feel free to call us at 0207 118 6045 or message us, and we'll be pleased to call you back.

We're here to help guide you through the complexities and ensure you maximise your R&D investments.