HMRC introduced the R&D claim notification rules in April 2023, with the objective of allowing pre-claim risk assessments and cutting down on abuse of the system. The legislation is complex to the extent that in May 2025, HMRC acknowledged that the guidance which appeared in its Corporate Intangibles Research and Development Manual at CIRD183000 in Autumn 2024 was incorrect. It might have led some companies to incorrectly believe that notification was not required.
As a result of their error, HMRC announced an “administrative easement”. However, that period is now over and the legislation is being applied rigorously to the extent that if the notification window is missed, a company could lose its R&D tax relief for that year - permanently!
The new rules apply to all companies with APs starting on or after 1 April 2023. Notification is required if the company is making its first R&D claim or has not submitted a claim within the previous three years. However, not all claims count in the context of this three-year review. If a company’s R&D claim was filed on or after 1 April 2023, related to an AP that began before 1 April 2023, and was submitted as an amendment to a previous return, it is excluded and notification for a later period will still be required.
R&D notifications can be made online and there is plenty of information about the process and what is required, as well as a link to the e-form at:
- Additional information you must submit before you claim for Research and Development tax relief - GOV.UK
- Tell HMRC you want to claim Research and Development (R&D) tax relief - GOV.UK
- CIRD183000 - R&D Tax Reliefs: reformed reliefs: claims process: pre-notification of claims - HMRC internal manual - GOV.UK
These publications from Markel Tax were correct at the time of going to press and should be considered as principles-based guidance only. To check current validity, call the Markel Tax helpline. ICAEW (as distributor) disclaims all liability for any errors or omissions.
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