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HMRC has opened a new pilot programme offering advance assurance on research and development (R&D) tax credit claims.
The pilot runs until May 2027 and gives eligible small and medium-sized businesses the chance to get pre-clearance on aspects of a claim before it is submitted.
For accountants supporting clients through the R&D relief process, this is a development worth understanding now.
What the pilot covers
Advance assurance is a voluntary service that confirms whether a claim is likely to qualify for relief.
Under the pilot, eligible businesses can submit up to two applications, with each one covering a single project and focused on one of the following areas:
- Whether a project qualifies as R&D
- How overseas expenditure should be treated
- Who is entitled to claim when work has been contracted out
- Whether a claimant meets the criteria for exemption from the PAYE and National Insurance Contributions cap.
These are areas where uncertainty tends to arise most often in practice, particularly around the newer overseas expenditure restrictions, which remain relatively untested.
Why is this pilot different?
If this doesn’t sound very new, it is because advance assurance itself is not a fresh concept, as it has existed since 2015, but the uptake has remained low.
The service was previously limited to first-time claimants with turnover under £2 million and fewer than 50 employees.
Perhaps unsurprisingly, many businesses were reluctant to invite a compliance review with no guarantee of a positive outcome.
This pilot is intended to change that perception and HMRC has set out three broad aims:
- Giving businesses more certainty over a claim’s eligibility
- Improving the customer experience of accessing relief
- Helping businesses plan R&D investment with greater confidence.
What it means for error and fraud
SMEs have historically shown higher levels of error and fraud within the R&D relief regime, so focusing the pilot on this group is a sensible starting point.
A more effective assurance process should help HMRC identify risk earlier while giving compliant businesses a smoother route to relief.
HMRC has committed to processing applications within 40 calendar days, although it has warned that the service may be paused at times to maintain consistent turnaround.
A global approach to R&D tax relief assurance
What HMRC is offering has already been trialled in a number of overseas jurisdictions that operate some form of pre-approval for R&D incentives.
Australia requires mandatory registration of R&D activities with AusIndustry, alongside an optional advance finding businesses can request for current or future projects.
Meanwhile, Canada offers an optional pre-claim review that determines whether a project meets its definition of scientific research and experimental development before a claim is filed.
What to watch out for next
A number of questions remain unanswered. How HMRC will resource the service, who will handle more technically complex cases and how learnings from the pilot will feed into wider guidance are all still to be confirmed.
For now, accountants advising clients on R&D claims should keep the pilot on their radar. Its success will depend on genuine engagement from businesses willing to test the process, and on HMRC using what it learns to improve consistency across the wider relief system.
Given how much the R&D regime has changed in recent years, this is unlikely to be the final version of advance assurance either.
If you support clients with R&D tax relief claims and want to discuss how the pilot might affect a particular project, get in touch with our team.
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