HMRC has announced the launch of a new targeted Advance Assurance pilot for R&D tax relief claims, beginning on 18 May 2026 and running for an initial 12 month period. The announcement was circulated to members of the R&D Communication Forum and represents another significant development in HMRC’s ongoing reshaping of the R&D compliance environment.
The new pilot is available to eligible SMEs and is intended to provide earlier certainty on specific technical aspects of an R&D claim before the Corporation Tax return is submitted.
The guidance for the pilot can be found here:
HMRC Targeted Advance Assurance Guidance
What Is the New Targeted Advance Assurance Pilot?
The pilot is designed as a narrower and more focused version of HMRC’s existing Advance Assurance process. Rather than reviewing an entire claim, HMRC will provide views on up to two specific technical areas relating to a single R&D project.
Applicants can request assurance on:
- whether a project meets the definition of R&D for tax purposes
- whether overseas expenditure qualifies
- whether contracted out R&D qualifies
- whether the company qualifies for an exemption from the PAYE and NIC cap
Separate applications must be submitted for each issue selected.
HMRC states it aims to respond within 40 calendar days where sufficient information is provided upfront.
The service is voluntary and free of charge. Importantly, it does not replace the normal claim process. Companies will still need to comply fully with Claim Notification requirements, submit an Additional Information Form and include the claim within the Corporation Tax return.
Contracted Out R&D Continues to Be a Major Risk Area
One of the most interesting aspects of the pilot is HMRC specifically including contracted out R&D as an area suitable for advance assurance.
That is not surprising.
Contracted out R&D has become one of the most contentious and uncertain parts of the regime, particularly following the merged RDEC and ERIS rules introduced from April 2024. HMRC’s recent guidance at CIRD161000 attempts to explain its interpretation of the legislation, but in practice significant uncertainty remains.
Historically this has been an area where HMRC guidance has shifted repeatedly. There have also been several tribunal defeats where HMRC’s own interpretation was criticised or revised. Despite the legislative rewrite, the new rules have arguably not simplified matters at all.
In many ways, a far simpler system would have been for the company physically undertaking the R&D work to claim relief directly. That approach would likely have reduced complexity, reduced disputes and avoided much of the uncertainty now facing claimants and advisers.
The compliance risks here are also increasing.
The Additional Information Form now specifically asks for details of companies to whom R&D work has been contracted out, including company registration details. That creates a much clearer mechanism for HMRC to identify situations where two parties may both be attempting to claim for the same R&D activity.
Businesses and advisers should assume that duplicate or overlapping claims are increasingly likely to be identified.
Additional Information recent updates
HMRC has also confirmed several minor amendments to the Additional Information Form.
The changes include:
- A challenge question for SIC codes they view as unlikely for R&D activity.
- allowing email consent within the form and verifying the agent email address
- additional prompts to help users verify entries
- preventing future accounting period end dates from being entered
- clarifying company registration number requirements for subcontractors
- clarifying trading and operating expense disclosures
While these changes appear administrative, they continue the broader trend of HMRC tightening data collection and improving its ability to risk assess claims automatically.
New Guidance on Pre-Contract Activity
HMRC has also added guidance at CIRD161000 covering pre-contract activity carried out by potential contractors during bidding or preliminary phases.
The guidance can be found here:
This area may become increasingly important for software consultancies, engineering contractors and development businesses where significant technical work is undertaken before formal contracts are signed.
A Wider Shift Towards Pre-Claim Compliance
Taken together, these updates reinforce a clear direction of travel.
HMRC increasingly wants technical positions addressed before claims are submitted, with more structured disclosure and more opportunities to identify higher risk claims early in the process.
For genuine claimants with strong technical evidence, the pilot may provide useful certainty in particularly complex areas.
However, businesses should be cautious about assuming that advance assurance represents approval of an entire claim. The pilot is narrow in scope, highly targeted and still sits within a much more compliance driven environment than existed historically.
Careful technical analysis and robust project evidence remain essential.
If your business is dealing with complex contracted out R&D arrangements, overseas expenditure issues or uncertainty around project eligibility, professional advice before submission has never been more important.
To discuss your R&D claim or compliance position, contact us here:
Christopher Toms MA MAAT
Compliance Director
RandDTax