The government has announced plans to remove the R&D Claim Notification Form requirement, alongside proposals to simplify the Additional Information Form and review several areas of R&D tax legislation.
These are welcome proposals. Claim notification has introduced an additional deadline which can prevent companies from accessing relief even where their underlying R&D activities and expenditure qualify.
However, an announcement is not passed legislation. The announcement does not change the law currently in force.
Claim notification removal proposed for April 2027
The government intends to legislate to remove the Claim Notification Form requirement through Finance Bill 2026 to 2027.
Until the law changes, companies and their advisers should continue to check whether notification is required and ensure that any applicable deadline is met.
Could this help companies which have already missed notification?
Consider a company with a straightforward 12 month accounting period and period of account ending on 30 June 2025. Assuming notification was required and no valid claim had been submitted within the notification period, its notification deadline would have been 31 December 2025. Its normal corporation tax amendment deadline would be 30 June 2027, this was the R&D claim deadline before notification became law in 2023.
Read literally, removing notification for claims made on or after 1 April 2027 might give that company an opportunity to claim between 1 April and 30 June 2027 without having submitted notification in the normal corporation tax amendment window.
However, this is a possible implication not an established entitlement or confirmed. The “devil” will be in the detail of the legislation.
The legislation could preserve the effect of an earlier notification failure, or otherwise limit how the removal applies. We may not know the final position until the legislation is passed. Annoucements cannot override the existing statutory requirements or provide a legal basis for a claim which those requirements prevent.
Companies which have already missed notification should therefore keep their position under review. Those which can still meet their notification deadline should continue to do so. The proposed removal should not be treated as a reason to let an existing deadline pass. It is good news that removes an administrative burden which is out of sync with other deadlines like 9 months to file accounts, 12 months to file a tax return, and 24 months from the period end to amend a tax return.
The Additional Information Form is to remain
The government has announced plans to simplify the Additional Information Form, or AIF, from autumn 2027.
These include reducing unnecessary duplication, improving questions about contracting and externally provided workers, providing greater clarity on project information requirements and clarifying information about the Enhanced R&D Intensive Support intensity ratio.
These are useful areas to address. Clear questions should help companies provide relevant information and understand what HMRC expects, without repeating the same material across different parts of the form.
The practical benefit will depend on the revised form and its supporting guidance. Until changes are implemented, claimants must continue to comply with the existing AIF requirements.
Three areas of legislation identified for review
The first is the intensity ratio used for Enhanced R&D Intensive Support, known as ERIS. The review will consider clarity around the definition of total expenditure and the complexity of the aggregation rules. These calculations can determine whether a company qualifies for ERIS, so uncertainty can have a direct effect on the relief available. Including an “aritificial” expeniture like depreciation which is cancelled out in the computation tax adjustments has always seamed odd to those that understand corporation tax.
The second is the PAYE and National Insurance contributions cap. Any resulting changes could be important for companies whose payable relief is restricted. The law on exemption is worded so harshly it is almost impossible for any SME to be exempt so reform is welcome.
The third concerns going concern status, including circumstances in which a company loses that status for technical reasons despite a viable trade continuing to exist.
These are areas identified for review, rather than agreed amendments. Companies should continue to assess their claims under the current legislation.
Other administrative developments
HMRC is also reviewing its R&D Expert Advisory Panel and gathering feedback on the targeted advance assurance pilot. These developments may influence future administration.
What should companies do now?
The immediate priority is to protect claims under the rules currently in force. Companies should continue checking notification requirements, meeting applicable deadlines and preparing the technical explanations and expenditure records needed to support their claims.
The proposed removal of claim notification is welcome. It could remove a procedural barrier with serious consequences for otherwise qualifying claims. However, a Budget announcement states an intention but does not change the law. We need to see the legislation.
For companies which have already missed notification, the legislation will be particularly important. The change implies some degree of redemption might be possible but we will not know until the the legislation becomes law.
If you would like advice on your company’s R&D claim, notification requirements or a missed deadline, contact RandDTax.
Christopher Toms MA MAAT
Compliance Director RandDTax
This article discusses the Budget 2026 proposals. The proposed legislative changes have not yet become law, and their final scope, including the treatment of previously missed notification deadlines, will depend on the legislation as enacted. This article provides general information rather than advice on an individual company’s circumstances.