What’s changed in HMRC’s approach to R&D claims?

Over the past several years, HMRC’s approach to R&D tax relief claims has evolved significantly.

While the core UK R&D tax legislation defining qualifying activity remains largely unchanged, the way claims are reviewed, scrutinised, and processed has shifted. For businesses submitting an R&D tax claim, understanding that shift is essential.

The regime has moved from volume to verification.

Increased HMRC scrutiny of R&D Tax claims

One of the most notable changes has been the rise in enquiry rates.

HMRC has invested in specialist compliance teams and data-led risk profiling. As a result, R&D tax claims are now more likely to be reviewed in detail particularly where:

• Technical narratives lack clarity
• Project descriptions appear generic
• Costs seem disproportionate to the activity described
• The claimant has limited filing history
• The sector has historically seen higher compliance challenges

Legitimate claims remain valid. However, they must now be prepared with significantly greater precision.

Greater focus on technical detail and evidence

HMRC now places far more weight on the quality of technical explanations within an R&D claim submission.

Language such as “innovative,” “complex,” or “industry-leading” carries little weight unless supported by clear legislative alignment.

Claims are expected to demonstrate:

• The baseline state of science or technology
• The specific technological uncertainties encountered
• Why those uncertainties were not readily deducible by a competent professional
• The systematic work undertaken to resolve them

In short, narrative quality has become central to compliance.

Administrative reforms and the Additional Information Form (AIF)

Recent reforms have introduced additional procedural requirements, including:

• Submission of the Additional Information Form (AIF)
• Senior officer endorsement
• Pre-notification requirements for certain claimants

These changes are designed to increase accountability and discourage speculative or poorly prepared submissions.

Internal governance around R&D tax relief claims now matters more than ever.

A clearer boundary between qualifying and non-qualifying activity

HMRC’s messaging has consistently reinforced that the regime exists to reward genuine technological advancement, not routine commercial development.

As scrutiny has increased, claims that rely on broad or aggressive interpretations of eligibility have become more vulnerable to enquiry.

The shift has not fundamentally altered the definition of qualifying R&D. Instead, it has raised the evidential threshold required to demonstrate it.

Processing times and compliance environment

Historically, high claim volumes led to processing backlogs. While efficiencies have improved in certain areas, compliance checks can extend timelines where clarification is required.

Businesses should now consider the possibility of enquiry as part of normal claim planning and manage cashflow expectations accordingly.

R&D tax relief remains valuable, but the process is no longer informal or lightly reviewed.

What has not changed

Despite the increased scrutiny, the core legislative definition of R&D remains unchanged:

• Qualifying activity must seek an advance in science or technology through the resolution of technological uncertainty.
• Genuine R&D still qualifies.
• What has changed is the level of scrutiny applied to ensure that it does.

What this means for businesses claiming R&D tax relief

In the current compliance environment, businesses should ensure their R&D tax claims are:

• Firmly grounded in legislation
• Technically robust
• Clearly evidenced
• Proportionately costed
• Prepared with the expectation of review

The objective should not be to maximise claim value at the expense of risk. It should be to prepare a defensible submission that withstands scrutiny.

The Knight perspective

At Knight R&D, we view the increased scrutiny as a natural evolution of the regime.

The legislation has always required genuine technological uncertainty and advancement. What has changed is the level of evidential precision expected in demonstrating it.

Our approach reflects that environment. We begin with legislative interpretation, dissect projects proportionately, and prepare claims on the basis that they may be reviewed.

Clarity is more valuable than optimism. Precision is more valuable than volume.

In a compliance-led landscape, defensibility is not an optional extra. It is fundamental.