HMRC’s R&D Claim Notification requirement has become an important aspect for companies to think about before embarking on an R&D tax relief claim. The rules are designed so that companies claiming for the first time or those who have not made an R&D claim in recent years must pre-notify HMRC of their intention to make a claim.
When is claim notification required and what is the deadline?
The rules apply to accounting periods beginning on or after 1 April 2023.
The deadline for filing a Claim Notification Form (CNF) is linked to the company’s period of account. The notification period starts on the first day of the period of account and ends six months after the end of that period. For a company with a straightforward 12-month period of account, this will usually mean that the form must be submitted within six months of the year end.
For example, a company with a 31 March 2026 year end would have until 30 September 2026 to notify HMRC. For a 31 December 2025 year end, the equivalent deadline would normally be 30 June 2026.
The recent claim exemption
A company may be exempt from the CNF requirement if it has made a valid R&D claim within three years of the claim notification deadline. The exemption therefore applies to the majority of companies who regularly make R&D claims but what counts as a “valid” claim isn’t completely straightforward.
An R&D claim is valid unless:
- HMRC has rejected the claim (by removing it from the Company Tax Return)
- The claim is for an accounting period beginning before 1 April 2023 and was made by amending the tax return and the amendment was received on or after 1 April 2023
As time passes the second point will start to fall away and simplify things.
Where the position is uncertain, submitting a protective notification can be a sensible way to preserve the company’s ability to claim.
Where notification fits in with the wider claim process
Submitting a Claim Notification Form is very much the first step to making a claim and does not replace a full technical report or the Additional Information Form (AIF). Claimants still need to include the R&D claim within the Corporation Tax return and simultaneously file an AIF for the period.
Filing a CNF gives you the option of later going on to make a full claim, rather than being an obligation to file one.
What the Claim Notification Form covers
The CNF is relatively simple to pull together compared to the full technical report needed for the Additional Information Form later on in the process. It asks for some basic company and contact details alongside a high-level summary of the R&D activities. The high-level summary should be enough to demonstrate that the project meets the definition of R&D, but you don’t need to go into detailed evidence.
A potential complication: periods of account and longer accounting periods
Most companies will have a standard 12-month period of account that matches the Corporation Tax accounting period being claimed for. However, the CNF obligations can be complicated slightly where accounts are prepared over a period longer than 12 months. A Corporation Tax accounting period (CTAP) cannot exceed 12 months, so a longer period of account will contain more than one Corporation Tax accounting period.
For claim notification purposes, the deadline is driven by the period of account rather than the CTAP(s). So only 1 claim notification form is needed where a period of accounts exceeds 12 months.
Practical approach
For companies, the practical approach is to review the notification position as a first step for both first-time and regular claimants. This will give certainty as you progress into making a full claim and avoids being tripped up later on.
If in doubt, submitting a Claim Notification Form ahead of the 6-month deadline is usually the most sensible course of action.
Joe Lock is Assistant Corporate Tax Manager – call 01242 776000 or email joe.lock@randall-payne.co.uk to arrange to discuss anything in this article.