In this KnowledgeBank article, we take a look at claim notification for R&D tax relief claims and the requirements of the claim notification form. This requirement has been introduced as part of wider reforms to help reduce error and fraud because the government believes that genuine research and development will have been planned. We cover everything you need to know from who needs to pre-notify HMRC and when, to what to include in the claim notification form.
What is R&D claim notification?
R&D claim notification is the process of letting HMRC know that you will be making a claim for R&D tax relief. It is a requirement for first time claimers and for those that have not claimed in the last three years (more on this below). Eligible businesses need to notify HMRC by submitting a claim notification form. Claim notification is one of several measures introduced to tackle fraud in R&D tax claims.
You may also come across the term ‘pre-notification’ in reference to this requirement. However, HMRC prefers ‘notification’ to avoid any suggestion this should take place before R&D is carried out (as opposed to before the claim is made).
Do I need to notify HMRC that I am planning to claim?
For R&D tax claims relating to accounting periods beginning on or after 1 April 2023, you must notify HMRC if you’re:
- Claiming for the first time, or,
- If your previous claim was made more than three years before the last date of the claim notification period, or,
- If you’ve submitted a claim within the last three years but it doesn’t meet certain criteria as detailed below.
How do I check if the three-year exemption applies?
If you are claiming R&D tax relief for the first time and your accounting period starts on or after 1 April 2023, you will need to submit a claim notification form.
If you have made a claim previously, you will need to check whether it was submitted in the three year window – and whether it was submitted by an original or an amended Corporation Tax return. To work out the relevant three year window, calculate the last day of the claim notification period (six months from the end of your accounting period) and count back three years. If you submitted a previous claim within this window, you should not need to notify, but there are some transitional provisions to be aware of relating to how your claim was submitted.
Transitional provision – amended returns for accounting periods beginning before 1 April 2023
When considering if any claims were submitted within the three-year window, it is necessary to ignore any claims relating to accounting periods beginning before 1 April 2023 which were submitted by way of an amended return after 1 April 2023. Claims submitted on original returns are not impacted.
For example, a company with a December year end is considering whether it needs to notify HMRC of its intention to submit a claim for the year ended 31 December 2024. It previously submitted a claim for the year ended 31 December 2023 via an amended return on 16 October 2024. That claim would need to be ignored and, if no other claims had been submitted between 1 July 2022 and 30 June 2025, the company would need to notify for its year ended 31 December 2024 (or submit the R&D claim itself) by 30 June 2025.
Error in HMRC guidance
This nuance has been included in the notification legislation since its introduction. However, the rules are undoubtedly complex, so much so that HMRCs own guidance on this point was incorrect for a period during 2024.
In May 2025, HMRC acknowledged that the guidance which appeared in CIRD183000 between 8 September 2024 and 17 October 2024 provided an incorrect interpretation of the legislation and may have led some companies to believe that they didn’t need to notify, when they did.
As a result, HMRC has confirmed an ‘administrative easement’ under which it will permit R&D claims by affected companies that haven’t notified, where:
- A company made a valid claim to R&D in an amendment to a return for an accounting period beginning before 1 April 2023, which was submitted to HMRC between 1 April 2023 and 30 November 2024 inclusive; and
- The accounting period for which a claim notification was not delivered, but ought to have been, had a claim notification period ending between 8 September 2024 and 30 November 2024.
What should I do next?
Affected companies need to contact the R&D Policy team with specified information, including the date the amended return containing the R&D claim, which the company was relying on to meet the claim notification requirement, was submitted.
HMRC will then review the information and, if it finds that the conditions have been met, will invite companies to submit a claim for the relevant period.
When do I need to notify HMRC?
If you intend to make a claim for an accounting period beginning on or after 1 April 2023 and need to notify HMRC, you must let HMRC know within six months of the end of the accounting period you wish to claim for. For example, a company with a 31 March 2024 year end would need to pre-notify HMRC on or before 30 September 2024.
Find out more about how far back you can claim R&D tax credits.
Who can make a claim notification?
R&D claim notifications can be made by a representative of your company or an agent acting on its behalf.
Claim notification form
In the following sections, we answer all of the questions in relation to the claim notification form. If you have additional questions, please contact ForrestBrown and our experts will be happy to help.
What information do I need to make a claim notification?
The following details are required to complete a claim notification form:
- Your company’s Unique Taxpayer Reference (UTR).
- The main senior internal R&D contact in your company.
- Contact details of any agents who provided advice in relation to any part of the R&D claim, helped prepare all or parts of the claim, or are involved in making the claim.
- Accounting period start and end dates (these must match the dates on your Company Tax Return).
- The period of account start and end dates.
- A high-level summary of planned R&D projects.
How do I submit a claim notification form?
Claim notification forms can be submitted online, using either a Government Gateway user ID or an email address.
What happens once I’ve submitted a claim notification form?
You will receive a confirmation email from HMRC containing a reference number which you need to keep a note of. If you decide to continue your claim, you will need to put an ‘X’ in box 656 of your Company Tax Return to tell HMRC you’ve submitted a claim notification form. No further action is required if you decide not to continue your claim.
Remember, you must submit an Additional Information Form when making a claim.
Can I still claim R&D tax relief if I haven’t submitted a claim notification form?
If you were required to notify HMRC but did not submit the notification form, you will be unable to claim R&D tax relief for that period. Unless the three-year exemption applies to your company, your claim will be removed from your Company Tax Return and relief denied regardless of whether your R&D would otherwise be eligible.