From 1 April 2027, the R&D claim notification form (CNF) is on its way out.

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What the Budget announced

1. The CNF is being scrapped for claims made on or after 1 April 2027. Companies will no longer have to tell HMRC in advance that they plan to submit a claim. The change will be made through the Finance Bill and covers both the merged R&D expenditure credit (RDEC) scheme and enhanced R&D intensive support (ERIS).
2. HMRC says the Additional Information Form (AIF) will be simplified from autumn 2027. No detail has been published yet, and I'm reserving judgement. Past changes to the AIF have tended to add to the workload, not reduce it.
3. The government expects more companies to claim. It estimates the two changes will cost an extra £45m in relief in 2027 to 2028, rising to £70m a year by 2031 to 2032. That's a clear sign the Treasury thinks the form has been keeping legitimate claims out.

You can read the detail in HMRC's policy paper.

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First-time claims have fallen five years in a row

HMRC published its annual R&D tax relief statistics at the end of September. In 2024 to 2025, 40,325 R&D claims were made, down 17% on the year before. Yet the total support claimed rose 5% to £8.2bn. Fewer claims, but bigger ones, the average claim is up 27%.

The first-time claimant data runs a year behind, to 2023 to 2024. In that year, just 3,405 SMEs made their first R&D claim. That's down 53% on the year before. Across both schemes, first-time claimants fell 43%, the fifth consecutive annual fall.

HMRC points to the AIF as a key driver of the wider fall in claims, which is fair enough. Its crackdown on error and fraud, when far more claims were opened to enquiry, also made smaller companies wary of claiming at all.

But from what I see week to week, the biggest hurdle for first-timers is the claim notification form. And because it only applies to periods beginning on or after 1 April 2023, these figures barely reflect it yet. Until the change takes effect in April 2027, I'd expect first-time claims to stay very low, if not fall further.

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A deadline most first-timers never heard of

For periods beginning on or after 1 April 2023, a first-time claimant has to notify HMRC within six months of its period end, or the claim is invalid. The same applies to any company that hasn't claimed in the previous three years. And a previous claim doesn't always count. If it covered a period beginning before 1 April 2023 and was made through an amended return received on or after 1 April 2023, you still need to notify.

The problem is timing. Many small companies don't speak to their accountant until they're working towards the accounts deadline, nine months after the year end. By then, the window has already closed. Unless the accountant specialises in R&D, and few do, it rarely comes up at all.

Some of the most frustrating conversations I have are with companies who come to us for the first time after their window has closed. The work qualifies. The claim doesn't.

My colleague Tom Elsbury has raised the six-month deadline with HMRC on more than one occasion. We both see it as a poorly thought-through rule. It catches out precisely the businesses the relief should be encouraging, young companies whose founders are busy doing the R&D, not tracking administrative deadlines.

To be fair to HMRC, the CNF arrived alongside the AIF and stronger compliance work, and together they've helped bring error and fraud down, from an estimated 17.6% in 2021 to 2022 to 6.4% in 2023 to 2024. But as the Treasury's own costing shows, that came at a price for genuine claimants.

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What changes from April 2027, and what doesn't

The biggest change is for first-time claimants. A company that only discovers R&D tax relief when its accounts are being prepared will no longer be ruled out by a deadline it didn't know existed. That should mean more young, innovative businesses claiming, which is the whole point of the relief.

What doesn't change is the test itself. Your project still has to seek an advance in science or technology by resolving a genuine uncertainty. If you're not sure where you stand, our guide on whether your business qualifies is a good place to start. And with the AIF staying, a well-evidenced claim matters as much as ever.

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A second window for companies that missed the deadline

HMRC's wording ties the change to the date a claim is made, not to the accounting period it covers. A company normally has two years from the end of its accounting period to make an R&D claim through its Company Tax Return. So if you missed a notification deadline, but your two-year window is still open on 1 April 2027, you may be able to claim after all.

Here's how that plays out for some common year ends, assuming 12-month accounting periods:

This is based on HMRC's published wording, and the legislation hasn't been published yet. I'll be waiting to read it before making any promises.

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Until April 2027, the current rules still apply

The change only takes effect from 1 April 2027, so a few things still hold in the meantime:

• Keep notifying. If you're a first-time claimant, or haven't claimed in the last three years, and your notification deadline falls before 1 April 2027, submit the form. It costs nothing and protects the claim.
• Don't file too early after a missed deadline. On the current wording, a claim made before 1 April 2027 without a valid notification is still invalid.
• Don't forget the AIF. It must be submitted before your Company Tax Return, or HMRC will remove the claim.

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‍The bottom line

It wasn't the Budget's headline announcement, but it fixes a rule that stopped genuine innovators from claiming over paperwork. If the UK wants to remain competitive in R&D, first-time innovators shouldn't lose their relief over a form most of them have never heard of.

Will claimants be thrilled? Sceptical? A little annoyed it didn't come sooner? Probably all three. Either way, if you were turned away because of a missed notification, it's worth another conversation.

If you're planning a first claim, or think you might fall into that second window, get in touch and we'll look at your dates together. You can read more about how we handle the full process on our R&D tax relief page.

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