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The Claim Notification Form: Does My R&D Tax Claim Need One?

Following an investigation into error and fraud in the R&D tax scheme, HMRC introduced new measures to reduce non-compliance. One of these measures was the claim notification form, which affects all first-time claimants and those who haven’t made a claim in the last three years.

The deadline to submit a claim notification form is much earlier than the submission of the actual claim; many companies could be caught out if they don’t make their notification in time.

HMRC recently announced further guidance on the topic to clear up some confusion; more on this later.

The claim notification form is an online form that companies fill in to let HMRC know that their company will be making a claim for R&D tax relief/expenditure credit. It is a requirement for first-time claimants and for those who have not claimed in the last three years.

The form can be submitted by a representative of the company or an agent acting on behalf of the company. The claim notification form requires basic company information and project information.

The form doesn’t require any costing details or any specifics about the R&D done in the period, so it’s relatively easy to complete. However, the deadline to submit a form is much earlier than the deadline for the actual claim; you only have until 6 months after the end of the period of account.

While there is no penalty for submitting a claim notification form if you don’t need one, forgetting to submit a form when you do need one risks making your R&D tax credit claim invalid.

Below, we’ve asked easy questions which should clear up whether you should be submitting a form (although it doesn’t hurt to submit one if you’re not sure!).

Which accounting period are you claiming for?

The claim notification requirement only applies to accounting periods beginning on or after 1 April 2023.

Any claims for accounting periods before this can be submitted without a claim notification form.

Has your company claimed for R&D activity before?

Companies claiming for the first time for periods beginning on or after 1 April 2023 must submit a claim notification form.

Was your last R&D claim in any of the previous three years?

Claimants who have claimed for R&D tax credits before will need to submit a claim notification form if the last claim was made more than 3 years before the last date of the claim notification period.

For example, a company with a period of account running from 1 January 2024 to 31 December 2024 would have a notification window of 1 January 2024 to 30 June 2025. The company must have made a claim between 1 July 2022 and 30 June 2025 (i.e., three years before the end of the window).

Those who have made more recent claims need not submit the claim notification form.

HMRC recently released extra guidance on this point, so make sure you read on if you think this applies to you.

The details required at this early stage are mostly to identify who is making the claim; you’ll only need to provide high level details about your actual R&D done.

• Unique Taxpayer Reference (UTR)
• Contact details of the main senior internal R&D contact responsible for the claim
• Contact details of any agent involved in the R&D claim (e.g., R&D tax consultant who helped prepare or advise on the claim or accountant who helped make the claim)
• Accounting period start and end date for which you’re claiming R&D tax relief/expenditure credit
• Period of account start and end date
• High-level summary of the planned R&D activities

The claim notification window begins on the first day of the period account and runs until six months after the end of the period of account.

Essentially, for most companies with a 12-month accounting period, the claim notification period is 18 months from the first day of the accounting period.

For example, a company's accounting period and period of account run from 1 April 2025 to 31 March 2026. The claim notification window starts on the first day of the period; in this instance, 1 April 2025. The claim notification window ends six months after the end of the period of account, in this instance, 30 September 2026.

With these earlier deadlines, it pays to be prepared. While you can make your claim up to two years from the end of your accounting period, you must signal to HMRC that you plan to do so pretty quickly from the end of your period (or even earlier, if possible!).

If you miss your deadline, or if you forget to submit a claim notification form entirely, it is very unlikely that HMRC will accept your R&D tax credit claim.

Longer periods of account

A period of account can exceed 12 months; it is the period for which a company prepares its accounts and can be extended. In contrast, an accounting period must be equal to or less than 12 months. Your accounting period is covered by your Company Tax Return (CT600) but your period of account is covered by your accounts.

In the vast majority of cases, a company's accounting period is the same as its period of account.

Claims which cover a longer period of account (e.g., 1 January 2024 to 31 March 2025) cover two different account periods (1 January 2024 to 31 December 2024 and 1 January 2025 to 31 March 2025).

In this instance, the window to submit the claim notification form is between 1 January 2024 and 30 September 2025, i.e., 6 months after the end of the period of account.

Recently, HMRC contacted professionals in the R&D tax space to clarify the guidance around the three-year exemption (i.e., if a company has made a claim in the last three years, it is exempt from the claim notification requirement).

The additional rule is that any claim that:

• Was for an accounting period beginning before 1 April 2023, AND
• Was submitted through an amended tax return on or after 1 April 2023

Is not eligible for the three-year exemption.

For example:

Company A has a period of account of 1 January 2024 to 31 December 2024. It did not submit a claim notification form for this period, as it had previously submitted a claim for the 2022 period through an amended tax return in December 2023.

However, since the 2022 period began before April 2023 and the claim was submitted through an amendment after April 2023, this claim cannot be included in the three-year exemption.

Of course, there’s no harm in submitting a form in any event, nor is there any harm in submitting a form but later deciding not to make your claim. However, if you want more certainty, get in touch with our experts at Tax Cloud.

When you choose to make a claim with Tax Cloud, this is the first thing we check. We take the guesswork out of making your claim, evaluating all your project information and submitting it to HMRC on your behalf, so you can focus on your innovation and leave the complex tax law to us.