Companies Are Still Unaware They Are Missing the Deadline

In the past few weeks, we have unfortunately had to inform some companies that they are not eligible to file an R&D Tax Credit claim for their accounting period ending 30th April 2025. This was because they were considered first-time filers and did not file the required Notification with HMRC within 6 months of the end of their accounting period or in this case 31st October 2025.

As a reminder, both first-time filers of an R&D Tax Credit claim and companies that have not filed an R&D Tax Credit claim in the past 3 years (that is 3 years prior to the last day of the notification period) must file a Notification with HMRC within 6 months of the end of the accounting period to which the R&D Tax Credit claim relates. 

One company, as an example, thought they had 2 years in which to file an R&D Tax Credit claim. While this is true, you must still file a Notification if you are a first-time filer within 6 months of the end of the accounting period. The Notification informs HMRC that the company intends to make an R&D claim. Ensuring the claim will be accepted later when the full R&D submission is filed. If the notification isn’t submitted on time, the company loses the right to claim R&D relief for that period, even if it later files a complete claim.

Following is an example that HMRC provides:

A company’s:

• period of account — covers 1 May 2024 to 30 April 2025
• accounting period — also covers 1 May 2024 to 30 April 2025

This means the companies:

• first date of the claim notification period is 1 May 2024
• last date of the claim notification period is 31 October 2025 (this is 6 months after the end of the ‘period of account’)

If the company is claiming R&D tax relief for the first time, they must submit the claim notification form between 1 May 2024 and 31 October 2025.

If the company has claimed R&D tax relief previously and their last claim was before 31 October 2022 (this is more than 3 years before 31 October 2025) they must either:

• submit the claim notification form between 1 May 2024 and 31 October 2025
• send the claim on their Company Tax Return or as an amendment to the return so it’s received by October 2025

In another example, the company had filed an R&D tax credit claim within the past 3-years dating back from the end of the notification period. The company therefore felt they were exempt. Unfortunately, in this case, the only R&D Tax Credit claim that was filed within the past 3-years was for an accounting period commencing before 1st April 2023 and was filed after 1st April 2023 by way of an amendment to the original corporate tax return filing. In this specific case, the tax law states that this particular filing is ignored as an R&D Tax Credit claim and not filed within the 3-year notification period.

Companies continue to be caught up by the notification requirements. Accounting firms should therefore review all clients making an R&D Tax Credit claim well within 6 months of the end of the accounting period to determine if they need to file a notification.

The R&D rules and filing requirements have had multiple changes over the last 2 years, and can be tricky to keep up with. So if you have any questions, please do not hesitate to contact Jenni at [email protected].