RDP attended the HMRC R&D Tax Credit stakeholder group session 10th March 2026

While there were many important takeaways. The primary one of most importance in RDP’s opinion is that HMRC is concerned that an individual or the average R&D Tax Credit claim is increasing in amount. Therefore as a result, HMRC is shifting its risk assessment to these specific R&D Tax Credit claims.

Stats on R&D Tax Credit Claim Trends & Processing Times

• Total R&D Tax Credit claim submissions continue to fall significantly, year over. For example, R&D tax claim submissions totaled approximately 61K in 2023/2024 down to approximately 51K in 2024/2025. However, the average size of claim submissions is rising.
• Total R&D expenditures issued by HMRC, even with approximately less than 10K overall submissions, surprisingly increased from £7.7B to £8.2B. Reflecting the shift toward larger, more complex claims.
• HMRC performance on processing times has been good as approximately 90% of all R&D Tax Credit claims were processed within the 40-day window in 2024/2025. From the meeting, they have advised they are on track to repeat this year. The primary peak periods for R&D Tax Credit claim submissions continue to be in March and December. Which is also a key focus area of HMRC when questioning claim submissions.

R&D Mailbox & Customer Service Improvements

• Significant changes are underway to triage, track, and respond faster to mailbox queries and the expected improvements to the public are likely to be seen sometime in April 2026. The mailbox at present is designed (included but not limited to) to ask general questions pertaining to the status of R&D claims. In addition to discussing eligibility requirements or examples of R&D projects and costs mentioned in the BEIS Guidelines.
• HMRC Clarification: many “no reply” cases were actually actioned via standard assessment/repayment correspondence. HMRC intends to tighten up this communication.
• HMRC is also conducting changes to introduce more direct communication from case-worker teams before formal inquiries begin.

Compliance & Risk Approach

• Shift in focus as HMRC is moving away from the broad campaigns team to more targeted, risk-based work by WMBC (Wealthy and Medium Business Compliance by the Incentives and Relief’s team)
• The HMRC Campaigns team will no longer be opening new query cases. However, will be assisting with the existing ones continuing to close with support.
• ADR (Alternative Dispute Resolution) applications are down roughly 33% and processing times are expected to be normalised to approximately 4 weeks.

Other comments made regarding Compliance Checks

• If HMRC has a compliance check letter asking for information that is not relevant or was supplied in the AIF. Then the company/R&D tax relief provider can raise this with the HMRC caseworker
• HMRC currently has no plans to hire technical specialists to review R&D project eligibility
• If a taxpayer or claimant is claiming an exemption for contractor fees outside the UK, they are required only to provide an explanation as to why, as support for their position.

AI in R&D Administration

• HMRC caseworkers now have access to Copilot, governed by the UK Government’s Generative AI Playbook (emphasis on human oversight, no reliance on final decisions).
• The AI is being used as an R&D summariser tool to help caseworkers quickly review reports/AIFs.
• External AI tools for R&D Tax Credit claim preparation are expected to follow HMRC’s published guidelines for transparency, reliable data, human control, and ethics (key reasonings).

Mandatory Tax Adviser Registration

• New requirement starts 18th May 2026 for businesses providing tax services and interacting with HMRC on behalf of clients.
• Free, online via Agent Services Account; existing agents with SA/CT accounts can join from 18 August 2026.

Policy Outlook (HM Treasury / HMRC)

• HMRC continues to communicate to have a strong commitment to stability in R&D tax reliefs as no further major changes are expected after recent reforms.
• HMRC’s focus is about improving Administration for genuine claimants while tackling error and / or fraud. 

Advance Assurance

Piloting new advance assurance that will comment on:

1. If the project qualifies
2. Claiming the exemption to overseas spend for contractor/EPW
3. Exemption regarding cap on PAYE
4. Who claims the R&D Tax Credit; company paying for the work or companies engaged to do the work

Additional Information Form

• HMRC continues to see a high number of errors in the Form, they are reaching out to companies/R&D Tax Credit service providers when this happens.

Based on all the above stated points, RDP is stressing it is even more important to have the right information conveyed to HMRC. Having an R&D Tax Credit service provider like RDP who can communicate with HMRC case workers employing AI is no longer a luxury, it has and will become a necessity with the R&D Tax Relief programme.

If you want to learn more about the issues raised in the recent HMRC stakeholder meeting, please contact Jenni at [email protected].