HMRC R&D Pre-Notification Process – Is it blocking legitimate claims? 

In April 2023, HMRC introduced a pre-notification process for R&D tax relief claims. This new requirement means that if a company has not made an R&D claim in any of the previous three years, they must notify HMRC in advance if they intend to submit a claim.  

There is a limited window to do this for accounting periods starting after 1st April 2023. The window in which a pre-notification can be completed as the following example:  

• Accounting Period: 1 April 2023 – 31 March 2024  

• Pre-Notification Period: 1 April 2023 – 30 September 2024 (six months after period end)   

This means that as of now, any company with an accounting period ending in March 2024 that did not submit a pre-notification can no longer claim R&D tax relief for that year.  

I’ve spoken to several businesses recently that have been caught out by this rule, and the consequences are frustrating.  

Example 1

A company has carried out significant R&D over the past two years but never claimed before.  

• March 2023 claim? No problem, we can help.  

• March 2024 claim? Unfortunately, they missed the pre-notification deadline—so they cannot claim at all, despite conducting genuine R&D.   

Example 2

A business received substantial R&D grant funding from NIHR, Innovate UK (IUK), and SBRI since 2022 but had never claimed R&D tax relief.  

• They decided to claim for 2023—which is fine.  

• But when they tried to claim for 2024, they found out they had missed the pre-notification deadline. That’s now lost funding they could have reinvested into further innovation.

Is the pre-notification step blocking legitimate R&D?

The Pre-Notification requirement appears to be an unnecessary barrier that restricts access to legitimate R&D tax relief. The R&D schemes are supposed to support innovation, yet businesses are being penalised not because their work isn’t R&D, but simply because they didn’t complete an administrative step in time.  

Companies that genuinely deserve tax relief are losing out, not because of fraud, not because they don’t meet the criteria, but because of an admin exercise!   

If you’re even considering an R&D tax relief claim, we urge you to submit the pre-notification. It takes just 30 minutes to complete and could save you thousands in lost claims.  

If you need guidance or have any questions about the pre-notification process, feel free to get in touch with the TBAT team or book an appointment with me today! 

Check out these questions from our Knowledge Centre:

What is the claim notification period for pre-notification?

What is the HMRC R&D pre-notification?