HMRC hasn’t changed the definition of R&D, but it has changed how it reviews claims

Over the last few years, HMRC’s approach to R&D tax relief has become far more structured and risk-driven.

Compliance activity is no longer random or reactive; it is increasingly targeted, data-led, and narrative-focused.

Key trends we’re seeing include:

Greater scrutiny of technical explanations

Claims are being reviewed for technical logic, not just eligibility keywords. HMRC wants to understand why the work wasn’t readily deducible, not just what was done.

For broader context on the incentive itself, read our guide to R&D tax relief.

Increased emphasis on governance and reasonable care

Who prepared the claim?

Was a competent professional involved?

Does the company demonstrate an understanding of the rules, or does the submission look templated?

Early-stage risk filtering

With Claim Notification Forms and Additional Information Forms now embedded in the process, HMRC is assessing claims much earlier, often before a full technical review takes place.

Closer alignment between narrative and costs

Costs are expected to map cleanly to the qualifying activities described. Where there’s a disconnect, enquiries are more likely.

Less tolerance for borderline or commercial “innovation” claims

HMRC is drawing a firmer line between commercial improvement and qualifying scientific or technological advancement.

None of this means legitimate claims are unwelcome.

It means well-prepared claims are rewarded, and poorly articulated ones are filtered out more quickly.

Questions to ask before your next claim

If HMRC reviewed your last R&D claim tomorrow:

• Would a technical reviewer clearly understand why the work involved uncertainty?
• Could your team explain the challenges without relying on marketing language?
• Do your costs tell the same story as your narrative?
• Does your claim reflect how the work actually happened in practice?

R&D relief is still a valuable incentive, but it now sits firmly in a compliance-led environment. The businesses that adapt to that reality are the ones best placed to continue claiming with confidence.