Your company remains responsible for the claim even if the adviser who prepared it has stopped trading or gone quiet. HMRC will still deal directly with the company. Find the original claim file, appoint a new agent under Schedule 18 Finance Act 1998, and respond to any open enquiry promptly.
Gather every document you hold relating to the R&D claim.
If the reply date on your letter is within 14 days, call 020 3441 1258 rather than waiting, or check the reply to an enquiry you have already sent.
It is a difficult but common situation. A number of R&D boutique firms have closed or become uncontactable following HMRC's tighter scrutiny of the sector.
The company that made the claim carries the legal responsibility for it, so an adviser vanishing does not pause an enquiry or extend a deadline.
Your priority is to recover whatever paperwork exists and get a new, competent adviser in place quickly.
R&D relief is claimed under Part 13 Corporation Tax Act 2009 (opens in a new tab) through the company tax return. The return, and everything in it, is the company's legal responsibility under general Corporation Tax Self Assessment rules.
Where HMRC opens a compliance check, it does so under the enquiry powers in Schedule 18 Finance Act 1998. Those powers and deadlines attach to the company, not to whoever drafted the claim.
If HMRC has issued a Schedule 36 Finance Act 2008 information notice, the request stands regardless of who prepared the original documents; someone at the company must respond within the stated period, usually usually at least 30 days to produce the documents listed.
There is no statutory mechanism that pauses an enquiry because an agent has become unreachable, so acting fast matters.
First, check what records you actually hold: the submitted CT600, R&D technical report, cost workings, and any correspondence with the old adviser or HMRC.
If the adviser held key evidence on their own systems and cannot be reached, you may need to reconstruct the technical justification for the claim from project records, emails, and staff time data held internally.
Notify HMRC of your change of agent as soon as a new one is appointed, and ask for confirmation of any outstanding deadlines in writing so nothing is missed during the handover.
Reconstructing a claim file from scratch takes time and specialist input, and costs more than a well-documented handover would have. Expect additional fees for that reconstruction work.
If the original claim turns out to be weak or unsupportable, you may face the outcomes described for a clawback, including repayment, interest, and penalties.
Growth plan clients have free tax investigation insurance included, covering professional fees for defending an HMRC enquiry — see /fees to check what is included before you need it.
Do not wait for the old adviser to resurface before acting; HMRC's clock keeps running.
Do not assume no news from HMRC means the enquiry has closed; ask for written confirmation.
Do not appoint a replacement adviser without checking their track record and how they will evidence the claim, particularly after issues with unregulated R&D boutiques.
*Included on the Growth plan — see our fees.
My R&D adviser has disappeared, what do I do? is handled by the same team at Accotax London Limited, 12 London Road, Morden, London SM4 5BQ. We deal with HMRC compliance checks for limited company directors across Morden, Wimbledon, Mitcham, Sutton, Croydon, Kingston and central London, and by video call for companies anywhere in the UK.
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