What evidence does HMRC want for an R&D claim?

HMRC wants a detailed technical narrative showing genuine scientific or technological uncertainty, project by project, plus traceable cost records linking staff time, subcontractor spend and consumables to the qualifying work. It carries far more weight when this evidence is contemporaneous, rather than written up only once a claim or enquiry begins.

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Do this first

Check whether the mandatory additional information form was submitted with the 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.

Key facts

Statutory basis
Part 13 Corporation Tax Act 2009 and the requirement to submit an additional information form supporting each R&D claim
Technical evidence
Project-level narratives describing the advance sought, the uncertainty, and why it could not be readily resolved
Cost evidence
Payroll records, timesheets or time allocation methodology, subcontractor and externally provided worker invoices, and consumables records
Mandatory form
An additional information form must be submitted before or with the claim for accounting periods starting on or after 1 August 2023
Retention
Keep records supporting a claim for at least the statutory record-keeping period, longer if an enquiry is open

The evidence HMRC expects to see

HMRC's starting point is the additional information form, now mandatory for claims covering accounting periods beginning on or after 1 August 2023, which requires a breakdown of qualifying costs and a description of the projects, including how many were included and the technical uncertainties addressed.

Beyond the form, HMRC wants detail showing genuine engineering, scientific or software development uncertainty — not simply that something was difficult, expensive, or new to the company. Evidence such as design iterations, failed attempts, technical specifications, and internal discussions about how to solve a problem carries real weight.

On the cost side, HMRC checks that staff time claimed as qualifying is properly apportioned using a reasonable methodology, that subcontractor and externally provided worker costs meet the connected or unconnected party rules, and that consumables genuinely relate to the R&D activity.

Why contemporaneous evidence matters most

Under the general principles applied by HMRC and tribunals in R&D cases, evidence created at the time the work was carried out is far more persuasive than a narrative reconstructed after the event purely to support a claim. Contemporaneous records demonstrate that the uncertainty genuinely existed and was worked through, rather than being described with hindsight.

This is reinforced by how HMRC assesses claims under Part 13 Corporation Tax Act 2009 (opens in a new tab): the legal test focuses on what a competent professional could not have readily deduced at the time, so evidence must speak to that point in time.

Where a company cannot produce contemporaneous technical records, it can still build a case using witness evidence from the staff involved, but this is generally weaker and more open to challenge than documents created as the work happened.

What this means for a limited company director

Put a simple system in place going forward: even brief notes made at the time a technical challenge is identified and worked through are far more valuable later than a detailed narrative written months afterwards.

Keep timesheets or a defensible time-apportionment method for staff working partly on qualifying projects, since HMRC frequently challenges cost apportionment even where the technical case is accepted.

If you are already under enquiry and contemporaneous records are thin, focus on the strongest and most defensible projects rather than trying to justify every line of a broad claim equally.

What this costs you

Building an evidence base from scratch during an enquiry, rather than having kept it as you went, takes considerably more adviser and staff time, and the outcome is less certain.

Growth plan clients have free tax investigation insurance included, covering our fees for helping assemble and present evidence during an R&D compliance check — see /fees.

Investing modest time in record-keeping at the point work is done is far cheaper than reconstructing a defence years later.

Common mistakes to avoid

Do not rely on a single company-wide narrative for multiple distinct projects; HMRC expects project-level detail.

Do not submit a claim without the mandatory additional information form where required — claims without it can be removed from the return entirely.

Do not assume enthusiastic marketing language about innovation is the same as evidence of qualifying technical uncertainty; HMRC looks past sales copy to the underlying facts.

Building an evidence file going forward

Set up a simple running log per project capturing the technical challenge, the approaches tried, and the outcome, updated as the work happens rather than at year end.

Record staff time against projects using a consistent, explainable method, even if it is not minute-by-minute timesheeting.

Review your evidence file before each claim is submitted, not just before an enquiry starts, so gaps are caught early.

What to do next

  1. Check whether the mandatory additional information form was submitted with the claim.
  2. Gather project-level technical narratives and any contemporaneous notes.
  3. Reconcile staff time, subcontractor and consumables costs to source records.
  4. Identify and shore up the weakest parts of the evidence file first.
  5. Set up an ongoing record-keeping process for future claims.

Where we can help

Sources

About the author

Waqas Sagar ACA FCCA FMAAT, Managing Director. 18+ years advising UK directors on HMRC enquiries, supported by a team with over 100 years' combined experience.

Reviewed: 16 September 2026 · Next review: 16 March 2027

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