R&D Advance Assurance Consultation Findings
The government published its response to the consultation on R&D tax relief advance clearances on 26 November 2025, Budget Day, signalling that reform of the current Advance Assurance system is now a policy priority. The consultation, launched in March 2025 sought views on how a clearance model could reduce error and fraud while giving businesses earlier certainty over their claims. Ministers confirmed their commitment to maintaining the existing rates under both the merged R&D Expenditure Credit scheme and the Enhanced R&D Intensive Support for SMEs, meaning companies will continue to receive between £15 and £17 for every £100 of qualifying R&D spend. At the same time, the government acknowledged that non‑compliance has reached unacceptable levels and that changes are needed to protect the integrity of the regime.
Feedback showed that the current Advance Assurance Scheme has experienced low and declining uptake. Respondents attributed this to restrictive eligibility limited to SMEs, poor awareness among claimants and agents, and administrative burdens such as long processing times and inconsistent feedback. Many businesses felt the scheme did not deliver the flexibility or clarity originally intended and in some cases was viewed as an invitation to scrutiny rather than a source of reassurance. Nevertheless, there was broad agreement that some form of early assurance remains valuable if it can be redesigned to reduce compliance burdens, improve decision‑making and provide clearer guidance and communication.
A central theme of the consultation was whether any future model should be voluntary or mandatory. Most respondents favoured a voluntary approach, arguing that it would allow companies to seek certainty when needed without imposing additional requirements on confident claimants. This was seen as particularly important for SMEs that often lack the resources to manage complex processes. Support for a mandatory system was more cautious and generally limited to a targeted, risk‑based model focused on first‑time claimants or sectors with high levels of non‑compliance. Concerns were raised that a compulsory process could increase costs, create administrative complexity and deter legitimate claims unless transparent safeguards were in place.
The idea of introducing a minimum expenditure threshold divided opinion. Some believed a threshold between £10,000 and £25,000 could help HMRC focus resources on higher‑value claims and deter fraud, particularly as data show higher non‑compliance below £50,000 of expenditure. Others warned that impactful innovation is not always linked to high spending and that a threshold could exclude genuine smaller businesses, discourage legitimate claims or even encourage artificial inflation of costs.
Improving HMRC capability was another recurring message. Respondents felt caseworkers often lacked sector expertise and called for better training, specialist knowledge and more consistent decision‑making. The role of agents was emphasised as critical, with strong support for allowing agent‑led submissions, clearer authority within any new system and stronger regulation of advisers. Suggestions included accreditation for agents, publication of approved or non‑compliant lists, online portals and structured feedback forums.
As a next step, HMRC will launch a limited pilot of a new targeted Advance Assurance Service while the existing scheme continues to operate. Further details are expected in due course, but the direction of travel is clear: a more flexible and accessible clearance process aimed at restoring confidence, supporting genuine innovation and ensuring that R&D tax relief delivers value for businesses and the wider economy.
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