The real reason HMRC opens an R&D enquiry
Would your R&D narrative stand up to detailed technical scrutiny from HMRC?
Most R&D compliance checks don’t start because the claim value is high.
They start because the technical logic doesn’t stack up.
HMRC’s approach to R&D compliance has changed significantly over the last few years.
The emphasis is no longer just on “what was claimed”, but on whether the company can clearly demonstrate why the work meets the definition of R&D for tax purposes.
Explanations that do not establish R&D
- “We developed an innovative solution”
- “There were technical challenges”
- “We improved an existing process”
These statements say nothing about why the work couldn’t be done using existing knowledge.
The reasoning HMRC expects
- What scientific or technological advance was being sought?
- What baseline of existing knowledge or capability was available at the outset?
- Why was the solution not readily deducible by a competent professional?
- What technical approaches were tried, tested, or rejected, and why?
- What was learned through the process?
If those questions aren’t answered in plain, technical terms, the claim can appear speculative, even where the underlying work was genuine.
Governance and reasonable care
- Was the claim prepared with input from competent professionals?
- Is there evidence the company understood the rules?
- Do the costs clearly map to the qualifying activities described?
Where the narrative feels templated, oversimplified, or disconnected from how the business actually operates, enquiry risk rises sharply.
A robust R&D claim is no longer about persuasive language, it’s about technical clarity, logic, and evidence.
