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How HMRC reviews your R&D claim before you even hear from them

If HMRC pre-screened your claim today, would it pass early risk checks with confidence?

By the time you receive an enquiry letter, your claim has usually already been through risk assessment.

HMRC has been clear that its approach to R&D tax relief is risk-based: it assesses risk to decide where to focus compliance activity and when to ask for more information.

That matters because a lot of “review” happens before you see a formal enquiry letter.

What “pre-screening” looks like in practice

It’s not one single test. It’s a set of indicators that can increase perceived risk and drive HMRC to:

  • issue “nudge” style communications (one-to-many letters),
  • request further information, or
  • open a formal compliance check.

Why the Additional Information Form (AIF) matters

For many claims, HMRC requires an Additional Information Form to be submitted before the claim is made on the return. The AIF is designed to standardise what HMRC receives and improve upfront checking/compliance.

In other words: HMRC is often forming an early view of risk based on the structured data you submit, before a caseworker ever writes to you.

Risk indicators HMRC may weigh up

HMRC does not publish a definitive “scoring model”, but based on its risk-based compliance approach and how claims are commonly filtered/queried in practice, factors that can increase attention include:

  • Claim profile vs company profile (e.g., claim size relative to turnover and staffing footprint)
  • First-time or irregular claiming behaviour (especially after gaps)
  • High levels of subcontractor and/or connected party costs, because these areas are rule-heavy and frequently misunderstood
  • Sector patterns and thematic risks that HMRC targets through wider compliance activity
  • AIF quality: clarity of projects, coherence of costs, and whether the narrative demonstrates genuine technological uncertainty
  • Consistency with public/statutory data (for example, whether the company’s described activity aligns with its filings and outward profile)

This doesn’t mean a claim is wrong.
But it does mean weak technical narratives, disproportionate costs, or inconsistencies can increase perceived risk long before you receive any formal communication.

A robust claim is built on the assumption that this pre-screening exists.

Pause for thought

If your claim were assessed purely on early risk indicators, before anyone spoke to you:

  • Would the technical story read as specific and credible (not templated)?
  • Do the cost categories “fit” the narrative (and reconcile cleanly)?
  • Would an independent reviewer see consistency across your AIF, accounts/tax return, and company profile?

In today’s environment, robustness starts before submission.