In spring 2025 HMRC consulted on overhauling advance assurance for R&D tax relief, asking whether businesses should be able to get certainty on their claims before submitting them. The consultation closed on 26 May 2025. The outcome is now known: mandatory clearances were rejected, and a voluntary targeted advance assurance pilot was announced at the Autumn Budget 2025 and launched in spring 2026.
This article records what was proposed and, updated in July 2026, how it turned out.
What was HMRC consulting on?
The consultation sought views on the future of advance assurance: the process by which an eligible company can ask HMRC to confirm, before a claim is filed, that its R&D qualifies. The stated aims were to reduce error and fraud, give businesses greater certainty, and improve the experience of claiming. At the time, advance assurance was limited to certain first-time SME claimants and take-up was low.
A well-designed assurance route has an obvious appeal in the current environment, where HMRC checks roughly one in six claims. Certainty up front reduces the risk of a post-submission enquiry and the cash-flow damage of a clawback.
What was the most contested proposal?
The possible reintroduction of a minimum expenditure threshold for R&D claims. The concern was its effect on start-ups and early-stage companies, which often run lean and may not meet a spending floor despite doing genuine qualifying R&D.
Matthew Jones commented during the consultation: “The current advance assurance scheme has proved not fit for purpose. The idea of improvement is a welcome one. However, the proposed reintroduction of a minimum expenditure threshold raises some concerns. Such a threshold could inadvertently penalise start-ups and early-stage businesses, especially those with founders or directors not drawing a salary, who would otherwise be eligible under the ERIS scheme. Once again, it feels like genuine businesses could get caught in the crossfire.”
The threshold worry was sharpest for exactly the companies Enhanced R&D Intensive Support exists to help: pre-revenue, loss-making and R&D-intensive, a profile we see most often in biotech.
What did the consultation lead to?
At the Autumn Budget 2025 (26 November 2025), the government announced a voluntary targeted advance assurance pilot for SMEs and rejected the idea of mandatory clearances. The pilot launched in spring 2026: eligible SMEs can ask HMRC for its view on up to two specific high-risk areas of a claim before filing. We have written a full guide to how the targeted advance assurance pilot works, including who can apply and what HMRC asks for.
Separately, HMRC launched a non-binding online tool in September 2025 that lets companies check whether their work is likely to qualify. It is a useful first filter, not a clearance.
Does advance assurance replace careful claim preparation?
No. Assurance, targeted or full, is only as good as the information behind it, and most claims will still be filed without any assurance at all. The foundation remains the same: a project that genuinely meets the definition of qualifying R&D, documented well enough to withstand scrutiny.
If you are weighing up whether the pilot is worth using for your next claim, talk it through with a chartered adviser.
Written by Matthew Jones ACA CTA. Last reviewed July 2026.
Sources
- Advance clearances: summary of responses — the consultation outcome and the decision to pilot advance assurance.
- Apply for targeted advance assurance — the resulting targeted advance assurance pilot.
- Check if a project qualifies as R&D (checker) — HMRC’s non-binding online tool for testing whether work is likely to qualify.
This article describes the rules as they stood at the review date above. The rules change: for the current position, start with our guides or talk to us.
