Anyone can sell R&D tax advice. The market is not a regulated profession: no qualification, registration with a professional body or track record is required to set up as an “R&D specialist”, and the mis-selling era that followed is why HMRC checked around one in six claims in 2023-24 and why the compliance regime tightened the way it did. Choosing an adviser is therefore less about comparing marketing claims, which anyone can make, and more about checking the things that can be verified — because when a claim goes wrong, the consequences land on your company, not on the agent who prepared it.
This page sets out what we would check before appointing any R&D adviser, including us.
Why the choice carries real weight
Three facts frame it. Your directors are legally responsible for the accuracy of the company tax return, whoever prepared the claim inside it. Every agent involved in an R&D claim must now be named to HMRC on the Additional Information Form, so the adviser’s standards are attached to your company’s file. And HMRC checked around one in six claims in 2023-24, its latest published figure, with enquiries arriving months or years after payment. An adviser is not a supplier you can quietly swap if the work is poor; their judgement becomes part of your compliance history.
Check what can be verified, not what is claimed
Marketing copy is unverifiable by design. These things are not:
- Professional body membership. ICAEW maintains a public register of chartered accountants, and CIOT a public directory of Chartered Tax Advisers, so a claimed qualification can be checked in minutes against the named person, not the firm’s logo strip. If a firm’s website shows no named, qualified individual anywhere, that is itself the answer — HMRC’s own guidance on choosing a tax agent is blunt that anyone can call themselves one, with no qualifications required, and that HMRC does not regulate them.
- Professional conduct rules. Members of the main tax and accountancy bodies are bound by Professional Conduct in Relation to Taxation (PCRT), which requires advice to have a sustainable basis in law and prohibits letting a fee shape a filing position. An adviser outside those bodies is bound by none of it.
- Anti-money-laundering supervision. AML supervision is a legal requirement for tax advisers — the professional bodies note that if a firm never asks you for client due diligence at the outset, that silence is itself informative. Ask who supervises them; a regulated firm will answer in one sentence.
- HMRC registration, with a caveat. HMRC’s mandatory registration regime for tax advisers began rolling out in May 2026, with AML supervision a condition of registering. It becomes compulsory for the first group of advisers on 18 August 2026 and for the remaining groups by 1 April 2027, and it reaches any adviser who deals with HMRC on a client’s behalf. The caveat is that you cannot verify it: there is no public register of registered advisers to search, and the details HMRC publishes are of advisers it has penalised, banned or refused to deal with. Does my R&D adviser have to be registered with HMRC? covers the dates and the gaps. You can ask, and you can note how readily the question is answered, but the checks that produce evidence are the ones above.
- Age and ownership. A firm’s incorporation date and filing history are public at Companies House and take a minute to check. The mis-selling era minted R&D agents in volume from 2019 onwards, and HMRC’s compliance push has been closing them nearly as fast — so a firm that predates the boom and is still trading under the same ownership is showing you a track record no marketing copy can fake. Ours is 2017; check it while you are there.
- Professional indemnity insurance and a complaints route. A regulated firm carries PII and answers to its professional body if you complain. An unregulated one offers neither.
Questions to ask before you sign
- Who will actually prepare my claim, and what are their qualifications? Not the firm’s — the person’s. Ask who reviews it and who signs it off.
- Who will speak to our technical people? The claim stands on a competent professional’s account of the uncertainties. A claim written without anyone talking to your engineers or scientists is a claim written backwards.
- What happens in an enquiry? Ask whether enquiry defence is included, what it costs if not, and whether they defend claims they prepared. An adviser who charges extra to defend its own work is telling you how much confidence it has in that work.
- What does the fee incentivise? Contingent fees are common and legitimate, but they reward size; ask what happens when something you hoped qualified does not. The answer you want is that the adviser will take it out of the claim and explain why, whatever it does to their fee.
- Will you tell me if we do not qualify? The most useful thing an honest adviser does is say no early. Ask for an example of a claim they declined to make.
- Can I see the fee and scope in writing before work starts? If not, walk away.
Red flags, from the enquiry files
- Success-rate and outcome promises. “100% success rate” and its variants are unverifiable and structurally dishonest: HMRC pays most claims on a process-now, check-later basis, so a paid claim proves processing, not approval — and no adviser controls HMRC’s decisions.
- Speed promises. HMRC’s processing queue is not the adviser’s to promise. Preparation speed is theirs; payment timing is not.
- “Maximise your claim” as the core pitch. The right claim is the objective. A maximised claim and a defensible claim are different things, and only one of them survives a compliance check.
- Speculative approaches and “everyone qualifies”. HMRC has warned about unscrupulous agents approaching businesses in sectors where qualifying R&D is rare, offering to file speculative claims for high commission. If the pitch arrived before any question about what your company actually does, the analysis is not going to improve after you sign.
- “HMRC approved.” HMRC does not approve advisers or methodologies; the professional bodies’ own guidance calls such marketing spurious.
- Committee seats presented as credentials. Some firms cite membership of HMRC’s Research and Development Communication Forum — often under its old name, the Consultative Committee — as if it were a mark of official standing. It is a twice-yearly forum on how the relief is administered; organisations apply to the chair to join, subject to space and a waiting list. Participation is participation, not accreditation: HMRC states plainly that it does not endorse individual businesses or tax agents, and a forum seat tells you nothing about the quality of an adviser’s work in either direction. When you are choosing, set it aside entirely and weigh the things on this page that can be verified.
- No named professionals. A team page of job titles with no qualifications, or no team page at all.
- Pressure to sign before the technical conversation. The eligibility view should come first and should cost you nothing.
An honest note to end on
A specialist is not always the right answer. Some claims sit perfectly well with a company’s own accountant, and the honest comparison — including when we would not be the right choice — is on specialist or accountant: who should prepare the claim? Whoever you appoint, check them against the list above. We publish how we are regulated so you can run those checks on us, and if you want a second opinion on an existing arrangement, our free claim review is confidential and comes with no obligation.
Sources
- Finance Act 2026, section 223 — the prohibition on a tax adviser interacting with HMRC for a client while unregistered.
- The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026, SI 2026/807 — the appointed days: 18 August 2026 for the first tranche, phased to 1 April 2027.
- How to choose a tax agent — HMRC’s own checklist, including that anyone can call themselves a tax agent and HMRC does not regulate them.
- HMRC’s approach to R&D tax reliefs 2023 to 2024 — the unscrupulous-agent warnings and the compliance coverage behind the one-in-six figure.
- PCRT topical guidance on R&D tax credit services — the conduct rules that bind members of the professional bodies in R&D work.
- Submit detailed information before you claim — every agent involved in a claim must be named on the AIF.
- Choosing a specialist R&D tax adviser (CIOT/ATT) — the professional bodies’ consumer guide, including the warning on “HMRC approved” marketing.
- The Research and Development Communication Forum — what the forum is and how organisations join; HMRC’s Standard for Agents prohibits implying HMRC endorsement.