HMRC’s Advance Assurance for R&D Claims: What’s Changing in 2026?

Advance Assurance is available for companies making their first Research and Development (R&D) tax relief claim. This provides written confirmation from HMRC that planned R&D activities qualify, giving businesses confidence that their claims will not be subject to enquiry for their first three accounting periods, provided the claims are consistent with what HMRC agreed.

 

Who can currently apply for advance assurance?

Under the existing rules, Advance Assurance is restricted to smaller, first-time claimants.

A company may apply if:

• It has never claimed R&D tax relief before (including any companies within the same group).
• It has an annual turnover of £2 million or less.
• It has fewer than 50 employees

For eligible companies, Advance Assurance can offer greater certainty and smoother claims during the early years of its R&D activity. So given this obvious benefit, why is it that the number of applications have been relatively low?

 

Feedback From the Government Consultation

The government sought views from stakeholders on the current Advance Assurance process, its usefulness, clarity, and any areas for improvement. The responses highlighted several recurring concerns:

• Low uptake: Use of the system has been limited, likely because eligibility is restricted to SMEs that are only making their first claim.
• Operational issues: Businesses and advisers reported long processing times, inconsistent feedback, and unclear guidance from HMRC officers.
• Lack of trust: Some agents expressed scepticism about the system, fearing it may be used as a tool to challenge or reject claims rather than support them.

This feedback has prompted HMRC to rethink its approach.

 

A New Targeted Assurance Pilot Launching in Spring 2026

HMRC has announced that it will introduce a limited pilot of a new targeted advance assurance service in Spring 2026. Unlike the current scheme, the pilot will:

• Be open to any SME preparing to make an R&D claim.
• Not be restricted to first-time claimants.
• Focus on providing certainty on specific, high-risk or complex aspects of R&D claims.

This represents a significant expansion that could make Advance Assurance far more accessible and valuable for a wider range of clients.

 

What Will the New Pilot Cover?

Participants in the 2026 pilot will be able to seek targeted assurance on one of four key issues:

1. Whether a project meets the definition of R&D for tax purposes
   The most relevant area for many claimants and advisers.
2. Qualification of overseas expenditure
   Clarifying whether certain foreign costs can be included in the claim.
3. Which party can claim for contracted-out R&D activity
   Helping businesses involved in subcontracted arrangements avoid claim conflicts.
4. Whether the company qualifies for exemption from the PAYE/NICs cap
   Offering early certainty around this common compliance hurdle.

 

What This Means for Businesses and Advisers

The 2026 targeted assurance pilot is expected to provide more practical, focused guidance than the current system. For existing clients, especially those engaging in new, evolving, or uncertain R&D activities, this may be an opportunity to secure early HMRC agreement on the riskiest parts of their claims.

Businesses should keep this development on their radar as Spring 2026 approaches, as participation could reduce the likelihood of future enquiries and provide greater confidence when planning for any R&D activities.

 

Next Steps

If you’d like support assessing whether your projects could benefit from the upcoming scheme or want guidance on preparing robust R&D claims then please get in touch with our team. We can help you navigate the changes and identify opportunities.