HM Revenue & Customs (HMRC) recently corrected its guidance surrounding the Advance Notification Form (ANF).

This correction could mean that some clients who missed the pre-notification deadline may still be eligible to claim, but they’ll need to act quickly.

What is the ANF?

The ANF is a mandatory requirement for certain companies that wish to claim R&D tax relief.

It must be submitted within six months of the end of the accounting period in which the qualifying R&D took place. That means if your client has a financial year-end in December 2024 for example, the ANF deadline is 31 June 2025.

The ANF was introduced in April 2023 as part of HMRC’s wider clampdown on poor-quality and ineligible claims and applies to all R&D schemes, including the enhanced R&D intensive support (ERIS), old SME scheme, RDEC and merged RDEC schemes.

This pre-notification process allows HMRC to assess and identify potential claims early, ensuring that companies are aware of their obligations and the reliefs available before submitting their Corporation Tax return.

Companies must submit an ANF if they:

• Are making their first R&D claim; or
• Have not claimed for any of the previous three accounting periods.

If you're unsure if or when your client needs to submit their pre-notification, we recommend seeking advice from an R&D tax specialist.

What went wrong with HMRC’s guidance?

Between 8 September and 17 October 2024, HMRC’s Corporate Intangibles and R&D Manual (specifically, section CIRD183000) mistakenly suggested that companies submitting an amended return for an earlier period (beginning before 1 April 2023) after the rule change came into force would be exempt from filing an ANF.

This was incorrect, as amended claims for older periods do not count toward exemption from the ANF.

The consequences of this error are that some companies were led to believe that they didn’t need to file the ANF because they had submitted an amended R&D claim after April 2023 for an earlier period, when in fact, they still needed to notify HMRC.

What is HMRC doing to correct this error?

In light of the confusion, HMRC will accept R&D tax relief claims for an accounting period even without a Claim Notification Form, provided both of the following conditions are met:

• The company submitted a valid R&D claim by amending a return for an accounting period that began before 1 April 2023. This amended return must have been filed with HMRC between 1 April 2023 and 30 November 2024; and
• The accounting period in question (where an ANF should have been submitted but was not) had a claim notification deadline falling between 8 September 2024 and 30 November 2024.

The company or its agent must email randd.policy@hmrc.gov.uk with:

• Proof of authorisation to act
• Company name and Unique Taxpayer Reference (UTR)
• Date the amended claim was filed
• The accounting period that was not notified
• The period of account it falls under

Emails must include ‘CIRD183000 notification’ in the subject line and follow HMRC’s email communication guidance.

HMRC will review the information, and if they determine that the conditions have been met, they will invite companies to submit a claim for the relevant period.

What should accountants do next?

To ensure your clients receive the R&D tax relief they are eligible for, we advise you to take the following steps:

1. Check your client list to identify any who filed amended R&D claims post-1 April 2023 for pre-April 2023 periods, and who did not submit an ANF for a new claim.
2. Verify your client's deadlines to check if their ANF window was due between 8 September and 30 November 2024.
3. Contact HMRC if you believe your client is eligible for this grace period, prepare the required details and email the R&D Policy team before the claim is filed.
4. To avoid administrative rejection, review your processes to ensure future ANFs are completed with the correct details and accounting period dates.
5. Educate your clients about the R&D tax relief process, as many still don’t realise that the ANF is now a fundamental part of the R&D regime.

By taking these steps now, you’ll not only protect your clients’ current claims but also strengthen your firm’s approach to R&D tax compliance going forward.

Get specialist R&D tax support from randd uk

If you’re unsure whether a client qualifies under this exception, it’s best to seek clarity sooner rather than later. The pre-notification rules are now firmly embedded in the R&D relief process, and future oversights are unlikely to receive the same flexibility.

At randd uk, our R&D tax specialists work closely with accountants to support their clients at every stage of the claims process, from eligibility checks to submission and enquiry support.