Quick answer: HMRC disclosure is the information a claimant must submit to support an R&D tax relief claim. Since 8 August 2023 the minimum is the Additional Information Form naming the agent, senior competent professional, projects and qualifying expenditure; good practice also includes a written technical narrative cross-referenced to the cost schedule.
What is HMRC disclosure?
HMRC disclosure, in the R&D context, is the information that a claimant must provide to support a research and development tax relief claim. Since 8 August 2023 the minimum disclosure is the Additional Information Form, naming the agent, the senior competent professional, the projects and the qualifying expenditure. Good practice goes further, providing a written technical narrative describing the advance sought, the uncertainty addressed, and the work done, cross-referenced to the cost schedule.
How does HMRC define the disclosure requirement?
The disclosure framework is set out at CIRD81800 of the CIRD Manual, with the specific AIF content rules at CIRD81810. HMRC's Guidelines for Compliance GfC3, Help to see if your work qualifies as R&D for tax purposes, describes the content and standard HMRC expects. The Agent Standard applies to all agents providing disclosure on behalf of clients.
What does good HMRC disclosure look like in practice?
A biotechnology SME submitting its first R&D claim provides the AIF, a 10-page technical narrative covering two projects, a cost schedule cross-referenced to the AIF, and a short CV for the competent professional. HMRC accepts the disclosure and the claim proceeds without enquiry. A competing firm that submitted only the bare AIF receives an enquiry. The free eligibility calculator is a useful first step before assembling a full disclosure package.
Related terms
Frequently asked questions
Since 8 August 2023 the minimum disclosure is the Additional Information Form, naming the agent, the senior competent professional, the projects and the qualifying expenditure.
It is the statutory minimum, but good practice goes further by providing a written technical narrative describing the advance sought, the uncertainty addressed and the work done, cross-referenced to the cost schedule. Claims with only the bare AIF are more likely to receive an enquiry.
The claimant company is ultimately responsible, but agents preparing the claim on the company’s behalf must meet the HMRC Agent Standard, which applies to all agents providing disclosure for clients.