R&D Tax Claim Named Officer: What Company Directors Need to Know

The R&D tax named officer requirement sits within the Additional Information Form (AIF), which became mandatory for all R&D tax relief claims submitted on or after 8 August 2023. The AIF is submitted under the merged R&D scheme for accounting periods beginning on or after 1 April 2024. Every AIF must include the name, job title, and contact details of the senior company officer who is responsible for the claim. This is a deliberate shift from the previous approach, where the claim was prepared and submitted largely by the external adviser with limited formal accountability inside the company itself.

What the AIF Requires from the Named Officer

The gov.uk guidance requires the AIF to include "the contact details of the main senior internal R&D contact in the company who is responsible for the R&D claim, for example a company director."

The person named must have:

• Reviewed all project descriptions included in the AIF
• Approved the descriptions before the AIF was submitted
• Verified that the cost schedule reconciles with the actual expenditure of the company
• Technical or commercial knowledge of the R&D activities being claimed

The named officer is not required to have written the AIF, and in most companies the detailed drafting is done by the R&D adviser. What they are required to do is read it, check it, and confirm that the contents are accurate to the best of their knowledge. HMRC expects this to be a substantive review, not a rubber stamp.

Who Can Be the Named Officer

The guidance specifies a director or senior finance officer. In practice, the most appropriate person is usually one of:

• The managing director, where the MD has personal involvement in the company's R&D activities
• The finance director or CFO, who understands the cost schedules and the financial structure of the claim
• The chief technology officer, where the R&D is primarily technical and the CTO has the strongest understanding of the project content
• A director with technical responsibility for the specific projects being claimed

The external R&D tax adviser cannot be the named officer. The requirement is specifically for an internal senior officer of the claiming company. This matters because one of the policy objectives of the named officer requirement is to ensure that someone within the company has actually engaged with the content of the claim, rather than delegating the entire process to an external firm.

Where a company has multiple projects being claimed, the named officer does not need personal involvement in every project. They do need to have reviewed the project descriptions and cost schedules and to be satisfied that the claim is accurate overall. If one director oversees most of the technical R&D and another oversees the finances, consider which one has the broader visibility of both dimensions and can speak to the claim as a whole.

What the Named Officer Is Attesting

The framing in the AIF guidance is that the named officer is "responsible for the R&D claim." Unpacking what this means in practice:

Accuracy of the project narratives

Each project in the AIF must include a description of the field of science or technology, the baseline knowledge level at the start of the project, the specific advance being sought, the scientific or technological uncertainties encountered, and how those uncertainties were or are being addressed. The named officer is confirming that these descriptions are accurate. Where a narrative has been drafted by an adviser and contains technical inaccuracies or overstatements about the nature of the advance, the named officer's association with the claim is direct.

Accuracy of the cost schedules

The AIF includes cost information by qualifying expenditure category. The named officer should verify that the costs claimed match actual expenditure, that the apportionment between R&D and non-R&D use is reasonable, and that the costs fall within the categories permitted under the merged scheme rules. A finance director is usually best placed to sign off on this dimension.

Identification of the agent

The AIF also requires the company to name all agents involved in preparing the claim, including the adviser and anyone else who assisted. This is linked to the mandatory agent registration requirement from 18 May 2026. HMRC now uses the AIF to track which advisers are associated with which claims, and that information feeds into both compliance activity and the wider adviser accountability framework.

What Could Go Wrong and Why It Matters

The named officer requirement has heightened the personal accountability of directors in a way that did not previously apply to R&D claims. Consider the following scenarios:

Generic project descriptions

HMRC has stated publicly that it can identify when project descriptions are generic, inconsistent with the company's sector, or contain technical inaccuracies. A description that says a software project "sought to advance the state of the art in machine learning" without specifying the advance, the existing baseline, or the uncertainty involved will not hold up in an MREP review. If the named officer approved a description in that form without flagging the problem, they have approved an inaccurate document.

Costs that do not reconcile

R&D claims that include costs not supported by the underlying financial records are a common source of HMRC adjustment. If the named officer approved a cost schedule without verifying that the figures could be backed by payroll records, invoices, or contracts, the company is exposed to both the cost of repayment and a potential penalty discussion.

Activities that do not qualify

HMRC's MREP2 data found that in 2021 to 2022, 30 per cent of SME claims were wholly non-compliant, meaning the activities claimed did not meet the definition of qualifying R&D. In most of those cases, the company was not aware that its activities did not qualify: it relied on an adviser's assessment. The named officer requirement places the company's own senior person directly in the review chain. A director who asks the adviser to explain why each project qualifies, and who challenges any project they are not convinced by, provides a meaningful check that reduces this risk.

How to Evidence "To the Best of My Knowledge"

The standard applied to the named officer's accountability is whether the information was accurate "to the best of their knowledge." This is a lower standard than absolute certainty. A director who cannot personally verify every line of a technical project narrative is not expected to have done laboratory work. What they are expected to have done is read the narrative, cross-referenced it with what they know about the project, and either confirmed it or asked the adviser to correct it.

In practice, a director can evidence that they carried out a genuine review by:

• Keeping a record of the review meeting or email exchange in which the AIF draft was discussed with the adviser before submission
• Documenting any questions raised and the adviser's responses
• Ensuring that the project descriptions were reviewed by the relevant project leads within the company, not just by the external adviser
• Keeping a copy of the AIF as submitted, with a note of the date and who reviewed it

This matters most if HMRC later opens a compliance check and the named officer's conduct is scrutinised. A director who can show a paper trail of review has a strong position. A director who cannot recall ever seeing the AIF before it was filed has a weak one.

Penalties and Professional Consequences

Where an R&D claim contains inaccurate information and results in an overclaimed refund, the company must repay the excess plus interest calculated at HMRC's statutory rate. On top of that, HMRC can charge penalties. The penalty regime under Schedule 24 of the Finance Act 2007 applies to inaccuracies in tax returns and documents. The penalty scale is:

• Careless inaccuracy: up to 30 per cent of the additional tax due
• Deliberate inaccuracy: up to 70 per cent of the additional tax due
• Deliberate and concealed inaccuracy: up to 100 per cent of the additional tax due

The named officer's personal accountability does not create personal liability for the company's tax debt. Corporation tax is owed by the company, not by the director. What the named officer requirement does create is a clear record of who within the company was responsible for the accuracy of the claim, which is relevant to any assessment of whether conduct was careless or deliberate.

Beyond HMRC penalties, a director who approved a claim that later proved to be substantially inaccurate may face scrutiny from their company's board, audit committee, or shareholders. In companies where the R&D claim is material to the financial statements, the named officer's conduct is also relevant to the company's statutory directors' duties under the Companies Act 2006.

A Practical Checklist for Named Officers

Before the AIF is submitted, the named officer should be able to answer yes to each of the following:

• Have I read every project description in the AIF?
• Has each project description been confirmed as accurate by a technical person at the company who worked on that project?
• Do I understand why each project qualifies as R&D for tax purposes, including the specific advance and uncertainty?
• Have I reviewed the cost schedule and verified that the figures are supported by financial records?
• Have I confirmed that the adviser named on the form is registered with HMRC or has applied for registration?
• Has the AIF been submitted before or on the same day as the Corporation Tax return?
• Do I have a record of this review in case HMRC asks about it later?

If any of these questions cannot be answered yes, the claim is not ready to be filed. A specialist R&D adviser working to the standard required by PCRT should raise these points proactively. If they do not, that is a signal about the quality of the advice.

Uplift Tax introduces companies to HMRC-registered R&D specialists who build the named officer review into their claims process as standard. Get a free assessment to discuss your position before the next claim is filed.