In 2026, a good R&D tax consultant is defined less by how much value they can “find” and more by how confidently a CFO can defend that value under scrutiny. With tighter filing requirements, more structured disclosures, and higher expectations of evidence, “good” now means audit-ready, enquiry-ready, and board-ready.
R&D Tax Consultant in 2026: What “Good” Looks Like Under the New Compliance Reality
Introduction
The UK’s R&D tax relief remains a cornerstone of innovation finance, but the compliance environment has changed materially. HMRC has consistently highlighted historic levels of error and fraud as a driver for reform, which explains the sustained policy and operational focus on claim quality.
For CFOs, the issue is not theoretical. It is practical and immediate: cash flow timing, uncertainty in recognising benefits, audit sign-off pressure, and the risk that an enquiry absorbs senior management time for months.
What an R&D tax consultant does in 2026
An R&D tax consultant translates scientific or technological work into a Corporation Tax position that HMRC can accept. In 2026, this requires three disciplines operating together:
- Technical eligibility: demonstrating a genuine advance in science or technology and the resolution of technical uncertainty
- Cost eligibility: mapping qualifying activities to qualifying costs, with reconciliations back to the ledger and CT600
- Compliance governance: meeting mandatory submission requirements, providing named accountability, and maintaining enquiry-ready documentation
The most credible advisers also understand CFO constraints, including audit evidence thresholds, accounting policy interactions, cash runway management, and avoiding uncertain tax positions that may later crystallise as liabilities.
The compliance reality shaping “good” in 2026
Several policy changes are now embedded in how HMRC assesses claims, materially altering what good advisory support looks like.
1) A merged regime with enhanced support for R&D intensive businesses
For accounting periods beginning on or after 1 April 2024, the UK moved to a merged R&D expenditure credit regime for most claimants, with Enhanced R&D Intensive Support (ERIS) available to qualifying loss-making SMEs. The merged credit rate sits at 20%, and the PAYE cap remains a binding constraint unless an exemption applies.
2) Claim notification is now an early gate
Some companies, including first-time claimants and certain returning claimants, must submit a claim notification before making an R&D claim. If notification is required and missed, the claim is invalid regardless of merit.
3) The Additional Information Form is mandatory
The Additional Information Form (AIF) must be submitted before or on the same day as the Company Tax Return. If both are filed on the same day, the AIF must be submitted first. A missing or late AIF invalidates the claim.
4) Pre-claim certainty is moving up the agenda
Government has confirmed a targeted advance assurance pilot planned for Spring 2026. This reflects demand for earlier certainty and a recognition that prevention is cheaper than post-claim compliance activity.
5) Transparency and automation debates raise the bar on clarity
Recent scrutiny of HMRC decision-making processes has increased the premium on structured, consistent, and well-evidenced claims that can withstand systematic review.
What “good” looks like: a CFO-grade benchmark
A good R&D tax consultant in 2026 demonstrates the following behaviours.
1) Evidence-first, not narrative-first
The claim is built around contemporaneous evidence, not retrofitted storytelling. A reviewer should be able to understand eligibility from the evidence alone.
Minimum standard evidence pack
- Project scoping notes and baseline assessment
- Competent professional role definition and sign-off
- Defined technical uncertainties and alternatives considered
- Experimentation records, testing outcomes, and iteration logs
- Version-controlled technical documentation
- Clear cost mapping from activity to general ledger to tax computation
2) Regime accuracy by accounting period
Where periods span legislative change, claims are segmented correctly. Good advisers avoid blending rules across regimes or applying simplified assumptions that do not stand up to review.
3) Cost traceability aligned with audit standards
CFOs value defensibility over creativity. Strong advisers reconcile staff costs to payroll and roles, evidence subcontractor scope and eligibility, and document all apportionment assumptions.
4) Disciplined disclosures
The AIF and any required notifications are treated as regulated submissions. Agent involvement, project descriptions, and cost categories are disclosed consistently and accurately.
5) Explicit risk assessment
Good advisers present a written risk register, grading eligibility strength, highlighting cost categories most exposed to challenge, and setting out residual risk clearly.
6) Enquiry readiness by design
Given extended enquiry timelines and cash flow disruption, advisers assume scrutiny is possible and prepare accordingly. Evidence is assembled before filing, not after a compliance letter arrives.
7) Competent professional alignment
Eligibility is grounded in real technical expertise. The competent professional is clearly identified, understands the work, and can articulate why it goes beyond routine practice.
How a compliant claim is built in practice
A robust 2026 process is operational and repeatable:
- In-year capture of projects, uncertainties, and decisions
- Eligibility gating against HMRC criteria
- Cost mapping with ledger reconciliation
- Structured AIF preparation
- CFO and competent professional sign-off
- Independent quality assurance review
- Enquiry pack finalised prior to submission
“Good” versus risky: a CFO scorecard
Dimension
Good in 2026
Risk signal
Eligibility
Specific uncertainties and outcomes
Generic sector narratives
Costs
Ledger-linked, evidenced
Rounded estimates
Compliance
Timely AIF and notification
Treated as admin
Governance
Named owners and approvals
No accountability
Enquiry
Ready pre-filing
Built reactively
Mini case study: clean claims outperform inflated ones
A UK software scale-up developing a performance-critical platform separates genuine technical uncertainty from routine feature delivery. Rather than claiming all engineering time, mixed activities are apportioned with evidence. The result is a lower headline benefit, but faster cash conversion, reduced enquiry risk, and greater confidence at board level.
FI Group insight
Consultancy FI Group highlights that the new compliance reality requires finance teams to treat R&D tax relief as a governed financial process, not a one-off exercise. Their experience shows that early technical scoping, in-year evidence capture, and disciplined documentation significantly reduce disruption if a claim is reviewed. FI Group also emphasises the value of coordinating technical specialists and tax professionals, particularly for businesses with multi-site R&D operations and complex delivery models.
FAQs
What is the biggest change for R&D tax claims since 2023?
Mandatory structured disclosures and stricter up-front validity conditions.
Who needs to submit a claim notification?
Typically first-time claimants and certain companies returning to the regime after a gap.
What is the merged scheme rate in 2026?
The merged R&D expenditure credit rate is 20%.
What is ERIS?
Enhanced R&D Intensive Support provides additional relief for qualifying loss-making, R&D intensive SMEs.
How should CFOs choose an R&D tax consultant in 2026?
By prioritising evidence discipline, regime accuracy, governance, and enquiry readiness over aggressive interpretations.
