For accounting periods starting on or after 1 April 2023, the Claim Notification Form (CNF) will become a statutory requirement for some R&D tax relief claimants.
A CNF needs to be submitted to HMRC if you are planning to claim R&D tax relief for the first time, or your last claim was made more than 3 years before the last date of the “claim notification period” (see more detail below).
The form should be completed by a representative of the company or agent acting on your behalf.
In general it is correct that any company that has made a claim in any of the earlier 3x accounting periods does not need to submit CNF for their fourth accounting period in which they intend to make a claim.
However, it should be stressed that it’s three years before the last day of the claim notification period (not from the end of the accounting period). Notification must have been made by that date (e.g. an intention to make a claim for an earlier period which will ‘frank’ that later period but is not made within the six months).
Additional layers of complexity, such as the inclusion of R&D claims through amended returns, may create issues around the timing of advanced notification but in the most straight forward of circumstances the below worked example would apply.
First step – identify your claim notification window
Suppose a company has an accounting period that runs from 1 April 2025 to 31 March 2026. The company can notify HMRC of its intention to claim R&D tax relief for this accounting period during the claim notification window – this starts on the first day of the accounting period, 1 April 2025, and ends six months after the end of the accounting period, 30 September 2026.
Second step – check if the three year exemption applies
The company does not have to submit a claim notification form for the current accounting period if the company made an R&D tax relief claim for an earlier period at any point during the three years that ends with the last date of the claim notification window i.e. at any point between 1 October 2023 – 30 September 2026. R&D claims made through an amended tax return may need additional consideration to ensure that the timing of the amendment doesn’t take you out of the three-year window.
Third step – if the three-year exemption does not apply check whether a relevant claim has been made after the last date of the claim notification window:
If the company made an R&D tax relief claim for an earlier period but they submitted that claim after the last date of the claim notification period for the current year of 30 September 2026 (i.e. after the normal claim deadline but before the CT return amendment deadline), then the company will have to submit a claim notification for the current accounting period to claim R&D tax relief.
Fourth step – check if the long period of account exemption applies:
The exception to the previous step would be where the earlier and current year accounting periods form one long period of account and a claim notification has been received which covers the whole period of account.
To complete the CNF you will need:
To compound the issues in this already confusing area, HMRC itself published incorrect guidance in the Corporate Intangible Research & Development Manual (CIRD183000) on 8 Sept 2024. The correction wasn’t made until 17 October, six weeks later.
This error provided an inaccurate interpretation of the requirement for a claim notification and how exemptions were to be applied.
For clients affected by the incorrect information, HMRC has agreed an appeal process and will allow claims for an accounting period without a CNF where the following apply:
A company made a valid claim to R&D in an amendment to a return for an accounting period beginning before 1 April 2023, which was submitted to HMRC between 1 April 2023 and 30 November 2024 inclusive.
The accounting period for which a Claim Notification was not delivered, but ought to have been, had a claim notification period ending between 8 September 2024 and 30 November 2024.
