RDEC Claims: HMRC Doubles Down on Accountability

How the recent AIF portal changes and automated compliance checks impact R&D tax relief submissions

Over the last few years, anyone working seriously in the Research and Development (R&D) tax relief space has seen the writing on the wall. HMRC has fundamentally shifted its focus. It is no longer just about calculating numbers; it is about governance, technical credibility, absolute accountability and the quality of claim preparation.

With the transition to the unified RDEC / Merged Scheme framework, HMRC is using its digital infrastructure to rigorously gatekeep claims. Two critical operational developments within the Additional Information Form (AIF) submission process signal exactly how HMRC is profiling risk.

In this news item I use my insights as an R&D professional consultant to assess what this means for claimant companies. (Published May 2026)

1. The Expanded Senior Officer Declaration: True Director Accountability

One of the most telling updates to the mandatory AIF online form is the expansion of the senior officer declaration section.

Previously, the AIF required a nominated senior officer to merely confirm the submission and agree to receive email communications. Today, HMRC explicitly requires confirmation that the signing senior officer has personally read HMRC’s formal R&D guidance before clicking submit. This seems designed to dismantle a defense used in the past to avoid penalties for invalid claims, where directors were able to make the case that they had acted with "reasonable care" by hiring a specialist advisor.

The Takeaway: HMRC is actively trying to end the era of "hands-off" sign-offs. They want to ensure directors cannot claim ignorance if a submission is found to be non-compliant. 

Personally, I have always believed that any director signing off on an RDEC claim must thoroughly understand four core areas:

• The Scope: The exact nature of the projects being claimed.

• The Science: The precise technical basis on which the work qualifies.

• The Math: The exact cost breakdowns included in the submission.

• The Liability: The legal weight of the declaration regarding R&D being made to HMRC.

The True Role of the Competent Professional

This shift highlights why the Competent Professional (the technical expert leading the project) can no longer be a passive figure whose name is simply added to a report for credibility. HMRC expects genuine, collaborative technical input. A robust claim must explicitly detail:

• The specific scientific or technological uncertainties encountered.

• Why the solution was not readily deducible to another experienced professional in that field.

• How the project actively sought to achieve an overall advance in science or technology.

2. SIC Code "Challenge" Questions & Risk Profiling

The second development is the introduction of automated Standard Industrial Classification (SIC) code challenge questions directly within the AIF submission workflow.

If a company’s primary SIC code falls outside of traditionally tech-heavy or scientific sectors, the portal triggers an explicit prompt stating the code is "not usually associated with qualifying R&D activity." The user must then provide a dedicated, explicit justification of why the work qualifies before the form can even be submitted.

This is a clear window onto one aspect of HMRC’s automated risk-profiling algorithms.

HMRC Risk Screening Process on AIF

  
Check Company SIC Code ──► Outside Traditional R&D Sector?

   ▼ (Yes)

Triggers AIF Challenge Block

▼

Requires Explicit Technical Justification to Proceed