Claim Notification Forms (CNF): Emerging insights and good practice

We’ve been discussing pre-notification throughout the year and how claim notification forms (CNFs) have introduced practical challenges for R&D tax relief.

The rules can be hard to interpret, creating uncertainty about if and when a CNF is required. Missed claims have arisen in part because the requirement itself was not always clearly communicated to the sector.

Added to this, the instructions provided through HMRC’s portal about what is required are high-level and sometimes ambiguous. A regular question in our customer WhatsApp group is: What content actually needs to be included in the form?

Until now, HMRC has not issued any formal feedback on submitted CNFs. With the first wave of notified claims reaching their systems only now, we’re starting to hear anonymised insights from HMRC-facing contacts.

While not official guidance, these early observations shed light on how CNFs are being received and are consistent with HMRC’s broader focus on compliance across the R&D scheme.

Here’s what our source told us:

• Repeated wording across clients: HMRC have noticed instances where agents submit multiple CNFs for different companies, all with identical descriptions of the R&D. This may prompt further enquiries.
• Overly brief descriptions: Some CNFs contain little more than “R&D was carried out.” Although such wording technically fits the requirement for “a summary of the high-level planned activities,” it is not as informative as HMRC would like to see and may be questioned.
• Incomplete or nonsensical entries: A few forms have been submitted with placeholder or random text. These do not meet the requirements and risk rejection or follow-up.

The key takeaway?

HMRC are reviewing CNFs and patterns are being noticed. That makes it essential to treat the CNF as a meaningful step in the claims process.

Reflecting on CNFs and timing

Given what we now know, is there possibly a disconnect between the information provided in a CNF and the details eventually included in a full R&D claim? Because a CNF can be submitted on the first day of an accounting period, the full extent of R&D activity within that period may not yet be known. This raises questions about the intended purpose of the form and if and how it will be used alongside the eventual claim submission.

And finally, during our recent discussion, we also touched on the current CNF submission window – six months after the accounting period ends – and how this may be shorter than practical for many companies and advisers. R&D activity is often only fully considered when year-end accounts are prepared, nine months after the period ends. Aligning the CNF deadline more closely with the year-end could reduce missed claims and make the process easier to manage, while still supporting HMRC’s aim of early notification.

Let us know what you think!

For further information, you can review HMRC’s guidance on claim notification forms here

And for a distilled down version about pre-notification, the CNF and how to manage the process, why not check out our recent blog

If you’d like to see how our newly updated WhisperClaims app helps you stay on track with the new Merged Scheme – including built-in guidance, risk assessments, and Advice Line support – why not book a demo today?

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