Subcontracted R&D, EPWs and overseas costs: Webinar catch up

Author: Suz Harkness Published: 28th February, 2026

Nearly two years after the introduction of the merged RDEC and ERIS schemes, many firms are now preparing claims fully under the new rules. As a result, technical questions around subcontracted R&D, EPWs and overseas costs are popping up as the theory is being put into practice.

Through supporting hundreds of claim preparations each year, WhisperClaims has a clear view of where firms are encountering difficulty. In our recent webinar, we explored some of these key areas.

Overseas cost restrictions

The merged schemes introduced new restrictions on overseas expenditure meaning that:

  • Payments to subcontractors are only allowable where the R&D activity is carried out in the UK, unless exemption criteria apply
  • EPW costs are only allowable where payments are subject to UK PAYE
  • Detailed justification is required where overseas activity is included under the exemption rules

In practice, firms are finding that determining where work was actually carried out, and documenting the reasons for any overseas activity, requires more structured evidence gathering than under the previous schemes.

Contracted-out R&D

The merged schemes also introduced a clearer framework for determining which company can claim for contracted-out R&D.

Eligibility now centres on:

  • Who initiated the R&D
  • Whether R&D was intended at the point the contract was agreed

Although the principles are clearer, applying them in real situations requires careful judgement and clear documentation.

Increased information requirements

Alongside the rule changes, the Additional Information Form (AIF) requires significantly more detail about subcontractors and overseas activity.

Firms now need to capture information such as:

  • Subcontractor company details and locations
  • PAYE references for EPWs
  • Overseas activity and exemption reasoning
  • Project-level cost breakdowns

Without this information, subcontractor and EPW costs may not be claimable.

A structured approach to claim preparation

As claims under the merged schemes become routine, many firms are recognising the need for a more structured preparation process to ensure that key questions are addressed consistently, and that supporting evidence is captured as the claim is prepared.

WhisperClaims provides a compliance-first framework designed specifically for accountants and advisers preparing R&D claims in-house.

Our platform guides users through eligibility costs and evidence requirements, produces structured outputs, including everything you need to complete the Additional Information Form, and provides access to expert support through our Advice Line channels.

Watch the webinar

Our recent webinar is available on demand to watch back, where you will hear a round up of the rules, and get to see a short demo of how WhisperClaims’ compliance-first framework ensures the right questions are asked, and the right data is gathered, every single time.

Watch webinar on-demand

And, if your firm would benefit from a structured, evidence-led process for subcontracted R&D and overseas cost rules, WhisperClaims provides guided workflows, risk reviews and expert support to help you and your team prepare robust claims with confidence.

Book a demo to see how it works.

Book a demo

Never miss a beat. Get R&D tax scheme updates and guidance sent straight to your inbox!

Subscribe to email updates

Get started - Book a demo and get a 30-day free trial!

Book a Demo

© 2026 Wobbegong Technology Ltd (Registered number 10754811), trading as WhisperClaims.

WhisperClaims is a registered trademark of Wobbegong Technology Ltd (Trade Mark No.: UK00003360482).

WhisperClaims

Complete the form and we’ll be in touch to arrange a time!
First Name  *
Last Name *
Business Email *
Phone *
Company Name 
*Required fields
By submitting this form you consent to WhisperClaims sending you ongoing communications, in accordance with our  Privacy policy   

Please complete this form to create an account, receive email updates and much more.
First Name  *
Last Name *
Business Email Address *
Company Name 
*Required fields
By submitting this form you consent to WhisperClaims sending you ongoing communications, in accordance with our  Privacy policy