When clients say ‘HMRC says I qualify’: A closer look at HMRC’s new R&D tax eligibility tool

At the end of September HMRC launched an online R&D eligibility checker . A self-service tool designed to help companies understand whether their project might qualify for R&D tax relief.

The tool takes a claimant through a short series of questions before giving an outcome on whether the project “includes qualifying R&D for tax purposes.”

On the surface, this is a positive move. Anything that helps improve understanding of the rules and supports compliant claims is to be welcomed. But, for accountants and advisers working directly with claimant companies, this new tool could also bring new challenges – particularly when it comes to managing client expectations.

Where good intentions meet practical limitations

The tool splits its questions into three sections:

Identifying the project

Establishing the competent professional, baseline and advance

Confirming the presence of scientific or technological uncertainty

If the user answers these largely “yes/no” questions in a certain way, the outcome given is (what appears to be) a clear and confident message that the project includes qualifying R&D.

Screenshot: Example outcome from HMRC’s R&D eligibility checker

While HMRC does caveat that the result may be unreliable if the user hasn’t read the linked guidance, the only link provided is to the Guidelines for Compliance (GfC3) . This is a valuable set of documents but, it’s less detailed than the BEIS or CIRD guidance that advisers should be fully across.

The concern here isn’t about the intent – HMRC’s goal of encouraging understanding is commendable – but about the definitive tone of the output. The tool’s binary outcome doesn’t always reflect the nuance of R&D eligibility, and it would be easy for a company with only a surface-level understanding of the rules to reach a positive result.

That means advisers could soon face more conversations with clients who arrive confident they “definitely qualify”, when in fact the reality may be more complex.

What advisers should do next

Familiarise yourself with the tool – understanding the flow and logic makes it easier to discuss with clients who’ve tried it

Ask why clients answered as they did – it can reveal how well they understand the scheme and help guide the conversation

Reinforce your process – use a structured, repeatable method for assessing eligibility, so you can always back up your conclusions with clear reasoning, especially if those differ from HMRC’s quick tool output.

A step in the right direction – but more to do

HMRC’s move to provide public guidance tools is very encouraging. Anything that helps to demystify R&D tax relief and promote compliance deserves recognition.

But, for the tool to genuinely support compliant claiming, its output may need refining. For example:

Using softer outcome wording (“you might qualify” rather than “your project includes qualifying R&D”)

Including stronger disclaimers about the limitations of self-assessment

And ideally, signposting next steps i.e. encouraging companies to discuss results with their accountant or a credible R&D adviser, rather than treating the result as confirmation

With thoughtful iteration, tools like this could help HMRC and advisers work more collaboratively, supporting claimants while reducing misunderstanding and risk.

The power of no

At WhisperClaims we’ve long advocated for what we call the “power of no” – helping accountants and advisers have confident, evidence-based conversations with clients about eligibility, even when the conclusion is that a project doesn’t qualify.

Being able to demonstrate why something doesn’t meet HMRC’s criteria is just as valuable as confirming when it does. It builds trust, protects the client from future exposure and preserves the adviser’s professional integrity.

That’s exactly why our software provides a structured framework for assessing eligibility – giving users both the language and the evidence trail to support transparent conversations with clients. Knowledge and structure turn what could be a difficult “no” into a constructive discussion about risk, alternative support options and next steps.

If you’d like to explore how our software can support your firm, get in touch to find out more. We don’t prepare claims – you do.

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