As advisers and R&D tax relief claimants started wrestling in earnest with new RDEC and ERIS claims, we were very pleased that no new changes to the R&D tax relief scheme were announced at the March 2025 Spring Statement. However, as expected, HMRC did release some updates to their guidance, and an unexpected but welcome consultation into Advance Assurance was launched.
This consultation focuses on the current Advance Assurance scheme, delving into why only 80 applications were received in 2023/24 out of 11,500 potential users. HMRC seeks to explore whether this scheme could be expanded, what the advantages and disadvantages of this would be and whether such a scheme would be mandatory. The consultation is live now and runs until the 26th May 2025. We will, of course, be preparing and submitting a response.
Finance Act 2025 has now been enacted, which means that the legislation around NI ERIS claims is no longer draft and HMRC have been able to publish full guidance on how to make these claims. The CIRD guidance doesn’t contain anything unexpected, but a key point that HMRC have made is that the Additional Information Form (AIF) is not currently able to gather all of the required information about NI ERIS claims – users can’t yet make the required declarations about the amount of de minimis aid received, for example. They expect to have this functionality ready in a few months, and in the meantime will contact anyone making a claim for NI ERIS after submission to complete the process.
HMRC have identified ERIS claimants who do not appear to meet the ERIS criteria and will be contacting these claimants to check. These claimants will be given the opportunity to either confirm their eligibility for ERIS or amend their claim to route it through new ERIS instead. HMRC haven’t given any details as to how these claimants have been identified, or how these claims were able to be made despite the detailed ERIS eligibility checks in the AIF.
HMRC have indicated that they are aware that there is no option on the CT600L for claimants to indicate that they are exempt from the PAYE cap for claims made under new RDEC or ERIS.
They advise claimants to ensure that the amount entered in Box L75 equals the amount entered in Box L70, so the amount of Step 3 restriction carried forward to next AP in Box L80 is zero, and to a note in their computations or in a PDF attachment with the CT return that they are claiming an exemption under CTA09/S1112E.
The CT600L will be updated in April 2026 to fix this issue.
So, while the absence of new legislative changes in the Spring Statement offers some stability, HMRC’s latest updates highlight ongoing adjustments and areas for improvement within the R&D tax relief landscape. The Advance Assurance consultation presents an opportunity to shape future policy, while practical guidance on ERIS, NI ERIS, and the CT600L underscores the need for claimants to stay informed and proactive.
If you have any questions about these updates or need support with your R&D tax claims, get in touch with our team – we’re here to help.
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