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White Paper No. 32

HMRC error and fraud estimates

White Paper No. 32

HMRC error and fraud estimates

This paper sets out research and the publisher's opinion. Factual statements are cited to their sources. It makes no allegation about any firm or person not named in a cited official record.

Since 2019 to 2020 HMRC has estimated how much of the money paid out through the UK research and development reliefs was claimed in error or by fraud. This paper sets out how those estimates are made, how they have been revised, what the random enquiry programmes found, and the policy response that followed.

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Summary

  1. HMRC's first estimates of error and fraud in the R&D reliefs, built from risk based compliance reviews, put the rate at 3.6 to 4.9 percent, and the National Audit Office later said the assumptions behind them understated the true level.

  2. When HMRC switched to random enquiries, its estimate for 2020 to 2021 rose from 3.6 percent to 16.7 percent, and its estimate for 2021 to 2022 was 17.6 percent, with 25.8 percent for the SME scheme.

  3. HMRC's July 2026 annual report gives a final estimate of 6.4 percent for 2023 to 2024 and illustrative estimates of 5.3 percent for each of the two following years, and links the fall mainly to digital claims and the additional information requirements introduced in 2023.

  4. The SME scheme remains the main source of error and fraud, and the Comptroller and Auditor General has qualified his opinion on HMRC's accounts every year since 2019 to 2020 because of it.

  5. HMRC's published analysis distinguishes claims made with and without a specialist R&D agent, and by the agent's professional body membership, but no published estimate distinguishes claims by how the agent was paid.

Contents
  1. 1Summary
  2. 2Why HMRC estimates error and fraud in the reliefs
  3. 3The first method: risk based compliance reviews
  4. 3.1How the early estimates were made
  5. 3.2What the National Audit Office said about them
  6. 3.3The 2022 attack on the payable credit
  7. 4The random enquiry programmes
  8. 4.1What a random enquiry programme is
  9. 4.2The four programmes so far
  10. 4.3The National Audit Office's observations
  11. 5The estimates and their revisions
  12. 5.1From first estimate to latest estimate
  13. 5.2Why the numbers moved
  14. 5.3Statistical caveats
  15. 6What the random enquiries found about claims
  16. 6.1The shape of non-compliance
  17. 6.2Agents
  18. 7The policy response
  19. 7.1Parliamentary scrutiny
  20. 7.2The measures
  21. 7.3How HMRC connects the estimates to the measures
  22. 8What the estimates do not show
  23. 9What the record shows
  24. References

1Summary

The United Kingdom pays research and development (R&D) relief to companies through Corporation Tax, and much of it is paid in cash. Because of that, HMRC reports the reliefs as expenditure in its accounts and must estimate how much of that expenditure was paid in error or as a result of fraud.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). It has published an estimate every year since 2019 to 2020.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).

The estimates have changed a great deal. The first ones, based on compliance cases selected for risk, put error and fraud at between 3.6 and 4.9 percent of the cost of the reliefs.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). In 2023 HMRC began using a random enquiry programme, which examines a random sample of claims in full. Its revised estimate for 2020 to 2021 was 16.7 percent, and for 2021 to 2022 it was 17.6 percent, with the SME scheme at 25.8 percent.3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). HMRC's July 2026 annual report gives a final estimate of 6.4 percent for 2023 to 2024 and illustrative estimates of 5.3 percent for the two following years.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

This paper explains how the estimates are made, why they were revised, what the random enquiries found about claims and agents, and the measures that followed. It relies only on HMRC and National Audit Office publications. It describes the UK record and makes no recommendation for the United Kingdom.

2Why HMRC estimates error and fraud in the reliefs

HMRC operates the R&D reliefs as part of Corporation Tax. Its Resource Accounts report spending on the schemes as expenditure because they often result in cash payments, unlike most other tax reliefs.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). Where error or fraud leads HMRC to overpay a claimant, the National Audit Office treats the payment as not conforming with Parliament's intention, and so as irregular.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

HMRC has included an estimate of error and fraud in the reliefs in its accounts since 2019 to 2020, "in response to the increasing take up of these reliefs over recent years".2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026). The Comptroller and Auditor General has qualified his opinion on the regularity of HMRC's accounts on this ground every year since then.6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). When it first asked HMRC to produce an estimate, the National Audit Office pointed to HMRC's own "Strategic Picture of Risk", the growth in spending on the schemes, and "an increase in public reporting of instances of abuse of these schemes, including through unregulated agents".1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

The term "error and fraud" is wide. HMRC uses it to cover "mistakes and failure to take reasonable care through to deliberate non-compliance".3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026). To classify a case as fraud, a caseworker must have found evidence that the claimant "deliberately set out to misrepresent their circumstances to get money to which they were not entitled".3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026). A common example of error given by HMRC is claiming for expenditure that was not incurred on qualifying R&D activity.7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).

3The first method: risk based compliance reviews

3.1How the early estimates were made

For 2019 to 2020, 2020 to 2021 and 2021 to 2022, HMRC estimated error and fraud by combining results from claims it had reviewed through its compliance work with an estimate for the claims it had not reviewed, using comparable error rates from its tax gap work.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026). Its 2021 to 2022 annual report listed the uncertainties: the rate was extrapolated from historic compliance activity; it assumed that error in claims not reviewed matched general error rates in the tax gap; and the cost of the reliefs was itself an estimate. HMRC said that, given these uncertainties, it could not produce "a meaningful range of outcomes" for the estimate.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).

Year SME scheme RDEC Overall
2019 to 2020 5.6% (£271m) 1.0% (£40m) 3.6% (£311m)
2020 to 2021 5.5% (£303m) 0.9% (£33m) 3.6% (£336m)
2021 to 2022 7.3% (£430m) 1.1% (£39m) 4.9% (£469m)

Figure 1. HMRC's estimates of error and fraud under its earlier method, as reported by HMRC and the National Audit Office.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

HMRC said the rise in 2021 to 2022 "reflects improvements in HMRC's risk identification process".2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).

3.2What the National Audit Office said about them

The National Audit Office later explained that these estimates rested on compliance cases where HMRC had assessed the claims as at risk, together with assumptions including "that unreviewed cases have a lower rate of error and fraud". It said they were enough to show that error and fraud was material, but were limited by the data on unreviewed cases, so that the actual level "could be significantly different". It added: "This is borne out in the significantly higher levels of error and fraud reported in HMRC's current estimates."1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

3.3The 2022 attack on the payable credit

In April 2022 HMRC identified a pattern of irregular claims, which it later described as "a criminal attack on the R&D payable tax credit regime".2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026). It introduced a threat risk assessment of all R&D claims, more payment identification and verification controls, and an accelerated R&D Anti Abuse Unit.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026). By July 2023 it reported that it had refused £85 million of suspected fraudulent claims, issued over 2,500 letters challenging suspect claims, and arrested 9 people suspected of conspiring to submit £16 million of fraudulent claims.3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).

4The random enquiry programmes

4.1What a random enquiry programme is

A mandatory random enquiry programme (MREP) takes a random sample of claims and subjects each to a full enquiry. HMRC describes the approach as representing "international best practice", and the National Audit Office describes it as "good practice in the measurement of error and fraud".8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). The programmes cover claims made by small and medium-sized enterprises (SMEs), under the SME scheme and under the R&D expenditure credit (RDEC). Large businesses claiming RDEC were not included, because HMRC considered that its customer compliance manager model gave it sufficient insight into those claims.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).

Random enquiries introduce a lag. Companies claim up to two years after incurring the expenditure, and enquiries take time to close, so each programme measures claims made some years before the estimate is published.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

4.2The four programmes so far

Programme Sample Claims examined Share with some non-compliance
MREP 1 Random sample of 500 SME claims filed in 2020 to 2021 484 closed when the estimate was made 244 (50%)
MREP 2 Stratified random sample of 404 claims filed in 2021 to 2022 387 closed 200 (52%)
MREP 3 Stratified random sample of 350 claims filed from 1 November 2023 to 29 February 2024 334 closed by July 2026 109 (33%)
MREP 4 Not stated in the reports reviewed 61% of enquiries closed by July 2026 Not yet used

Figure 2. HMRC's random enquiry programmes, as described by the National Audit Office.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

The sampling changed over time. For MREP 2 HMRC moved from a wholly random sample to a stratified one, by type of relief and size of claim. For MREP 3 it sampled proportionately more high value claims, which earlier programmes had found to yield more.4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).9Source 9National Audit Office, Report by the Comptroller and Auditor General on HM Revenue & Customs 2024-25 Accounts, published within HMRC's Annual Report and Accounts 2024 to 2025, Summary paragraphs 9 and 10, and Part Two, paragraphs 2.5 to 2.17, Figure 8 and paragraph 2.41. https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026). In each programme HMRC applied a "non-detection multiplier" to allow for error or fraud that caseworkers may have missed, and estimated the likely yield from enquiries that were still open.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

MREP 3 is the first programme drawn wholly from claims made after the additional information form became mandatory on 8 August 2023.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026). When HMRC produced its 2024 to 2025 accounts, it had closed 296 of the 350 enquiries, and 88 of them (30 percent) had found some non-compliance.9Source 9National Audit Office, Report by the Comptroller and Auditor General on HM Revenue & Customs 2024-25 Accounts, published within HMRC's Annual Report and Accounts 2024 to 2025, Summary paragraphs 9 and 10, and Part Two, paragraphs 2.5 to 2.17, Figure 8 and paragraph 2.41. https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026). By the 2025 to 2026 accounts it had closed 334, and 109 (33 percent) had found some non-compliance.6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). HMRC did not use MREP 4, because only 61 percent of its enquiries had closed when the latest estimate was produced.6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

4.3The National Audit Office's observations

The National Audit Office reviewed samples of the random enquiry cases each year. Its observations included the following.

  • In 2022 to 2023, more than half (32) of the 60 cases it sampled related to claims for software and information technology R&D. Referral of technically complex cases to HMRC's internal technology experts was at the caseworker's discretion; in one case a recommended referral was not made because of capacity.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
  • HMRC had set no minimum value below which error would not be pursued, so caseworkers decided individually whether to pursue small errors. The National Audit Office said it "would expect HMRC to include all error or fraud in its estimate, irrespective of value".1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
  • HMRC applied no non-detection adjustment to large business RDEC claims, which the National Audit Office said could mean that error and fraud in that scheme was understated.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
  • In its sample for 2023 to 2024, HMRC had initially used the wrong yield figure in 6 of 56 cases, compared with 3 of 60 the year before.4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
  • In one case, HMRC received no contact from either the taxpayer or the agent; it referred the case to its Fraud Investigation Service, "and the agent is currently being investigated". HMRC told the National Audit Office that the mandatory additional information form, which includes information on agents, had increased its ability to identify suspicious claims at source.4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

For 2023 to 2024, HMRC replaced its assumption based method for large business RDEC claims with desk reviews of a stratified random sample of 108 cases, 106 of which were completed. The National Audit Office said this produced a more accurate estimate, reflected in a higher error rate for large businesses.6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

5The estimates and their revisions

5.1From first estimate to latest estimate

Each year HMRC publishes an illustrative estimate for the current year, projected from the most recent random enquiry results, and later replaces it with a final estimate once a programme covering that year has closed.4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

Year Earlier estimate Latest estimate Range for the latest estimate
2020 to 2021 3.6% (£336m), earlier method 16.7% (£1.13bn), July 2023 13.0% to 23.2%
2021 to 2022 4.9% (£469m), earlier method, July 2022 17.6% (£1.34bn), July 2024 13.8% to 23.2%
2022 to 2023 13.3% (£1.05bn), illustrative, July 2023 9.9% (£759m), July 2025 6.7% to 14.1%
2023 to 2024 7.8% (£601m), illustrative, July 2024 6.4% (£493m), July 2026 3.8% to 11.1%
2024 to 2025 5.9% (£481m), illustrative, July 2025 5.3% (£442m), July 2026 (illustrative) None published
2025 to 2026 None 5.3% (£475m), July 2026 (illustrative) None published

Figure 3. HMRC's overall estimates of error and fraud in the R&D reliefs, as a share of the estimated cost of the reliefs.2Source 2HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). The ranges are those HMRC published with each final estimate.3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). HMRC notes that later years are not directly comparable because of the merger of the schemes.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

For the SME scheme alone, the final estimates were 24.4 percent for 2020 to 2021, 25.8 percent for 2021 to 2022, 14.7 percent for 2022 to 2023 and 11.1 percent for 2023 to 2024. The illustrative estimates for the SME scheme and enhanced R&D intensive support (ERIS) are 11.0 percent for 2024 to 2025 and 2025 to 2026.4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). In July 2025 HMRC published an intermediate estimate of 6.5 percent for 2023 to 2024, before revising it to 6.4 percent in July 2026.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

5.2Why the numbers moved

Several separate things explain the revisions.

  • The method changed. The jump in the 2020 to 2021 estimate, from 3.6 to 16.7 percent, came from replacing assumptions about unreviewed claims with random enquiry results. HMRC said the programme showed that "the assumptions for the SME estimate were previously underestimating the true rate and value of error and fraud".3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).
  • Projections built in assumed effects. The illustrative estimate for 2022 to 2023 assumed that compliance interventions would reduce error and fraud by £250 million.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026). The illustrative estimate for 2023 to 2024 started from a projection of £1,045 million and deducted £444 million for "changes in the compliance environment".4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). The National Audit Office noted each time that HMRC would not know the actual effect until it completed random enquiries for that year.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
  • The basis changed to accruals. From the 2024 to 2025 accounts, HMRC estimates error and fraud by the year in which expenditure was incurred, rather than the year in which claims were received.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).
  • Claims before and after the new form were weighted. The final estimate for 2022 to 2023 weights the MREP 2 rate, for claims received before 8 August 2023, and the MREP 3 rate, for claims received after it.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).
  • The expenditure base was revised. HMRC revises its estimate of the cost of the reliefs over five years. The cost for 2022 to 2023 fell from £10.19 billion as first reported to £7.69 billion, and for 2023 to 2024 from £9.44 billion to £6.94 billion, which affects the monetary value of the estimates.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).
  • Large businesses were measured differently. The final estimate for 2023 to 2024 is the first to use the new desk review method for large business claims.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

5.3Statistical caveats

HMRC itself qualifies the trend. In its 2024 to 2025 accounts it said that the SME rate for 2022 to 2023 "is not statistically different from the rate for 2021 to 2022 of 25.8%", and that the overall rate for 2022 to 2023 was not statistically different from 2021 to 2022.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026). In its 2025 to 2026 accounts it said that the SME rate for 2023 to 2024 "is not statistically different from the rate for 2022 to 2023 and reflects natural variability in the results based on a sample of cases".5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). The illustrative estimates carry no confidence intervals.9Source 9National Audit Office, Report by the Comptroller and Auditor General on HM Revenue & Customs 2024-25 Accounts, published within HMRC's Annual Report and Accounts 2024 to 2025, Summary paragraphs 9 and 10, and Part Two, paragraphs 2.5 to 2.17, Figure 8 and paragraph 2.41. https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

The wide ranges reflect sample sizes. For 2023 to 2024, HMRC's range for the SME scheme runs from 7.4 to 15.5 percent, and for the RDEC scheme from 1.4 to 8.2 percent.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

6What the random enquiries found about claims

6.1The shape of non-compliance

HMRC's analysis of the first random enquiry programme found that around half of claims contained at least some non-compliance.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026). In 25 percent of claims no qualifying R&D activity took place, in 19 percent R&D took place but the company overclaimed, and in 2 percent there was a technical misinterpretation of the legislation.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026). Fraud indicators were found in fewer than 10 percent of claims, accounting for less than 5 percent of the value claimed, which HMRC said "indicates that the majority of non-compliance is down to other behaviours".8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026). The second programme found similar overall results: 26 percent of value non-compliant, 49 percent of claims compliant, 30 percent wholly non-compliant and 21 percent overclaimed.7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).

The first programme also showed patterns by claim.

  • Size. In claims with expenditure below £10,000, 78 percent of the value claimed was non-compliant; in claims over £1 million, 13 percent was, and around 75 percent of those claims were fully compliant.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).
  • First claims. 38 percent of the value of first time claims was non-compliant, against 22 percent for companies that had claimed before.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).
  • Sector. Non-compliance by value ranged from 9 percent in professional, scientific and technical activities to 87 percent in education.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).

6.2Agents

HMRC states that more than 90 percent of R&D claimants are represented by an agent.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026). For the random enquiry samples it assessed whether the company used a specialist R&D agent.

Programme Share of claims with a specialist R&D agent Non-compliance by value, with such an agent Without an identified agent of that kind
MREP 1 (2020 to 2021) 51% 25% 24%
MREP 2 (2021 to 2022) 54% 28% 21%

Figure 4. Non-compliance by value of claims, by whether the company used a specialist R&D agent.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).

HMRC described non-compliance in the second programme as "slightly higher in those claims that were submitted with the support of a specialist R&D agent".7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026). In the first programme the largest claims, over £500,000, showed non-compliance of 15 percent with a specialist agent and 18 percent without, while claims under £10,000 showed 90 percent and around 75 percent.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).

A separate analysis of the first programme, published with HMRC's 2024 consultation on the tax advice market, divided claims by whether the agent belonged to a professional body.11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

Representation Claims in sample Claims with non-compliance Cost of relief non-compliant
Agent affiliated to a professional body 303 49% 20%
Agent not affiliated 118 53% 53%
Affiliation unknown 41 56% 42%
No agent 38 66% 12%

Figure 5. HMRC analysis of the 500 claims in the first random enquiry programme, by agent affiliation.11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

HMRC cautioned that some groups are small, that claim size is correlated with non-compliance, and that companies with no agent tend to make higher value claims and are likely to be larger businesses able to manage their own claims.11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

None of these breakdowns divides claims by how the agent was paid. HMRC's published analyses distinguish the presence of an agent and the agent's affiliation, not the basis of the agent's fee.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

7The policy response

7.1Parliamentary scrutiny

The Committee of Public Accounts made recommendations in February 2022 on HMRC's approach to abuse of the reliefs. HMRC accepted them, and its formal response in April 2022 committed it to a cross cutting team of around 50 staff focused on abuse, digital claims with more detail endorsed by a named senior officer, customer education, analysis of the growing cost of the reliefs, and continued random enquiries.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). In 2023 the Comptroller and Auditor General recommended that HMRC consider whether the scale and focus of its compliance work were adequate, and whether to inspect more claims from before the period covered by its estimates.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

7.2The measures

Measure Applies from
Cap linked to PAYE on the size of SME claims Accounting periods from April 20217Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
R&D Anti Abuse Unit created July 20228Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).
SME additional deduction cut from 130% to 86%, SME payable credit from 14.5% to 10%, RDEC raised from 13% to 20% April 20234Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
Advance notification of claims Accounting periods from April 20237Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
Digital claims with additional information, a named company officer and the identity of any advisers Claims from 8 August 20234Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
No new assignments of R&D tax credits; payment to the company rather than to nominees Assignments from November 2023; claims from April 20247Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
Merged RDEC and enhanced R&D intensive support April 20244Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).
Online disclosure service for companies that claimed too much and can no longer amend their return Published 31 December 202412Source 12HM Revenue and Customs, Tell HMRC if you've claimed too much Research and Development (R&D) tax relief (published 31 December 2024, last updated 14 August 2026), sections "Who can use the R&D disclosure service", "When you should not use it" and "How to work out the penalties due". https://www.gov.uk/guidance/tell-hmrc-if-youve-claimed-too-much-research-and-development-rd-tax-relief (accessed 11 October 2026).

Figure 6. Measures listed by HMRC and the National Audit Office.

HMRC also increased its R&D compliance staff from around 100 in 2020 to 2021 to more than 500, and opened compliance checks on 17 percent of claims in 2023 to 2024.7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026). The National Audit Office recorded that the Finance Act 2023 rate changes were "in part, a response to the estimated level of error and fraud for the SME scheme being considerably higher than for the RDEC scheme".4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

The disclosure service lets a company tell HMRC that it claimed too much where the time limit for amending its return has passed. It may be used by a director or company secretary, or by a tax adviser on the company's behalf, but not where the company's behavior was deliberate.12Source 12HM Revenue and Customs, Tell HMRC if you've claimed too much Research and Development (R&D) tax relief (published 31 December 2024, last updated 14 August 2026), sections "Who can use the R&D disclosure service", "When you should not use it" and "How to work out the penalties due". https://www.gov.uk/guidance/tell-hmrc-if-youve-claimed-too-much-research-and-development-rd-tax-relief (accessed 11 October 2026). HMRC warns that a company "may be charged extra interest and penalties if they wait for HMRC to contact them".12Source 12HM Revenue and Customs, Tell HMRC if you've claimed too much Research and Development (R&D) tax relief (published 31 December 2024, last updated 14 August 2026), sections "Who can use the R&D disclosure service", "When you should not use it" and "How to work out the penalties due". https://www.gov.uk/guidance/tell-hmrc-if-youve-claimed-too-much-research-and-development-rd-tax-relief (accessed 11 October 2026).

7.3How HMRC connects the estimates to the measures

HMRC's 2025 to 2026 annual report says that the 2023 to 2024 rate "is lower than estimates since 2020 to 2021, reflecting legislative and operational changes to tackle error and fraud, notably the mandation of digital claims and additional information requirements introduced in 2023".5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). It attributes the lower illustrative rates for later years to the additional information form and the new ERIS and merged RDEC schemes.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). HMRC told the National Audit Office that requiring companies to provide more information "has helped reduce the number of non-compliant claims".6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

The National Audit Office said that HMRC "is beginning to see the impact of compliance and legislative changes made in recent years", that there are "currently no further changes planned", and that HMRC is reviewing recent random enquiry results "to consider whether the measures taken have gone far enough".6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). It also noted that claims by SMEs typically have a higher rate of error and fraud than claims by large businesses, and that HMRC will not know the full impact of the changes until it has completed enquiries on 2025 to 2026 returns, which it expects will most likely be reported in HMRC's 2028 to 2029 annual report.6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

8What the estimates do not show

The estimates are the most detailed public measure of claim quality in the UK reliefs, but they have limits that HMRC and the National Audit Office acknowledge, and others that follow from what is measured.

  • Lag. The most recent final estimate is for 2023 to 2024. Later figures are projections.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).
  • Attribution. Several measures took effect within a short period: rate changes, notification, the additional information form, digital claims, the payment restriction and the merged scheme. HMRC has not published a separate estimate of the effect of each.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).
  • Behavior. The headline figure combines mistakes, carelessness and fraud. HMRC's thematic analysis indicates that most non-compliance is not fraud.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
  • Agents. The analysis records whether a specialist R&D agent was used and whether an agent belonged to a professional body, but not how any agent was paid.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026). HMRC states that it "does not regulate tax agents including those who advise on R&D claims".7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).
  • Responsibility. HMRC states that a customer who uses a tax agent remains responsible for its own tax affairs.7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).

9What the record shows

HMRC's measurement of error and fraud in the R&D reliefs changed when it moved from risk based reviews to random enquiries. The earlier method assumed that unreviewed claims were cleaner than reviewed ones; the random enquiries showed that around half of SME claims in 2020 to 2021 and 2021 to 2022 contained some non-compliance, and that error and fraud was 16.7 and 17.6 percent of the cost of the reliefs in those years.3Source 3HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). The National Audit Office described the SME rate as among the highest reported across all government spending programmes.1Source 1National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).4Source 4National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).

The latest final estimate, for 2023 to 2024, is 6.4 percent, and the illustrative estimates for the next two years are 5.3 percent.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). HMRC and the National Audit Office both connect the fall mainly to the 2023 requirements for digital claims and additional information.5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).6Source 6National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026). HMRC also states that some of the year on year differences in the SME rate are not statistically significant.10Source 10HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).5Source 5HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).

The record identifies who prepared a claim, whether that person was a specialist R&D agent and, in one analysis, whether the agent belonged to a professional body. It does not record the basis on which agents were paid, and no published UK estimate relates claim quality to fee arrangements.8Source 8HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).7Source 7HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).11Source 11HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).

References

  1. National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2022-23 Accounts, Summary paragraphs 9 to 11, 17 and 18, and Part Two, paragraphs 2.1 to 2.21 and Figure 11. https://assets.publishing.service.gov.uk/media/64da2f04c8dee4000d7f1c01/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).                    Back
  2. HM Revenue and Customs, Annual Report and Accounts 2021 to 2022 (print version, July 2022), "Research and development tax relief error and fraud" (page 116) and Resource Accounts note 5.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 241 to 242). https://assets.publishing.service.gov.uk/media/639c4a30d3bf7f7f8cebfe8f/HMRC_Annual_Report_and_Accounts_2021_to_2022_Print.pdf (accessed 11 October 2026).           Back
  3. HM Revenue and Customs, Annual Report and Accounts 2022 to 2023 (July 2023), "Research and development tax reliefs" (page 23), Principal Accounting Officer's report, "Research and development tax relief error and fraud" (pages 115 to 116), and Resource Accounts note 5.1.5 (pages 256 to 257). https://assets.publishing.service.gov.uk/media/64e34f1c3309b700121c9baa/HMRC_annual_report_and_accounts_2022_to_2023.pdf (accessed 11 October 2026).          Back
  4. National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, Summary paragraphs 10 and 11, and Part Two, paragraphs 2.4 to 2.21 and Figure 7. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026).                    Back
  5. HM Revenue and Customs, Annual Report and Accounts 2025 to 2026 (July 2026), "Our accountability", Control challenges, "Corporation Tax research and development tax relief error and fraud" (page 107), and Resource Accounts note 3.1.4, "Corporation tax reliefs: R&D error and fraud" (pages 251 to 253). https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).                   Back
  6. National Audit Office, Report by the Comptroller and Auditor General on HM Revenue and Customs 2025-26 Accounts, published within HMRC's Annual Report and Accounts 2025 to 2026, Summary paragraph 11, and Part Two, paragraphs 2.8 to 2.15 and Figure 11. https://assets.publishing.service.gov.uk/media/6a4f66c406e7256c331df8a2/HMRC_annual_report_and_accounts_2025_to_2026.pdf (accessed 11 October 2026).                Back
  7. HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), Introduction, sections 1.2, 2.1 (Table 2), 2.4 and 2.5, Annex A and Annex B (Themes 1 and 5, Tables B.4 and B.5). https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026).                 Back
  8. HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (corporate report, published 17 July 2023), sections 1.2, 2.1, 2.3, 3.1 (Table 1) and 3.2 (Themes 1 to 5 and Tables 2 to 6). https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026).                  Back
  9. National Audit Office, Report by the Comptroller and Auditor General on HM Revenue & Customs 2024-25 Accounts, published within HMRC's Annual Report and Accounts 2024 to 2025, Summary paragraphs 9 and 10, and Part Two, paragraphs 2.5 to 2.17, Figure 8 and paragraph 2.41. https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).    Back
  10. HM Revenue and Customs, Annual Report and Accounts 2024 to 2025 (July 2025), "Research and Development tax reliefs" (pages 52 to 53), "Corporation Tax research and development tax relief error and fraud" (page 105), and Resource Accounts note 4.1.5, "Corporation tax reliefs: R&D error and fraud" (pages 252 to 254). https://assets.publishing.service.gov.uk/media/687e5d318adf4250705c96d8/HMRC_annual_report_and_accounts_2024_to_2025.pdf (accessed 11 October 2026).            Back
  11. HM Revenue and Customs, Raising standards in the tax advice market: strengthening the regulatory framework and improving registration (consultation, 6 March 2024), Annex C, "Analysis: non-compliance according to tax practitioner membership of professional bodies", section "Research and development tax credit". https://www.gov.uk/government/consultations/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration/raising-standards-in-the-tax-advice-market-strengthening-the-regulatory-framework-and-improving-registration (accessed 11 October 2026).       Back
  12. HM Revenue and Customs, Tell HMRC if you've claimed too much Research and Development (R&D) tax relief (published 31 December 2024, last updated 14 August 2026), sections "Who can use the R&D disclosure service", "When you should not use it" and "How to work out the penalties due". https://www.gov.uk/guidance/tell-hmrc-if-youve-claimed-too-much-research-and-development-rd-tax-relief (accessed 11 October 2026).    Back

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