R&D tax relief has become increasingly complex in recent years, particularly for businesses operating at the intersection of technology and creativity. Updated guidance published in January 2026 marks an important shift in how such projects are assessed, offering greater clarity on when creative-led work can qualify as R&D.
At the centre of this change is the revised CIRD81300, part of HMRC’s Corporate Intangibles Research and Development Manual.
Expert Input into HMRC Guidance
HMRC has now formally incorporated external technical expertise through the R&D Expert Advisory Panel. The panel brings together specialists from areas such as artificial intelligence, life sciences and advanced manufacturing, with the aim of ensuring guidance reflects how modern innovation actually takes place.
This input is already visible in the updated manual, which takes a more realistic view of interdisciplinary development, where technical advances often sit within broader commercial or creative objectives.
Role Does Not Determine Eligibility
One of the clearest messages from the revised guidance is that R&D eligibility depends on activity, not job title or sector.
The updated CIRD81300 includes examples where creative projects give rise to qualifying R&D because they involve resolving technological uncertainty. These include:
- Film production tools where new methods are developed to simulate complex cloth behaviour in real time on consumer hardware.
- Interactive mobile experiences that require advances in real-time rendering, latency reduction and power efficiency using live data.
In each case, purely aesthetic or stylistic decisions remain non-qualifying. However, where individuals with creative expertise contribute directly to solving technological problems, their work may fall within the scope of R&D tax relief.
Drawing the Boundary
The guidance also reinforces that not all work within an innovative project qualifies. Only those activities that seek an advance in science or technology through the resolution of uncertainty are eligible. The closer a project sits to this boundary, the higher the standard of evidence required.
For businesses operating in software, gaming, film, or immersive media, the revised guidance provides welcome clarity, but it also demands more careful articulation of what the R&D actually is.
Asquith Bhondi can help your business to identify qualifying activity, articulate technological advances clearly, and ensure claims accurately reflect HMRC’s criteria. Any questions? Get in touch.
