HMRC rules and AI-generated content: what R&D tax advisers can and can't publish

The rules don't change because AI wrote the sentence — the same principle that applies to any regulated profession applies here. What makes R&D tax specifically unusual is how recently and how hard HMRC has moved: the Additional Information Form became mandatory for every claim from 8 August 2023, and the SME and RDEC schemes merged into one for accounting periods starting on or after 1 April 2024. A firm's marketing content written before those dates is not just stale, it may describe a scheme that no longer exists.

What the market is already citing instead of price

Our own sweep shows the compliance record has become the primary marketing claim in this sector, not the fee. One firm's live paid-search copy in our data leads with “HMRC-Ready R&D Tax Claims, under 5% HMRC enquiry rate” — an enquiry-rate figure, stated ahead of price, ahead of years in business, ahead of everything else in the ad. That is a direct market response to HMRC's own increased scrutiny, and it means any AI-drafted content for this sector that omits a compliance-credibility claim is competing with one hand behind its back.

The specific claims our sweep found doing the work

Every recommending sentence we found ties the pick to something checkable, HMRC-adjacent and specific — never a general trust statement.

• Sign-off process. RCK Partners won a compliance-record question specifically for “that extra lawyer-reviewed sign-off layer” — a stated process, not a claim of general rigour.
• Technical credibility tied to enquiry risk. Kene Partners was recommended for a biotech claim because “PhD-level technical understanding combined with tax expertise reduces the risk of HMRC challenging the science behind your claim” — the compliance benefit was stated as the direct reason.
• A quantified enquiry rate. The “under 5% HMRC enquiry rate” claim quoted above is a real, specific number an engine — and a buyer — can hold a firm to.

“There's a difference between showing up and being recommended. AI cannot recommend what it doesn't know.”

What to actually do about it

• Audit every page mentioning the SME scheme, RDEC or the claim process for whether it reflects the merged scheme rules that apply from April 2024. AI tools trained on older data will happily regenerate the pre-merger framing unless corrected.
• State your Additional Information Form process plainly. It's been mandatory since August 2023 — describing your claims process without mentioning it now reads as either out of date or thin.
• Publish a real enquiry-rate or compliance figure if you can substantiate it. Our data shows this is already the differentiator the market is marketing on.
• Treat AI-drafted technical or compliance copy the same as any other regulated content: a named person checks it against current HMRC guidance before it publishes, every time — the rules move fast enough here that a stale draft is a real risk, not a hypothetical one.