Ireland's R&D tax credit can help your business recover up to 35% of qualifying research and development expenditure. But before you can make a claim, there's one step that trips up more companies than you'd think: the pre-filing notification.
Miss it, and you won't be able to claim for that accounting period at all, regardless of how much qualifying R&D you've done.
What Is the Pre-Filing Notification?
The pre-filing notification (PFN) gives Revenue advance visibility that an R&D tax credit claim is coming. It's not the claim itself, as it doesn't include your final figures or technical documentation, but it opens the door for your actual submission later on.
Revenue introduced the requirement to help them allocate compliance resources and reduce last-minute, unsubstantiated claims entering the system. In practice, it means you need to be thinking about your R&D claim a few months earlier than you might assume.
Do You Need to Submit One?
Not every company needs to submit a PFN. The requirement applies in two specific situations:
- You're claiming R&D tax credits for the first time, or
- You've claimed before but haven't made a claim in the last three accounting periods
If either of those applies to you, a PFN is mandatory. But any company can also submit one voluntarily, even if not required.
When Does It Need to Be Submitted?
The PFN must reach Revenue at least 90 days before you file your R&D tax credit claim. There's no discretion on this; Revenue won't grant extensions.
The R&D tax credit deadline is one year after the end of your accounting period. If you're planning to leave your claim until close to that deadline, you need to work backwards from it.
Here's what that looks like in practice:
A software company has an accounting period running from 1 January 2025 to 31 December 2025. They leave their claim until the deadline, which is 31 December 2026. That means the PFN must be submitted no later than 2 October 2026, which is 90 days before.
If the same company planned to submit its claim earlier, say on 31 March 2026, the PFN deadline would fall to 31 December 2025.
The safest approach is to submit your PFN as early as possible. It doesn't commit you to making a claim; you can always decide not to proceed. But it keeps your options open.
What Information Do You Need to Include?
The PFN is submitted via MyEnquiries on ROS (Revenue Online Service), using Revenue's notification template. A letter that doesn't follow the template may not be accepted, so don't improvise on the format.
The information you'll need to gather includes:
- Your company name and tax reference number
- The accounting period for which you intend to claim
- The number of R&D projects expected
- The number of employees working on R&D at the time of submission
- Any grant-funded expenditure
- A brief description of your R&D activities (or planned R&D activities)
- Contact details for correspondence
You don't need precise figures at this stage. That said, if your claim value or the nature of your R&D activities changes significantly from what you outlined in the PFN, be prepared to explain those changes if Revenue questions them.
If you're including capitalised R&D expenditure in your claim, you'll need to submit a separate PFN for that element. The additional information required includes confirmation that the building or structure qualifies, the proportion used for R&D over a four-year period, and details of any related grant funding.
What Happens If You Miss the Deadline?
Revenue has been clear on this: no PFN means no claim. If you miss the deadline, you lose your entire R&D tax credit entitlement for that accounting period, regardless of how innovative it was.
Beyond losing the credit itself, a missed PFN can disrupt cash flow if you'd factored the refund into your financial planning, and it may attract greater scrutiny on future claims.
This is a high-risk area. You should have a process in place to make sure it never happens to you.
How to Stay on Top of Your PFN
The businesses that never miss a PFN deadline have built the requirement into their annual planning rather than treating it as a last-minute administrative task.
A few things that help:
- Calendar the deadlines. Mark your accounting period end dates and set reminders well in advance of the 90-day cutoff.
- Assign responsibility. Make sure someone specific owns the PFN submission, with a backup in place.
- Integrate it with your R&D planning. If you're reviewing R&D projects at the start of the year, that's a good moment to check whether a PFN is required.
- Keep records. Retain confirmation of every PFN submission, including proof of delivery.
Working with an experienced R&D tax adviser removes the risk entirely. A good adviser will manage PFN requirements as part of your broader R&D claim, so nothing slips. At Tax Cloud, this is one of the first questions we ask when you start your claim with us.
Key Takeaways
- A PFN is required if you're claiming R&D tax credits for the first time, or if you haven't claimed in the last three accounting periods. Any company can submit one voluntarily.
- The PFN must be submitted at least 90 days before you file your claim. There are no extensions, no exceptions.
- Missing the deadline means losing your entire R&D credit for that period, regardless of how much qualifying R&D you've carried out.
- Submit early. Sending a PFN doesn't obligate you to claim, it only keeps your options open.
- If you're claiming on capitalised expenditure, you'll need a separate PFN for that element.
If you'd like help managing your PFN requirements or putting together your R&D tax credit claim, get in touch and we'll walk you through it.
