Updated R&D Tax Application Form
A significantly updated version of the R&D Tax Incentive (R&DTI) application form was officially released on 15 August 2025. The new form is now available (and is mandatory) when you are seeking to register your R&D activities via the R&DTI portal for FY25 and beyond.
It is important to note that the eligibility criteria for the program have not changed. However, the ways in which information about the R&D activities that a business has been undertaking now need to be provided in a new format and with more detail. Further information regarding these changes and the rationale behind them are provided below.
Why has the form been updated?
The Department of Industry, Science and Resources (DISR), which oversees the R&DTI, has stated that the changes to the R&D application form will make it easier to identify key information and assess eligibility for the program. Many of the requests for additional information follow the types of key questions that we have seen asked in recent DISR & ATO reviews. They also appear to align more closely to the scope of information required in Advanced and Overseas R&D Findings.
The changes are being touted as an opportunity for companies to better align their applications with the legislative requirements of the program and provide DISR with the information needed to make a clear assessment of eligibility without initiating a review. The impact on businesses seeking to apply for the R&DTI, however, will be to add time and effort to the process of registering their R&D activities.
What are the key changes?
In the new application form, DISR has:
Increased the character limits for several sections (from 1,000 to 4,000 characters) – This suggests that DISR is seeking more detailed responses and fuller explanations for some areas of eligibility.
Expanded the unknown outcomes section into two separate questions – This indicates a stronger focus on ensuring that applicants can demonstrate the unknown outcomes associated with their work, and the steps taken up front to determine the state of existing knowledge.
Included questions asking applicants to describe the evidence and documentation they keep/plan to keep for their R&D activities – This reflects an increased emphasis on contemporaneous record-keeping. DISR is continuing to signal that inadequate documentation will raise compliance risks.
Included questions to help ensure that R&D activities are being conducted ‘on own behalf’ (Taxpayer Alerts TA 2023/4 and TA 2023/5) – This reinforces scrutiny on intercompany and contractual arrangements. Applicants will need to show that they bear financial risk, control the project, and own or retain rights to results.
Clarified the supporting activity dominant purpose test requirements – This seems to suggest that DISR wants clearer demonstration that the activity’s purpose is to support core R&D, rather than production or business operations.
Asked applicants to describe the plants and facilities used for their R&D – This question already appears in Finding applications, and its inclusion here likely reflects DISR’s intent to gain a fuller understanding of how R&D is conducted by claimants.
What do you do now?
Your next steps are very much dependent on the status of your R&D tax claim for FY25:
Any draft R&D applications that were in the portal before the update, but which had not been submitted by 15 August, will now have been deleted and must be restarted in the new form.
Businesses that submitted their FY25 R&D application submission prior to the rollover are not immediately affected and there is no requirement to resubmit using the new format for FY25. However, going forward you will need to use the new application form.
Businesses that have not yet prepared their FY25 R&DTI application form will need to use the new format for their submission. As a reminder, business have up until 10 months after the end of financial year to submit their R&D application form (i.e. up until 30 April for 30 June year end businesses). We recommend reviewing the new application form as soon as possible to ensure you can provide the additional information required to demonstrate eligibility of your R&D activities.
Finally, the continued emphasis on documentation makes it clear that good record-keeping continues to be central to how R&DTI applications will be assessed and will remain a critical item for ensuring compliance with the regulators. Addressing this upfront will put you in the best position when completing the new form and in the event that your claim is ever reviewed
Please reach out to our expert team at Intellect Labs if you’d like further information on the new R&D application form, or if you need specialist advice on how to improve your record-keeping and R&D project management processes going forward.