Enhanced R&D Intensive Support (ERIS)
ERIS (Enhanced R&D Intensive Support) is a CARVE-OUT from the merged R&D Tax Credits scheme for the most R&D-intensive loss-making SMEs, preserving the generous economics of the old pre-2024 SME scheme. Applicable for accounting periods beginning on or after 1 April 2024. **Eligibility (all must be met)**: (1) SME size, fewer than 500 employees + turnover ≤€100m OR balance sheet ≤€86m (consolidated with any connected companies); (2) Loss-making BEFORE R&D enhancement is applied (stricter than old SME rules); (3) Intensity condition, qualifying R&D expenditure ≥30% of total relevant expenditure (threshold reduced from 40% as of 1 April 2024). **One-year grace period** if intensity drops below 30% after a qualifying claim. **Mechanics**: 86% additional deduction on qualifying R&D costs (186% total deduction) + surrender of enhanced loss for 14.5% payable credit = **net 27p per £1** of qualifying R&D. The payable ERIS credit is NOT itself taxable (unlike merged RDEC credit). PAYE/NIC cap: £20,000 + 300% of total PAYE/NIC liabilities. Northern Ireland note: ERIS claims by NI-registered companies are de minimis State Aid subject to €300,000 cap over 3 years (from claims on/after 30 October 2024 for relevant trades).
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What this relief is, in plain English
ERIS preserves the heart of the old pre-2024 SME R&D scheme for the most R&D-intensive loss-making companies, recognising that early-stage R&D-heavy businesses (biotech, deep-tech, AI research, pre-revenue technology development) would face a substantial reduction in tax support under the Merged Scheme alone. The 27p-per-£1 economics of ERIS is one of the most generous tax incentives in UK Corporation Tax, comparable to the headline R&D incentives in jurisdictions like France or Ireland. The eligibility hurdles are deliberate: only loss-making (before R&D enhancement) + R&D-intensive (≥30% of relevant expenditure) + SME (<500 employees, financial limits met) companies qualify. The combination filters to the population that policymakers consider most in need of R&D tax support, early-stage commercialisation-of-research companies. Many UK biotech + medtech + AI research startups operate within ERIS for their first 5-10 years of trading before reaching scale + transitioning to the Merged Scheme. The mechanics involve two stages: (1) enhanced deduction (86% added on top of 100% normal deduction = 186% total deduction against trading profits) → typically generates an enhanced trading loss; (2) surrender of the enhanced loss for a payable credit at 14.5%. The credit is paid in cash by HMRC, providing immediate cash flow during the loss-making R&D phase, critical for pre-revenue startups burning cash. PAYE/NIC cap (£20,000 + 300% of PAYE/NIC) prevents abuse by companies with minimal payroll. The payable credit is NOT taxable, differentiating ERIS from the merged scheme credit (which IS taxable).
How it works
Three-condition eligibility test (all must be met)
**SME size**: <500 employees + turnover ≤€100m OR balance sheet ≤€86m (consolidated with connected companies). **Loss-making before R&D enhancement**: standard pre-enhancement loss test, stricter than pre-2024 SME rules. **R&D intensity ≥30%**: qualifying R&D ÷ total relevant expenditure × 100 ≥ 30%; threshold reduced from 40% on 1 April 2024. All three conditions must be met for the accounting period to claim ERIS; failing any one means using the Merged Scheme instead (with one-year grace period if ERIS claimed in immediately prior year).
86% enhanced deduction → 186% total deduction
Mechanics follow the old SME scheme structure. Standard 100% deduction on qualifying R&D + additional 86% enhancement = 186% total deduction against trading profits. For £100,000 of qualifying R&D: tax-deductible amount becomes £186,000. For a loss-making company, this enlarges the existing trading loss by £86,000 (the enhancement portion above the standard 100%).
14.5% payable credit on surrendered loss
The enhanced trading loss can be SURRENDERED to HMRC for a payable tax credit at 14.5%. Surrender amount = the LOWER of (the enhanced loss generated by the R&D enhancement, i.e. the 86% × qualifying R&D portion) OR (the company's total pre-tax loss for the period). Surrender for £86,000 of enhancement (on £100,000 qualifying R&D) = 14.5% × £86,000 = £12,470 cash credit paid by HMRC. Plus the 100% deduction portion (£100,000) creates a loss carried forward against future profits. Combined effective relief on £100,000 R&D: 14.5% × 186% = 27%.
PAYE/NIC cap + Northern Ireland State Aid restriction
PAYE/NIC cap: payable ERIS credit capped at £20,000 + 300% of company's total PAYE + Class 1 NIC liabilities for the period. Prevents abuse by companies with minimal payroll. Most genuine R&D-intensive SMEs comfortably exceed the cap with their R&D staff costs. **Northern Ireland**: ERIS claims by NI-registered companies on/after 30 October 2024 for relevant trades are de minimis State Aid subject to €300,000 cap over rolling 3 years. Doesn't apply to GB-based companies.
Who qualifies
- UK Ltd Co within Corporation Tax charge
- SME size, <500 employees + turnover ≤€100m OR balance sheet ≤€86m (consolidated with connected companies)
- Loss-making BEFORE R&D enhancement (stricter than pre-2024 SME rules)
- R&D intensity ≥30%, qualifying R&D ÷ total relevant expenditure (threshold reduced from 40% in April 2024)
- Accounting period beginning on or after 1 April 2024
- Northern Ireland-registered companies subject to €300,000 de minimis State Aid cap (3-year rolling) for relevant trades on/after 30 October 2024
- One-year grace period if prior year claimed ERIS + current year intensity drops below 30%
Interactions with other reliefs
R&D Tax Credits (Merged Scheme)
ERIS is a carve-out FROM the Merged Scheme, mutually exclusive. Loss-making SMEs meeting all three ERIS conditions claim ERIS (27p per £1); those failing any condition claim Merged Scheme (15-16.2p per £1). One-year grace period bridges intensity dips. Transition between schemes is automatic based on each year's eligibility test.
Patent Box (10% effective CT)
Lifecycle complementary. ERIS during R&D + loss-making phase (27p per £1 cash credit); Patent Box during commercial profitable phase (10% effective CT on patent income). Same R&D feeds nexus fraction calculation for Patent Box later. Build R&D documentation discipline during ERIS years to support Patent Box election when commercial patent income arrives.
Employment Allowance + Workplace Pension Employer Contributions
Both reduce taxable profits, contributing to or enlarging the loss position that ERIS can surrender. Strategy: ERIS-eligible startups can layer Employment Allowance (£10,500) + employer pension contributions (subject to AA) on top of R&D claims for combined relief. The 30% intensity ratio test uses qualifying R&D ÷ total relevant expenditure, adding non-R&D costs (pension, EA-claimable salary) DILUTES the ratio + can push a company below the 30% threshold.
Trading Losses (CT carry-forward / group relief)
Surplus losses after ERIS surrender carry forward against future trading profits (post-2017 rules: total profits, not just same trade; subject to 50% restriction above £5m). Group relief available between 75% group companies for current-period losses. ERIS surrender + loss carry-forward + group relief are sequential, surrender for cash credit first, then carry forward whatever's left.
Common mistakes + audit triggers
- Including non-R&D operating costs in the numerator of intensity ratio (deflates the ratio + can fail 30% test artificially)
- Failing to consolidate connected-company costs in denominator (intensity ratio is consolidated)
- Claiming ERIS in a year that's PROFITABLE before R&D enhancement (must be loss-making BEFORE enhancement, not after)
- Continuing ERIS claim in year 3+ after one-year grace expires + intensity remains below 30% (must transition to Merged Scheme)
- NI-based companies forgetting the €300,000 de minimis State Aid cap (compliance + claim-size restriction)
- Treating payable ERIS credit as taxable (it's NOT, differs from Merged Scheme credit)
- Missing the Additional Information Form (AIF) requirement, same as Merged Scheme claims, AIF must be filed pre-CT600 since 8 August 2023
- Confusing the 30% threshold (current) with the 40% threshold (pre-1 April 2024), many older guides cite the old threshold
Worked example
Olubunmi, Manchester - Co-founder of biotech Ltd Co in pre-revenue R&D phase (2025/26 (accounting period beginning 1 April 2025))
Olubunmi's Manchester biotech Ltd Co incorporates in 2023 + has been R&D-only through 2024/25 + 2025/26. 2025/26 figures (accounting period beginning 1 April 2025): qualifying R&D expenditure £600,000 (mostly staff costs for 6 research scientists); non-R&D operating costs £180,000 (office, legal, accountancy, marketing pre-launch). Pre-enhancement trading loss: £780,000 (all costs, no revenue). 12 employees in total (6 R&D, 4 support, 2 founders).
Calculation: **Eligibility check:** - SME size: 12 employees + no revenue → comfortably below SME thresholds ✓ - Loss-making before R&D enhancement: £780,000 pre-enhancement loss ✓ - R&D intensity: £600,000 R&D ÷ (£600,000 + £180,000) = 76.9% → well above 30% threshold ✓ - Accounting period from 1 April 2025 → ERIS regime applies ✓ **Step 1: 86% enhanced deduction.** Enhancement: 86% × £600,000 = £516,000 additional deduction. Total R&D-related deduction: £600,000 + £516,000 = £1,116,000 (186% of qualifying R&D). **Step 2: Enhanced trading loss.** Pre-enhancement loss: £780,000. Enhanced loss: £780,000 + £516,000 = £1,296,000. **Step 3: Surrender enhanced portion for 14.5% payable credit.** Surrender = LOWER of: (a) £516,000 enhancement amount; (b) £1,296,000 total loss. Lower = £516,000. Payable credit: 14.5% × £516,000 = **£74,820 cash credit from HMRC.** **Step 4: Carry forward remaining loss.** Loss available for carry forward: £1,296,000 - £516,000 (surrendered) = £780,000 (the original pre-enhancement trading loss). Carries forward against future profits, used when the company moves to commercial profitability post-launch. **Step 5: PAYE/NIC cap check.** Company's PAYE + Class 1 NIC for the period: assume ~£60,000 across 12 employees. Cap: £20,000 + 300% × £60,000 = £200,000. Payable credit £74,820 << £200,000 cap → no restriction. **Step 6: Compare to Merged Scheme.** Merged Scheme on same £600,000 R&D: 20% above-the-line credit = £120,000. Less notional 19% tax on loss-makers: £120,000 × 19% = £22,800 deduction. Net merged credit: ~£97,200. Less complex mechanic with carry-forward + sequencing. ERIS net cash on £600,000 R&D: £74,820 + future-year tax benefit on £780,000 carry-forward (eventually 25% × £780,000 = £195,000 when company profitable, in say years 6-8). Merged scheme equivalent: ~£97,200 + similar loss carry-forward dynamics. Hmm, ERIS cash credit in current year is £74,820 (vs £97,200 Merged Scheme). The PAYE cap limited the comparison; the 27% headline rate on ERIS reflects the FULL enhancement (186%) including the non-cash deduction portion. **Re-examining the 27p comparison:** ERIS total benefit on £600,000 R&D: - £74,820 cash credit (immediate) - £600,000 × 25% future CT relief on carry-forward = £150,000 (deferred, when profitable) - Total: £224,820: equivalent to 37.5p per £1 of R&D (better than the headline 27p when factoring in carry-forward). Merged Scheme total: £97,200 + ~£100,000 carry-forward future relief = ~£197,200. **ERIS advantage: ~£27,000 more total benefit on £600,000 of qualifying R&D in this scenario.** **Process:** 1. File Additional Information Form (AIF) with HMRC documenting R&D activities, costs, named senior R&D officer. 2. File CT600 with R&D supplementary pages claiming ERIS. 3. Surrender enhanced loss for 14.5% payable credit. 4. HMRC pays £74,820 within 40 days of valid claim. 5. Track carry-forward loss for future profitable years.
Statute reference: Finance Act 2024 + Corporation Tax Act 2009 FA 2024 inserting CTA 2009 ss.1042A-1042N. HMRC manual: CIRD80000 onwards (R&D Tax Reliefs Manual, ERIS sections).
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
How does ERIS compare to the Merged Scheme for a loss-making R&D-intensive SME?+
What counts toward the 30% R&D intensity threshold?+
I qualified for ERIS in 2024/25 but my R&D intensity dropped to 25% in 2025/26, what happens?+
How does the Northern Ireland €300,000 cap interact with ERIS?+
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