Updated R&D Tax Incentive Application Form — Link R&D Advisory

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The Updated 2025 R&D Tax Incentive Application Form: What You Need to Know

A new chapter after four years of the same form.
From August 2025 onwards, the R&D Tax Incentive application form has changed. Not cosmetically or in the online input structure through the portal, but instead in the quesitons asked and the order in which they are presented. Despite some early signals, offical guidance from DISR prior to the release on 15 August was quite broad. Now, the industry is catching up. While updates were expected, the scope and tone of the new form caught many off guard. Importantly, the legislation behind the R&D Tax Incentive remains unchanged.

At Link R&D Advisory, we’ve broken down the key updates, what they mean for your claim process, and how companies can move forward with confidence.

What has changed.
Since the launch of the online portal for 2021 year claims (replacing the older PDF form), there have been known gaps between the questions asked and what’s required by legislation. This often led to confusion during reviews when issues were raised that hadn’t been covered in the application. Additionally, 1,000-character text boxes left little room for properly describing technical activities. The updated form now addresses these issues with expanded text fields, more structured disclosures, and an emphasis on contemporaneous records and proper self-assessment.

Below is a factual summary of changes across the different sections.

General additions to the form.
New company overview questions on the number of independent contractors engaged in R&D, the company’s most recntly completed income year, and total R&D expenditure for that year.
Increased charater limits across all sections. Usually from 1,000 to 4,000 characters.
Introduction of minimum character requirements for some fields.
Tighter alignment with the Advance Findings form style, particularly around future planning.

The R&D project section of the form.
Must disclose how much the R&D Tax Incentive influenced the decision to undertake the project.
Must describe your documentaiton practices. So, what records have been or will be kept.
Provide details about:
Whether the R&D was performed at your main business address.
The address where the majority of R&D was undertaken and R&D site.
Plant and facilities involved.
New declarations are required confirming whether the company:
Owns the IP or know-how.
Directs and controls the R&D.
Bears the financial risk.

These areas have long been focal points during reviews by DISR and the ATO, but are now explicitly built into the application process. This is a helpful step for businesses unfamiliar with those requirements.

The core R&D activities section.
Must confirm if you’re re-registering a previously lodged activity.
Activity descriptions are now consolidated into a single 4,000 character field.
Neew disclosures include:
The name of the entity performing the activity and the relationship to your business.
Whether the activity is conducted under a consolidated orMEC group (and ABN).
Whether the activity is covered by a legislative determination.
Key questions are now split more clearly between:
What sources were investigated and what was found.
Why the outcome couldn’t be known in advanced by a competent professional.
New expenditure fields include past, current, and future anticipated costs.
Tick-box options for evidence kept have been expanded.

While not new requirements in substance, these areas now need to be directly addressed upfront, giving companies a better sense of what needs to be proven if reviewed.

The supporting R&D activities section.
Supporting activities now have a 4,000 character limit for the detailed explanation and explanation of how it directly supports the core. These items were previously covered but only to a 1,000 character limit.
Must declare:
The entity performing the work and relationship to the applicant.
That the activity was undertaken for the dominant purpose of supporting the core R&D activity.
What evidence was kept to support the claim.

In the past, supporting activities were often underserviced in the form, despite being tied to significant expenditure. These updates are a meaningful improvement.

The implications of change.
Yes, the form is longer, and more structured. But the responsibility for this level of detail has always been in place, and now it’s more visable.

The form changes reframe compliance expectations. In particular:

Companies must clearly explain why the R&D was done and what happened.
There’s a stronger emphasis on control, planning, and evidence.
The form encourages forward planning, not just retrospective description.

For advisors, this means providing continued and direct legislation advice. For claiments, it means greater awareness of what’s required.

How to respond.
To keep it simple:

Plan ahead. Look at the 2026 year as an opportunity to improve internal documentation processes, including structured records and experimental logs.
Update your templates and internal processes. Especially around internal write ups, costing methods and evidence tracking.
Engage your advisor early.

At Link R&D Advisory, we’re continually working with clients build knowledge base and systems. We are also consitently update internal templates and guidance packs. If you’d like to talk through how the new form may affect your claim, please get in touch, we are here to help.

Key offical resources.

DISR: Apply to register with the R&D Tax Incentive

DISR: Guidance for applicants