Recommendation 37

Given the range of commercial arrangements relating to R&D activity, we consider that defining ‘subcontracted R&D’ to exclude what the Government calls a ‘normal’ contract may be very challenging, if not impossible. We therefore agree that it is vital that detailed guidance on the meaning of ‘subcontracted R&D’ is made available as soon as possible. We are concerned, however, that there is insufficient time for such guidance to be developed prior to the legislation coming into force from April 2024.