A practical pre-30 June R&D activity and expenditure checklist for Australian businesses, with steps on contemporaneous records, ATO and AusIndustry
The end of the financial year is bearing down on Australian businesses, and for anyone claiming the Research and Development Tax Incentive (R&DTI) the weeks before 30 June carry a particular weight. This is not a static compliance deadline to be ticked off in the last week. The ATO, AusIndustry and Industry Innovation and Science Australia expect evidence that was created as the work happened, not reconstructed from memory.
This article is a practical, step-by-step pre-30 June checklist. It is general information only, not tax, financial or legal advice. Rules, rates and thresholds can change, and your business circumstances are unique. Always confirm your position with a registered tax agent or R&D tax specialist before lodging anything. With that understood, let's walk through what to do now to set up a defensible, well-documented claim.
Before you can make practical use of this checklist, a few building blocks should already be in place. If any are missing, use the next few weeks to close the gaps.
Pro tip: Do not wait until after 30 June to open a conversation with your tax agent. Many experienced practitioners close their books for new R&D clients in May or early June because of the sheer volume of year-end work. Book an initial eligibility review now.
The R&DTI has two core components, but remember that thresholds and rates are subject to change, so verify the current year’s figures with the business.gov.au program page or your tax agent.
Core R&D activities must be systematic, investigative and experimental, conducted for the purpose of generating new knowledge. Supporting activities are those directly related to core R&D activities. The ATO expects you to be able to distinguish between the two and to have records that support each activity’s classification.
The incentive provides a refundable tax offset for eligible entities with aggregated turnover below a stated threshold (a well-known figure, but always verify the current income year amount). Other eligible entities may receive a non-refundable offset. Any proposed changes to turnover thresholds, for example the widely discussed increase to the refundable-offset threshold, are at the time of writing proposed or announced only and should not be relied upon until enacted. Your tax agent will know the correct position for the income year you are preparing.
Use the pre-30 June period to review the official ATO checklist. It covers eligibility, registration, contemporaneous records and expenditure tracking, all from the regulator’s perspective.
Now is the moment to document, activity by activity, what your team actually did. An activity is not a project title like “new product prototype”. It is the specific experiment, trial, modelling or iterative development that generated the new knowledge.
Create a simple spreadsheet with these columns:
This is not the final format for your claim, but it is a practical working document that your registered tax agent can later shape into the formal R&D schedule. If you find gaps, you still have time to talk to your team and fill them in while memories are fresh.
Warning: The ATO regularly challenges claims where a business has described routine product development, market research or software configuration as R&D. The technical uncertainty must have existed before you started the work, and you must be able to demonstrate what you did to address it. If you cannot articulate the uncertainty, you may have a problem.
“Contemporaneous” means created at the time the work was done. The ATO expects records that show what activity was performed, when, how much it cost, and who did it. The ATO checklist and the government guide both stress this. Types of records that help:
If your records live across a mix of Microsoft 365, Google Workspace and Dropbox, you are not alone. GrantsMAX integrations connect read-only to the tools you already use, pulling the relevant evidence together without manual searching.
Pro tip: Now, before 30 June, is the cheapest time to fill gaps. Have a 15-minute stand-up with your engineering lead each week to confirm that the records are being kept. Trying to reconstruct a year’s worth of notebook entries in July will be expensive and far less credible to an ATO reviewer.
Eligible expenditure generally falls into four buckets, but always check the current legislation and ATO guidance:
Before 30 June, your accounting system should already be tracking these items. GrantsMAX for SMBs on cloud accounting explains how data from Xero, MYOB or QuickBooks can be mapped to R&D activities, giving you a clear view of what is claimable. If your current chart of accounts does not separate R&D expenditure from general operating costs, create the necessary tracking categories now so that the July-June data is complete.
Warning: Do not claim expenditure that you cannot substantiate with a time record, invoice, receipt or contract. The ATO uses data-matching to cross-reference wages, and if your R&D salary claims are not supported by timesheets or reasonable allocation methods, the claim will likely be reduced or denied. The time to fix this is not in the ATO audit room; it is before the year closes.
For each income year, you must register your R&D activities with AusIndustry within 10 months of the end of the income year. For a standard 30 June year-end, that deadline falls on 30 April of the following year. So why is this a pre-30 June task? Because registration is not a rubber stamp. The business.gov.au registration page outlines the process and warns that applications must include a comprehensive description of each core activity and any supporting activities.
If you leave the description until next April, you will be relying on faded memories and incomplete records. By drafting the activity descriptions now, while the work is fresh and you can still talk to the project team, you are essentially building your evidence base. You can hold the draft and lodge the registration closer to the deadline, but having it 80% complete before 30 June means you are not scrambling.
Note that registration is a prerequisite to claiming the R&DTI in your tax return. If you miss the deadline, you lose the ability to claim for that year, absent exceptional circumstances that AusIndustry rarely grants.
A common area of challenge is the linkage between dollars claimed and the R&D activity. The ATO wants to see a clear nexus. This is where a well-structured pack becomes essential. For every dollar of expenditure you plan to claim, you should be able to answer:
A practical way to prepare this is to use a spreadsheet that cross-references expenditure lines (from your accounting data) to activity IDs, employee names and document references. GrantsMAX for founders and CFOs shows how AI can automate much of this mapping, pulling data from your accounting and document systems and organising it into a pack that your registered tax agent can review, challenge and refine before lodgement.
Pro tip: If you have employees who split their time across R&D and non-R&D work, a timesheet that records hours against project codes is almost always the minimum the ATO will accept. Generic estimates like “about 60% of Jane’s time was R&D” are unlikely to hold up under review.
This is the step that turns a good set of records into a defensible claim. Your registered tax agent should review:
Remember the division of responsibility: the tax agent reviews, advises and lodges the claim; the business owns the claim and is responsible for its accuracy. A tool like GrantsMAX prepares the evidence-backed pack, but it does not lodge, does not guarantee an outcome, and does not replace the professional judgement of a registered agent.
While this article is focused on the R&DTI, the pre-30 June period is also a good time to look at whether your business may be eligible for other programs. The Export Market Development Grant (EMDG), administered by Austrade, has its own record-keeping and expenditure-tracking requirements. GrantsMAX for exporters and EMDG claimants explains how marketing and promotional spend aimed at winning overseas customers may be claimable under the EMDG, and how the same accounting data can be used to prepare both an R&D pack and an EMDG pack.
Other grants, such as state government innovation vouchers or the CSIRO Kickstart program, may have application deadlines that fall around mid-year. Checking now ensures you do not leave potential funding on the table.
The ATO says in its checklist for claiming R&D tax incentive that claimants must keep records for five years from the date the tax return is lodged. But the contemporaneous record expectation is effectively from the time the R&D work is performed. The practical rule of thumb is: if you do not have a record from within a few days or weeks of the activity, it is not contemporaneous.
Before 30 June, walk through your list of R&D activities and ask, for each one, “What record did we generate on the day we did the work?” If the answer is “nothing”, create a process to fix that for the remaining weeks of the financial year, and make a note to discuss with your tax agent.
An often-overlooked piece of the claim is a plain-English narrative that explains, in clear sentences, what the business was trying to achieve, what the technical uncertainty was, how the systematic experimentation occurred, and what outcomes eventuated. This is not the formal R&D schedule, but it will be the basis your tax agent uses to write it.
Use simple language. A test you can apply is: “Would my non-technical accountant (or an ATO officer) understand from this why the activity was not routine?” If it sounds like a normal project delivery description, you probably need to add more detail on the uncertainty and the experimental method.
If all of this sounds like a lot of manual work, there is a smarter way. GrantsMAX connects read-only to your Xero, MYOB, QuickBooks, Microsoft 365 and Google Workspace, identifies the grants and R&D tax incentives your business may be eligible for, and prepares a complete, evidence-backed application pack. A registered tax agent reviews and lodges the claim, and your business owns the outcome. It is a fraction of the cost of a legacy consultancy, and it means you walk into the year-end meeting with your accountant carrying a structured, defensible pack, not a shoebox of receipts.
To learn more and get early access, join the GrantsMAX waitlist today.
This article is general information only. It is not tax, financial or legal advice. Always consult a registered tax agent or professional R&D advisor about your specific situation.