An R&D report may describe an impressive project while leaving a basic question unanswered: what evidence shows that the claimed activity actually happened in the way described? A strong file connects the technical explanation to records created during the work. Reviewing that connection before lodging is usually more manageable than trying to reconstruct it when the team is responding to an examination.
Start with one activity
Choose a proposed core activity and ask someone unfamiliar with the project to follow its evidence. Can they see the problem being investigated, the proposed explanation, what was tested, the observations and the conclusion? This is an internal diagnostic exercise. The legal assessment still depends on the statutory criteria and the particular facts of the activity.
Departmental guidance emphasises records made when activities are conducted and explains that their content matters more than their format. Existing technical records can be useful if they substantiate the claim. A polished retrospective summary does not, by itself, demonstrate what was known, intended or done at the relevant time. [R2]
Connect the explanation to the record
An evidence index can be simple. For each important statement in the activity description, identify the supporting file, its date and what it shows. Avoid attaching a large archive with no explanation. A reviewer should not have to guess why a meeting note, test log or engineering ticket is relevant to a particular part of the claim.
Consider a hypothetical manufacturing trial. A photograph may show that equipment was installed, but not why a particular operating parameter was selected or what the test established. A dated test plan, measurements and evaluation could help answer those separate questions. The point is to understand what each record proves, rather than assume that more attachments necessarily mean stronger evidence.
Look for missing links
Common practical gaps include undocumented changes in the experiment, results without evaluation, and activity descriptions that do not match project terminology. Interview the people involved and preserve their explanations, but distinguish current recollection from contemporaneous evidence. If there is uncertainty, identify it. Do not create a false impression that a newly written account existed during the project.
Check the financial connection as well. The expenditure calculation should relate to the activity actually described. If the activity occupies only part of a larger project, ask how staff time, contractor charges and shared costs have been separated. Technical eligibility and expenditure substantiation require coordinated work, even though they are different questions.
Improve the next cycle
Use the review to make future record keeping easier. Decide where experiment plans, changes, observations and conclusions will be stored, and assign responsibility for maintaining the record. Keep the process proportionate to the work. A short, useful evaluation completed at the time can be more informative than a lengthy narrative assembled after everyone has forgotten the detail.
If you are uncertain whether your records support the proposed claim, Ardian Law can review the legal and technical position with your team and accountant. Call 02 8111 7700 to discuss an evidence review before lodgement or in preparation for a response.