SR&ED for AI and Machine Learning Companies
AI projects are fundamentally experimental — and that's exactly what CRA looks for. If your team is training models, tuning architectures, or solving inference problems that existing frameworks can't handle, you likely have a strong SR&ED claim. Here's what to document and how to avoid the most common mistakes.
Why AI work commonly qualifies
Machine learning is inherently iterative and uncertain. Choosing a model architecture, selecting training data, tuning hyperparameters, and optimizing inference pipelines all involve genuine technological uncertainty. CRA has consistently recognized that AI/ML development involving systematic investigation of technical unknowns is SR&ED-eligible.
AI and ML work that typically qualifies
- Model architecture research where standard architectures fail to meet accuracy, latency, or compute constraints for a specific domain
- Training data investigation — determining what data characteristics, augmentation strategies, or labelling approaches are required
- Inference optimization on constrained hardware where existing frameworks don't meet latency or memory requirements
- Novel loss function or training objective design for tasks where standard losses are insufficient
- Multi-modal learning and sensor fusion where temporal alignment or cross-modal integration required original investigation
- Uncertainty quantification or calibration in high-stakes applications where model confidence was not achievable with standard techniques
- Federated learning or privacy-preserving ML where novel protocol design was required
AI work that is less likely to qualify
- Fine-tuning pre-trained foundation models on new data using standard procedures
- Deploying existing models into production using documented frameworks
- Standard prompt engineering and LLM integration work
- Running experiments where the approach is fully documented and the uncertainty is operational, not technical
- Purchasing and integrating third-party AI APIs without original model development
AI SR&ED evidence examples
AI projects generate a lot of evidence. The key is organizing it so CRA reviewers can follow the narrative from uncertainty to systematic investigation to advancement.
- Training run logs with loss curves, accuracy metrics, and configuration snapshots
- Benchmark results comparing model variants against baselines and target metrics
- Hyperparameter search records (Weights & Biases, MLflow, TensorBoard exports)
- Architecture decision documents explaining why specific model choices were made and what alternatives were rejected
- GPU/compute usage records as evidence of systematic experimental activity
- Dataset version control and documentation of data preprocessing investigations
- Code commits showing iterative model development, ablation studies, and experimental branches
Common AI SR&ED documentation mistakes
- Claiming all model work as SR&ED without distinguishing routine fine-tuning from genuine uncertainty
- Using production performance metrics as evidence without showing the experimental process that achieved them
- Missing records of failed experiments — which are essential for demonstrating systematic investigation
- Describing business outcomes (e.g., 'improved conversion') instead of technical advancement
- Failing to document why standard approaches were insufficient for the specific problem
How sredy.io helps AI teams
sredy.io translates your AI research into CRA-ready T661 narratives. The platform structures your project descriptions around technical uncertainty, systematic investigation, and advancement — and helps your accountant file with confidence.
Documenting AI SR&ED work
AI and ML work often generates excellent evidence — the challenge is organizing it in a way CRA can follow:
- Training run logs with loss curves, accuracy metrics, and configuration details
- Benchmark results comparing model variants against baseline and target metrics
- Hyperparameter search records (W&B, MLflow, TensorBoard logs)
- Architecture decision documents — why specific choices were made and what alternatives were rejected
- GPU/compute usage records as evidence of systematic experimental activity
- Dataset version control and documentation of data preprocessing investigations
Common questions
Does fine-tuning a foundation model like GPT or LLaMA qualify?
Standard fine-tuning on new data using documented procedures generally doesn't qualify. However, if fine-tuning required resolving genuine technical challenges — custom training loops, novel data preprocessing, or overcoming well-documented failure modes — that specific investigative work may be eligible.
Can cloud GPU and compute costs be claimed?
Lease costs for equipment used primarily in SR&ED — including cloud compute used directly in qualifying experiments — can be claimed. The compute must be directly tied to SR&ED work.
Is prompt engineering eligible for SR&ED?
Routine prompt engineering and LLM integration work generally does not qualify. If your team systematically investigated novel prompting architectures or approaches where no documented solution existed, that work may meet the threshold.
Related SR&ED guides
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