A technical evidence guide for Canadian software teams

Document the technical work while it is happening.

Potential SR&ED work is easier to assess when the project leaves a dated, specific trail from the starting knowledge and technical uncertainty through the experiments, results, people, time, and underlying software artifacts. Build that trail into delivery, then let a qualified tax advisor and the CRA make the eligibility decisions.

The technical thread

What should a software team document for SR&ED?

CRA guidance focuses on what work was done, why it was undertaken, how the investigation proceeded, what it produced, and what evidence supports the people, dates, and expenditures. The record needs context, not a folder of disconnected tickets.

  1. Objective and starting knowledge

    State the capability the team sought and what was known at the start. Link the standards, vendor material, prior designs, prototypes, or expert review used to understand the available approaches.

  2. Scientific or technological uncertainty

    Describe the limitation in the available knowledge that made the result uncertain. Keep this separate from ordinary schedule, budget, market, or product uncertainty.

  3. Ideas and alternatives tested

    Record the proposed explanation, design, method, or approach and the alternatives considered. Explain why each test could resolve, narrow, or expose the uncertainty.

  4. Work actually performed

    Connect experiments and analyses to dated work items, commits, prototypes, configurations, test protocols, data, and observations. A feature list alone does not explain the investigation.

  5. Results and new learning

    Capture failed attempts, partial results, unexpected behaviour, decisions, and conclusions. A useful record explains what the team learned and how that changed the next step.

  6. People, time, and project boundary

    Identify who did the work, when it occurred, and how it was separated from routine engineering and commercial delivery. Keep the technical record traceable to the financial record.

Keep the boundary honest

Evidence and eligibility are different questions.

Documentation can show what happened. It cannot turn routine software work into SR&ED.

Evidence question: Can the team show the uncertainty, investigation, results, timing, people, and resources through usable records?

Eligibility question: Does the work and its purpose meet the current legal and CRA requirements for SR&ED, and which expenditures are allowable?

Keep normal product planning, feature implementation, bug fixing, migration, training, support, and commercial work visible too. A qualified advisor needs the full boundary to distinguish possible SR&ED from other delivery.

An evidence pack that follows the work

Make each artifact answer a specific question.

Use ordinary engineering and business systems where possible. Add short context and links so a reviewer can follow the project without treating every commit, ticket, or hour as qualifying work.

Examples of technical and financial records to organize during software delivery
RecordQuestion it should answerLikely ownerCadence
Technical decision recordStarting knowledge, uncertainty, alternatives, and the reason for a testEngineering leadWhen the decision is made
Work item and source historyWhat was attempted, who changed it, when it changed, and the related technical objectiveDelivery teamAs work happens
Test plan, data, and resultThe idea tested, method, conditions, result, anomalies, and conclusionEngineer or testerFor each meaningful trial
Architecture, prototype, or designSystem boundary, constraints, dependencies, and evolution of the approachEngineering leadWhen the design changes
Review and meeting notesQuestions, observed behaviour, decisions, rejected options, and follow-up workProject ownerAt reviews and decision points
Time and contractor recordsPeople, dates, hours, roles, agreements, and the basis used to connect effort to workProject and finance ownersAt least monthly
Release and component inventoryVersions, dependencies, deployment context, and software supply-chain changesEngineering ownerAt each material release

Keep the record useful beyond a claim. Design decisions, test evidence, source history, component inventories, and clear ownership also support security response, continuity, handover, and future development. The Canadian Centre for Cyber Security recommends that organizations which develop, procure, and operate software produce or request software bills of materials to understand supply-chain risk.

A delivery rhythm

Do not wait for the tax year to close.

CRA guidance emphasizes contemporaneous evidence, often meaning records generated as the work was carried out. A small recurring discipline is more reliable than asking a team to reconstruct technical decisions at year-end.

  1. Set the boundary before work starts

    Name the business owner, engineering lead, financial owner, and qualified tax advisor. Agree on the tax-year boundary, project naming, evidence location, access, and retention before records scatter.

  2. Capture the thread inside delivery

    Use the tools the team already works in. A short technical record should link the uncertainty, proposed approach, work item, source change, test, result, people, and date without asking engineers to write a tax claim.

  3. Reconcile every month

    Review possible SR&ED work with technical and financial owners. Separate routine delivery, correct missing links while the facts are current, and reconcile people, time, contractors, and costs without deciding eligibility by percentage.

  4. Prepare the claim with qualified advice

    Give the organized evidence to the qualified tax advisor. The claimant and advisor can assess the work and expenditures against current CRA rules and prepare the project description and Form T661.

Assign responsibility

Name the record owners before the first sprint.

Technical and financial records come from different people and systems. The claimant remains responsible for its claim, with engineering, finance, delivery partners, and qualified advisors contributing different evidence and judgment.

Business owner

Own the decision to explore or file a claim, provide the business and project context, approve access, and keep the company accountable for the accuracy of its records.

Engineering lead

Keep the technical thread coherent: starting knowledge, uncertainty, ideas tested, work performed, results, and the artifacts that support each part.

Delivery team

Record work and observations as they occur. Link tickets, source changes, prototypes, test data, decisions, and failed attempts instead of reconstructing them months later.

Finance or project owner

Maintain usable time, payroll, contractor, and expenditure records and reconcile them to the technical project boundaries chosen with the advisor.

Qualified tax advisor

Interpret current law and CRA guidance, assess potential eligibility and allowable expenditures, advise the claimant, and prepare or review the claim.

RSC delivery team

When engaged, RSC can maintain contemporaneous technical records and collaborate with the client and advisor. RSC does not determine eligibility, credit amounts, or tax outcomes.

Before an engagement begins, also agree who controls the repository, project history, cloud accounts, technical records, access, retention, and transition. Use the software ownership and handover guide to make those responsibilities explicit.

Research behind this guide

Primary sources reviewed October 26, 2026. CRA updated its Form T661 application and reporting pages in October 2026 and noted that Guide T4088 is being revised. Confirm the current form, guide, and advice for the claimant’s tax year before preparing a claim.

This guide is general planning information, not tax or legal advice. RSC can support contemporaneous technical documentation and collaborate with qualified tax advisors. RSC does not determine eligibility, allowable expenditures, credit amounts, or CRA outcomes.

Keep the evidence close to delivery

Make technical records part of the work.

RSC keeps senior developers close to architecture, experiments, review, and documentation, giving the client and its qualified advisor a clearer account of what the team actually did.

Discuss a software project