SR & ED Technical Documentation: Reconciling Reality and Hypotheses

In a technical audit, sufficient evidence can make all the difference between the success and failure of a claim.

CRA Research and Technology Advisors (RTAs) expect you to manage your SR & ED projects in parallel with your client projects. Consequently, the requirement is to keep contemporary, dated, signed and specific records of the SR & ED work carried out.

In practice, very few development managers go beyond documenting the activities leading to the delivery of a technology solution to their client. During a technical audit, some RTAs use the repeated mention of the name of clients in the documents provided to consider that it is not evidence of SR & ED experimentation but rather the normal delivery of a project. customer.

How to reconcile the reality of development work with the requirements of the CRA? Here we distinguish two types of justification: the development project, often carried out in part for a client, and the experimental SR & ED project, especially carried out in the minds of the designers of the technology.

1- Justification of development work

In Appendix 2 of T4088, the CRA identifies in a table “Examples of Evidence Supporting SR & ED”:

• Project planning documents
• Resource Allocation Records, Timesheets
• Experimental plans
• Design documents, computer-aided design (CAD) and technical drawings
• Project records, laboratory notebooks
• Design, system architecture and source code (software development)
• Test registers
• Project progress reports
• Project meeting reports
• Test protocols, test data, test results
• Analysis of test results, conclusions
• Final project report or professional publications
• Photographs and videos
• Prototypes, samples
• Destroyed materials, material disposal records
• Contracts and invoices

All these documents are typical of a conventional development project. The problem is that they are normally produced as part of a client project. Nothing links this work to the objectives, uncertainties and technological advancements requested in Form T661. So what is missing to prove the experimental work?

2- Justification of the experimental work: document the SR & ED hypotheses

Oddly none of the documents listed above and in Table 1 of Annex 2 of Guide T4088, is related to the column: “Work done: experimentation, analysis, support work, progress ” which corresponds to the line 244 of Form T-661. Why ?

The answer is the record of the hypotheses that is defined in the description of the fifth question to determine if work meets the definition of SR&ED :

“[The CRA] expects the work to be recorded in a way that clearly indicates the purpose of their key elements and how they fit into the overall project. The indicators or measures that will be used to determine if the project objectives are being achieved should be identified and documented at the beginning of the work. (Eligibility policy 2.1.5)

Therefore, the CRA expects us to have both development project tracking information and monitoring information from the claimed experimental process.

Two important remarks remain despite this definition:

2.1 It is necessary to document the acquisition of knowledge

The record of the hypotheses is the only place where the acquisition of knowledge can be linked to activities, uncertainties and technological advancements. It is therefore a key document to support your technical claim.

Note: the quality prevails on the quantity. What we demonstrate here is the acquisition of knowledge rather than the generation of a mass of more or less relevant information.

2.2 Hypothesis = choice

Nobody uses the word hypothesis in daily exchanges between members of the development team. However, the CRA requires “a record of verified assumptions and results retained during the course of the work”.

First, in a real project of technological development, the issue of hypotheses to resolve uncertainty is an exercise that happens between the two ears of those who conduct the work. It is therefore necessary to explain, verbalize and write the hypotheses raised, even if they were rejected even before formally testing them.

In addition, the word “hypothesis” is certainly far from the reality of engineers and solution designers. It would be clearer to use the term “option” or “choice”.

Basically, what the CRA is looking for is a record of the uncertainties encountered, the choices considered, the tests carried out, the results obtained, as well as the knowledge that we drew from them.

3- Conclusion

In conclusion, let us remember that for the CRA, we claim a systematic experimental process, where the progress of the work is done by an analysis of the results step by step. In this context, to use the results of the tests, we must record, write, note, the experimental work and analysis that will one day lead us to solve the technological uncertainties and to better understand the scientific or technological relations (also called scientific or technological advancement).

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