CIR-CII approval — research and innovation service providers
Voluntary for the provider, decisive for its client. No rule obliges a private design office or laboratory to seek approval. But article 244 quater B of the French Tax Code makes the inclusion of subcontracted research expenditure in the client's research tax credit base conditional on the provider being approved by the minister responsible for research. Without approval, the invoice — even for indisputable R&D work — is excluded from the calculation.
Issued by: The French ministry responsible for research (MESR) for approval under the research tax credit; the ministry responsible for industry, through the Directorate General for Enterprise, for approval applied for under the innovation tax credit alone
Private research organisations — R&D companies, design offices, laboratories, deeptech start-ups, engineering firms —, individual scientific or technical experts, style bureaux and stylists for the collection tax credit, and, since 1 January 2022, public and equivalent research organisations carrying out work on behalf of businesses.
What this scheme covers
- C.1An approval that earns the provider nothing directly: it opens no tax credit for the holder. It serves the holder's clients, who can then include subcontracted research invoices in the base of their own research tax credit.
- C.2Two separate approvals for two schemes: approval under the research tax credit (CIR), handled by the research ministry, and approval under the innovation tax credit (CII), which covers the design of prototypes or pilot installations of new products for SMEs. The standalone CII procedure is for firms that do not already hold a valid CIR approval.
- C.3A duration that depends on track record and activity: three years as a rule for the CIR, cut to one year where the organisation or expert has carried out no research operation in the twelve months before the application, and up to five years for organisations approved continuously over a long period. Approval granted under the CII alone covers five years.
- C.4A public list: the ministry publishes and updates the list of approved organisations, experts, style bureaux and stylists as open data. Clients check it before contracting — appearing on that list is a verifiable selling point.
- C.5Ceilings on the client's side: expenditure entrusted to third parties counts towards the CIR base only within an overall annual limit of ten million euros, reduced to two million euros where the company and its provider are related parties. A specific, higher ceiling applies to work entrusted to public and equivalent research organisations.
- C.6What approval does not guarantee: it attests to the provider's human and material resources, not to the eligibility of each project. The tax authorities can still challenge the client's tax credit if the work invoiced does not qualify as research and development in the tax sense, approval or not.
The link with Qualiopi
CIR-CII approval is a tax approval with no connection to Qualiopi: it concerns research capability, not the quality of a training service. The costliest confusion is to assume that a training course opens a right to the research tax credit — it does not; training expenditure is not research expenditure. The bridge exists for organisations doing both: a private R&D centre that also sells continuing training to its industrial clients will need approval for its study work and Qualiopi certification to make its courses eligible for public and pooled funding. Two procedures, two authorities, two timetables: neither replaces the other.
The process, summarised
- 1.Check that the activity really qualifies as research and development in the tax sense — novelty, scientific or technical uncertainty, an experimental approach in the sense of the OECD Frascati Manual criteria — rather than routine engineering, adapting to a specification, or production.
- 2.Choose the right approval: under the CIR from the research ministry for R&D work; under the CII alone, from the industry ministry, where the company designs prototypes or pilot installations of new products for SMEs and does not already hold a valid CIR approval.
- 3.Assemble the file: presentation of the organisation and its business, human resources assigned to research (headcount, degrees, qualifications, CVs), dedicated equipment and premises, a detailed description of representative research operations, and evidence of dissemination where it exists — publications, patents, academic collaborations.
- 4.File the application online within the campaign window. For the CIR, a first application is filed between 1 January and 31 March of the year applied for, and renewal between 15 August and 30 November of the last year covered. For standalone CII approval, the reference date is 30 September. Outside the window, approval only takes effect from the following year.
- 5.Answer the requests for further information from the expert assessing the file: the application is examined on the merits by a scientist in the field, and the decision is taken by the minister. Allow several months between filing and notification.
- 6.Track the expiry date and file the renewal within its window: a gap in coverage, even of a few weeks, deprives clients of the tax credit for work carried out during the interruption. It is the most common mistake, and the hardest to put right.
FAQ — CIR-CII approval
+Does approval guarantee my client's tax credit?
No. Approval is a necessary condition, not a sufficient one. It attests that the provider has the human and material resources to conduct research work; it validates no project in advance. In an audit, the tax authorities look at the real nature of the work invoiced: if it shows neither novelty nor scientific or technical uncertainty, the expenditure is removed from the client's base despite the approval.
+Do public research organisations need approval?
Yes, since 1 January 2022. Until then, certain public and equivalent organisations were exempt and deemed approved. Now, for the client company to include the corresponding expenditure in its research tax credit, the public or equivalent organisation must also hold approval issued by the minister responsible for research.
+Does an approved provider lose its own research tax credit?
No, but it cannot count the same work twice. Article 244 quater B bars an approved organisation from including in its own base the expenditure incurred to carry out research operations entrusted to it by third parties. The Conseil d'État held, in its decision of 9 September 2020 (no. 440523, société Takima), that those provisions do not require it to deduct from its base the share of the amounts invoiced to clients. An approved organisation therefore keeps the tax credit relating to work carried out on its own account.
- Building Your CIR Approval File: What the Ministry Actually Looks At8 min
- The CIR Approval Timetable: Two Windows You Cannot Miss7 min
- CIR Approval and Qualiopi Certification: Two Recognitions Wrongly Confused7 min
- CIR or CII Approval: Which One to Apply For, and Do You Need Both?7 min
- Subcontracted R&D: Why Your Client Cannot Claim Your Invoice Without Approval7 min