CIR/CII Approval: Please note that the dates have changed!

When an innovative company outsources its research operations to a private or public entity, it may, under certain conditions, include the expenses incurred in the calculation of its CIR (Research Tax Credit) or its CII (Innovation Tax Credit).

To this end, effective January 1, 2022, all research organizations—whether public, publicly funded, or private—must hold an accreditation issued by the minister responsible for research.

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Decree No. 2021-784 of June 18, 2021, provides further details regarding CIR/CII approval applications, effective as of June 21, 2021.

What are the procedures for issuing CIR/CII approval for a subcontractor?

To obtain CIR/CII certification, the subcontracting organization must submit an application to the administration, which will then conduct a thorough review of its application (first from an administrative perspective and then from a scientific one).

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Following the decree of June 18, 2021, the procedures for the Ministry of Research to grant accreditation have changed.

In particular, with regard to the duration of approvals:

• The approval will be granted for a period of 3 years
• This period will be extended to one year if the organization applying for accreditation has not completed any research projects during the 12 months preceding the application.
• Starting with the third year of the accreditation renewal application, accreditation may be granted for a period of 5 years provided that the organization has completed a research project within the 12 months preceding the application.

Second, the decree also revises the definition of activities classified as “basic research.” Specifically, the administration defines them as scientific or technical research activities “of a fundamental nature, which, in order to make a theoretical or experimental contribution to the resolution of technical problems, contribute to the analysis of properties, structures, and physical and natural phenomena, with a view to organizing, by means of explanatory models or interpretive theories, the facts revealed by this analysis.”

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(Source: Decree 2021-784 of June 18, 2021)

Finally, unlike in previous years, effective January 1, 2022, public entities—or entities treated as public—will also be subject to the CIR/CII approval requirement so that the contracting party can benefit from the CIR, as well as to the rules for calculating eligible expenses. This means that expenses subcontracted to these public entities will be capped at three times the total amount of research expenses eligible for the CIR, just as with private entities.

CIR/CII Approval Applications: The New Timeline

There are two types of procedures for applying for CIR/CII accreditation. Either it is an initial application for accreditation—meaning the organization has never been accredited by the Ministry of Research—or it is a renewal application.

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However, the deadlines for submitting an application for CIR/CII approval have recently changed:

• For a first-time application, the application materials must be submitted between December 15 of the previous year and March 15 of the year for which the application is being made.
• For a renewal, the application must be submitted between September 1 and November 30 of the organization’s final year of accreditation.

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Example: To obtain a renewal of certification valid for 2022, a company whose certification is valid from 2019 to 2021 must submit its application for renewal between September 1 and November 30, 2021.

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As a reminder, applications for CIR/CII approval must be submitted by mail or online (via the online application process) to the Ministry of Research.

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Please note that the agency processes approximately 3,000 applications per year, and its average processing time is 6 months. To avoid backlogs and obtain your CIR/CII approval as quickly as possible, it is recommended that you do not wait until the end of the application periods to submit your application.

Learn more

Are you a public or private research organization looking to obtain CIR/CII certification? Feel free to contact us to get help from our experts in putting together your application.