SR&ED Evidence Retention: CRA Requirements and How to Automate It (2026)

The best practice for SR&ED evidence retention is to maintain contemporaneous records that prove three things: a technological advancement was attempted, a technological uncertainty existed, and a systematic investigation was conducted to resolve it. GrantOps creates this evidence trail automatically by reading your existing developer tools, including GitHub, Jira, and Slack, in real time, so every commit, ticket, and technical discussion becomes a timestamped, audit-ready record without any extra effort from your team.

If your company claims SR&ED tax credits and you are relying on year-end reconstructed timesheets and project summaries to support those claims, you are carrying significant audit risk. CRA's guidance on contemporaneous documentation is unambiguous, and the gap between what most companies actually have and what CRA expects to see during a review is one of the primary reasons SR&ED claims are reduced or denied. This guide covers what CRA requires, what "contemporaneous" actually means in practice, the most common evidence failures, and how automated systems solve them.

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What CRA Actually Requires for SR&ED Evidence Retention

CRA does not publish a single definitive list of required SR&ED documents. What it does publish is a framework built around three eligibility tests, each of which has implied evidentiary requirements. To claim SR&ED tax credits, you must demonstrate:

1. Technological advancement. Your work must have aimed at advancing the general body of knowledge in a scientific or technological field. Records that prove this include technical reports describing the state of the art at the time the project began, documentation of the novel approach being attempted, and post-project analysis of what was learned.

2. Technological uncertainty. You must show that you did not know, and could not determine from existing knowledge, whether your goal was achievable or how to achieve it. Evidence includes design documents showing competing approaches considered, failure logs, test results showing unexpected outcomes, and communications where the technical problem was acknowledged as unsolved.

3. Systematic investigation. Your R&D must have followed a structured process of hypothesis, experiment, and analysis. The strongest evidence here is a continuous record of this cycle: dated notes showing what hypothesis was being tested, data from experiments or code runs, and analysis of results that informed the next step.

Every type of document CRA accepts during an audit maps back to one or more of these three tests. Records that cannot be tied to at least one test carry little weight, no matter how detailed they are.

For more on SR&ED eligibility criteria and how to structure claims, see the SR&ED overview at GrantOps.

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How Long You Must Keep SR&ED Records

Under the Income Tax Act, the general rule is that you must keep records until the later of:

• Six years from the end of the taxation year to which the records relate, or
• Two years after the date of the most recent notice of reassessment for that year.

In practice, this means most SR&ED-supporting records should be retained for at least six years from the fiscal year in which the work occurred. However, the reassessment trigger means the clock can be extended. If CRA reassesses a tax year, you must retain all records connected to that year for an additional two years from the reassessment date.

There are additional nuances for companies in complex situations. If a scientific research and experimental development expenditure pool balance carries forward across multiple years, the records supporting the original expenditures may need to be retained until the pool is fully extinguished, even if that extends beyond the standard six-year window. Similarly, if a SR&ED refund is under objection or appeal, retain everything related to that claim until the matter is fully resolved plus two years.

What happens if you destroy records early? Destruction of records before the statutory retention period ends is a violation of the Income Tax Act. CRA can assess gross negligence penalties in egregious cases, and in all cases, the absence of records shifts the burden of proof to the taxpayer in a way that is very difficult to overcome. If records were destroyed due to a disaster or accident, document the circumstances immediately and retain whatever corroborating digital records remain.

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The 7 Types of SR&ED Evidence CRA Accepts

CRA's audit teams recognize these primary categories of supporting documentation. Each type has specific characteristics that make it more or less persuasive.

1. Project diaries and laboratory notebooks. Dated entries describing the work performed, the hypothesis being tested, and the outcome observed. Entries must be made at the time of the work. CRA reviewers look for handwritten corrections, crossed-out text, and other signs that indicate real-time recording rather than after-the-fact compilation.

2. Time records. Hour-by-hour or session-by-session logs of who worked on the project, on what date, and what task they performed. Aggregated weekly or monthly totals without daily or task-level breakdown are routinely challenged. Time records must be cross-referenceable to payroll and project management records.

3. Design documents and technical specifications. Documents showing the architecture decisions made, the alternatives considered, and the rationale for the chosen approach. These are particularly important for proving technological uncertainty: if you had three competing approaches and rejected two of them based on experimental results, design documents should show that decision chain.

4. Test results and experimental data. Raw output from tests, experiments, code runs, or prototype evaluations. These records are most valuable when they include unexpected or negative results, which are the clearest signal that genuine uncertainty existed.

5. Source code repositories and version control logs. Git commit histories with timestamps, branch structures, pull request discussions, and code review comments. These serve as a technical diary of the software development process. CRA accepts these as contemporaneous records when they are drawn from active version control systems and are not manipulated post-hoc.

6. Meeting notes and internal communications. Notes from design reviews, retrospectives, and technical planning sessions. Email threads and Slack/Teams messages that discuss technical problems, proposed solutions, and experimental outcomes. These must be dated and attributable to specific individuals.

7. Correspondence and reports from third parties. NRC-IRAP advisor reports, academic collaboration documentation, consultant technical assessments, and correspondence with CRA on prior reviews. These carry strong evidentiary weight because they are contemporaneous records created by parties without a direct financial interest in the claim.

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What "Contemporaneous" Really Means

"Contemporaneous" is the single most important word in SR&ED evidence retention. CRA's published guidance defines contemporaneous documentation as records "created at the time the work is performed in the normal course of business." This definition has three components that are each load-bearing.

"At the time the work is performed." Not the week after. Not at fiscal year-end. Not before filing the T661. The record must exist at the moment the work happens. A commit log created by a version control system the instant a developer pushes code is contemporaneous. A spreadsheet summarizing that developer's activities, filled in three months later from memory, is not.

"In the normal course of business." The record must be something your organization would have created even if SR&ED credits did not exist. A Jira ticket updated as part of your standard sprint workflow is a normal course of business record. A project diary written specifically to support an SR&ED claim and backdated to appear real-time is not, and experienced CRA reviewers identify these quickly.

Why this is the most common audit failure. The majority of SR&ED claims that are reduced or disallowed on audit suffer from one core problem: the supporting records were assembled after the fact in preparation for filing, not captured in real time during the work. Even when the underlying R&D was genuine and eligible, reconstructed records cannot meet the contemporaneous standard, and CRA reviewers have developed considerable expertise at identifying them.

For a deeper look at what happens when CRA reviews your SR&ED file, see the SR&ED audit preparation guide.

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Evidence Retention Failure Modes That Kill SR&ED Claims

Understanding the specific ways SR&ED evidence fails during audit is the most direct path to building systems that prevent those failures.

Reconstructed timesheets. A developer cannot accurately recall, six months later, which specific hours on which specific days were spent on SR&ED versus other tasks. Reconstructed time records show uniform patterns (exactly 30% SR&ED every week) or suspiciously round numbers (exactly 1,500 hours per year) that no real work log produces. CRA reviewers flag these immediately.

No timestamps on technical records. A document titled "Project X Technical Notes" with no file creation date, no version history, and no internal date references cannot be verified as contemporaneous. Digital documents carry metadata that can be inspected. Word files that were created the week before filing and backdated in their content are identifiable.

Aggregated project codes without task detail. If your payroll system records SR&ED hours as a single project code with no breakdown by task, date, or activity, CRA cannot verify what work was actually performed on which days. This is one of the most common gaps in mid-size company SR&ED claims.

Narrative descriptions not tied to actual dates. A technical summary document describing the SR&ED project in general terms without connecting specific activities to specific dates does not prove systematic investigation occurred during the claimed period. It proves you can describe R&D work, which is not the same thing.

No documentation of failed experiments. SR&ED requires technological uncertainty, and genuine uncertainty produces failures. Claims that document only successes look suspicious. If you have no record of the approaches that did not work, your evidence base is incomplete regardless of how well-documented the winning solution is.

Records destroyed before the retention period ends. This is not merely an evidentiary problem. It is a compliance violation that can trigger penalties independent of the SR&ED claim outcome.

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How GrantOps Creates a CRA-Compliant Automated Audit Trail

GrantOps was built specifically to close the gap between how software development teams actually work and what CRA requires to support an SR&ED claim. The platform reads from your existing developer tools via read-only API connections, so your team's workflow does not change.

GitHub integration. Every commit is ingested at the moment it is pushed, with its original timestamp, author, branch, and message preserved. Pull request histories, including the review comments and the technical discussions that occur during code review, are captured and linked to the relevant SR&ED project. GrantOps uses this commit-level data to build a time-stamped technical narrative of the systematic investigation your team conducted. For a detailed look at how pull request evidence supports SR&ED claims, see the post on SR&ED evidence from pull requests and development history.

Jira integration. Issue tickets, sprint logs, and backlog items are read continuously. When a ticket is tagged to an SR&ED project, GrantOps tracks every status change, comment, and linked commit, preserving the full timeline of how the technical problem was identified, worked, and resolved. This creates exactly the kind of systematic investigation record that CRA reviewers look for.

Slack integration (read-only). Technical discussions in designated channels are captured with their original timestamps and participants. When your engineering team discusses a failed approach in a Slack thread on a Tuesday afternoon, that discussion becomes a permanent part of your SR&ED evidence file, timestamped to the moment it occurred.

Automated narrative generation. Raw technical data alone is not sufficient for a T661. CRA reviewers need a human-readable description of the work that maps activities to the three eligibility tests. GrantOps generates this narrative automatically from the captured activity data, producing technical descriptions that describe the uncertainty addressed, the systematic process followed, and the advancement achieved, all tied to specific dates and activities drawn from your actual tools.

T661 generation. The platform auto-generates T661 forms with supporting schedules, drawing from the accumulated evidence trail rather than from year-end estimates. Because the underlying data is captured contemporaneously, the resulting T661 carries a much stronger evidentiary foundation than one assembled from reconstructed records.

Seven-year retention guarantee. All captured data is retained in GrantOps for the full statutory period, with immutable timestamps and a complete audit log of every record in the system.

To see how the full automation workflow fits together, visit the SR&ED automation page.

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12-Item SR&ED Evidence Retention Checklist

Use this checklist to assess your current SR&ED evidence posture for the active fiscal year. Every item should be in place before you file, and ideally before the fiscal year ends.

• [ ] Project diaries or equivalent technical logs with dated entries for each SR&ED project, created at the time the work was performed
• [ ] Time records at the task or session level showing hours by employee, by project, by date, cross-referenceable to payroll
• [ ] Technical uncertainty documentation showing what was unknown at the outset of each project and what knowledge gap existed
• [ ] Systematic investigation records showing the hypothesis-experiment-analysis cycle for each project, with specific dates for each iteration
• [ ] Test results and experimental data, including failed experiments, with original timestamps
• [ ] Design documents and architecture decision records showing competing approaches considered and the rationale for each decision made
• [ ] Peer review and design review meeting notes with attendees, dates, and technical content documented
• [ ] Source code repository logs with commit histories accessible, timestamped, and linked to SR&ED projects
• [ ] Correspondence and internal communications (emails, Slack threads) that discuss technical problems, proposed solutions, and outcomes
• [ ] NRC-IRAP reports or other third-party technical assessments if applicable, retained with original dates and signatures
• [ ] Financial records showing SR&ED expenditures matched to project codes and time records, ready to reconcile against T661 schedules
• [ ] Signed technical project descriptions for each SR&ED project, describing the advancement sought, the uncertainty present, and the investigation conducted, completed before filing date

If you cannot check every item on this list for your current fiscal year, your SR&ED claim carries audit risk. The time to address gaps is before you file, not after CRA contacts you.

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Manual Documentation vs GrantOps Automated Audit Trail

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What to Do If Your Records Are Incomplete

If you are reading this post because you already have a gap in your SR&ED evidence, the most important thing to do is stop making it worse. Do not attempt to backfill records in a way that misrepresents when they were created.

Step 1: Inventory what you have. Collect all digital artifacts with original timestamps: git repositories with full history, Jira or GitHub issue archives, email threads, Slack exports, calendar records, and any existing project documentation. These corroborating records are the foundation for any reconstruction effort.

Step 2: Reconstruct from corroborating sources, transparently. CRA permits reconstruction of records when originals have been lost, but the reconstruction must be documented as a reconstruction. Note in each reconstructed document that it was prepared on a specific date based on specific sources, and identify those sources.

Step 3: Engage an SR&ED consultant. If your records gap is significant and you are facing an audit or preparing to file for a year with incomplete documentation, an experienced SR&ED consultant can help you assess the risk, structure the reconstruction, and communicate with CRA appropriately.

Step 4: Implement a contemporaneous capture system before the next fiscal year. Retroactive reconstruction is a one-time fix for a specific problem. The permanent solution is a system that captures evidence continuously. GrantOps is designed for exactly this purpose: companies that have realized, often after a difficult audit conversation, that their evidence collection process cannot scale.

The cost of a retroactive reconstruction effort, including consultant time and the risk of reduced credits, almost always exceeds the cost of implementing automated evidence capture going forward.

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Start Building Your Automated SR&ED Evidence Trail Today

CRA's requirements for SR&ED evidence retention are not complex, but meeting them consistently across every project, every sprint, and every fiscal year requires a system. Manual processes break down under the pressure of product deadlines, team changes, and the simple fact that developers are hired to build products, not to document their R&D methodology.

GrantOps gives Canadian technology companies a complete, automated SR&ED audit trail built from the tools their engineers already use every day. Every commit, every ticket, every technical discussion becomes a timestamped, CRA-ready record, captured in real time, retained for the full statutory period, and assembled automatically into T661-ready documentation when it is time to file.

If your team is carrying SR&ED audit risk because your evidence collection depends on year-end memory and good intentions, now is the time to fix it.

Visit grantops.ai to start building your automated SR&ED evidence trail.