Author
Alex Simmons - Co-Founder & CEO, Kashcade
With a background in big-bank product strategy at CommBank and management consulting at Accenture, Alex now works directly with Australian founders to unlock R&D funding at speed. Under his leadership, Kashcade has raised ~$100M in capital, served hundreds of companies, and built a profitable lending business from the ground up.
The Ambitious Australia report landed with considerable fanfare last week, and with good reason. The expert panel is high-calibre, the ambition is real, and Australia's R&D investment trajectory demands a serious response.
The panel was commissioned to tackle three interconnected challenges: maximising the value of public investment in research across universities, industry and government; harnessing and growing business investment in R&D; and leveraging our scientific strengths to address national priorities and foster new industries.
I want to share my view on the RDTI-related recommendations in Chapter 3. My perspective is shaped by two things: years working as a strategist prior to Kashcade (including at a consulting firm engaged in projects within the ATO and Australian Government) and now working daily with the founders and companies at the coalface of this program. I've also spent considerable time over the past week in conversations with many R&D advisors, which has helped me consolidate these views into an opinion from the perspective of an R&D lender.
My overall read: the report contains merit, and the intent throughout is sound. But in trying to be comprehensive, it has produced something that is net more complicated than what it set out to fix. The panel acknowledges the program is in serious need of simplification, yet what they've recommended is largely the opposite.
There are some recommendations that would genuinely simplify and streamline the program in there. But the addition of multiple new cohorts, tiered eligibility mechanisms, and bespoke carve-outs has produced a set of recommendations that are, in aggregate, unfeasible and unlikely to be executed in any meaningful timeframe.
Recommendation 5a: Reform the RDTI to simplify administration
Recommendation 5a:
Deemed rate for supporting activities
The proposal to introduce a deemed (i.e. fixed) rate for supporting activities would reduce the burden of documenting supporting activities. I understand the appeal, particularly for software companies where the supporting/core distinction creates much friction.
But it prompts a question the report doesn't answer: if supporting activities are requisites for the R&D to occur, why should they be treated differently at all? And in practice, a deemed rate introduces a new layer of calculation complexity that may simply trade one form of administrative burden for another.
Recommendation 5a:
Raising the minimum expenditure floor from $20,000 to $150,000
26%
of FY22 cohort spent under $150k (3,051 companies)
106%
avg R&D spend increase year-on-year for that cohort
I disagree with this recommendation strongly. Kashcade's RDTI research shows that companies spending less than $150,000 on R&D made up 26% of the FY22 RDTI cohort and 24% of the FY23 cohort. This is not a marginal cohort.
Those that spent under $150,000 in FY22 and returned in FY23 increased their R&D spend by an average of 106% in that single year. These are early-stage companies on a growth trajectory, and this recommendation would cut them off at precisely the moment they are gaining momentum, redirecting them to a grants program that operates on entirely different timelines and criteria.
Raising the floor does not simplify the program. It shrinks the program. Those are not the same thing.
Recommendation 5a:
Removing clawback rules
This one I agree with. Clawbacks have functioned as a dampening effect on legitimate claims. And companies that have distinguished themselves enough to have won the support of other government grant programs should see the benefit of multiple support programs.
Removing it is clean, simple, and immediately beneficial. It is one of the few recommendations in this chapter that is both high-impact and truly low-effort to implement.
Recommendation 5b: The Premium Startup Stream
Recommendation 5b:
A premium stream sounds good in theory - but the design undermines the concept
In theory, I agree with the intent. We should be doubling down on high-potential ventures. And there are elements here I support: a higher refundable offset rate, project-based rather than activity-based eligible expenditure, and extending eligibility to development, deployment and early commercialisation. These would provide meaningful and much-needed support to companies through to market. But the implementation design undermines the concept.
390
VC startup investments in Australia in all of 2025
13,000
companies currently served by the RDTI program
A 100-point eligibility test - requiring criteria such as VC backing, accelerator participation, university collaboration or existing IP – would likely exclude the vast majority of RDTI claimants. Consider the numbers: in the entirety of 2025, there were only 390 VC startup investments in Australia. The RDTI program serves approximately 13,000 companies. Even being generous about how the 100-point test would work in practice, the premium stream would be accessible to a tiny fraction of the existing cohort, and likely not the ones who need cashflow support most urgently.
The access limitation of three years for SaaS and AI companies creates further complexity. This would require a new clock to track, new eligibility transitions to manage, and a category distinction (deep tech vs. other) that advisors and the ATO would need to assess and administer.
The reality is, this is too complicated.
Recommendation 5b: On quarterly cash advances:
Quarterly payments are not a new idea - and there's a reason they were never implemented
2012
when the Government first explored quarterly payments
12 pages
of 2013 draft legislation just to cover the mechanics
Of course, I believe the quarterly cashflow proposition is appealing. That's what Kashcade is built upon. And any founder waiting twelve months for a refund they could receive quarterly instead would take it.
But quarterly payments are not a new idea. The Government explored them in 2012 but it was never implemented. The decision not to implement serves as a case study in how hard this specific change is to execute. The 2013 draft legislation ran to twelve pages just to cover the mechanics of how quarterly amounts would be calculated, varied and reconciled. And that was for a simpler, flat mechanism with no 100-point eligibility filter sitting upstream of it.
Now consider what implementation would require today: DISR and the ATO jointly agreeing on policy design; new legislation; budget allocation; systems development; and a go-live process – all for somewhere between 1,000 and 13,000 companies out of three million in Australia. Then layer on the startup side: quarterly claims would require time-constrained teams, their bookkeepers, tax agents and RDTI advisors to all operate on a quarterly compliance rhythm rather than the annual one they currently scramble through.
The ATO struggles to process RDTI refunds once per year as it is. Quarterly processing would quadruple that workload overnight.
Our own process at Kashcade is purpose-built to strike the balance between what companies can provide and what a lender needs to assess. Even so, it would not come close to meeting the standard the ATO would require to release a quarterly refund. That tells you something about the gap between the idea and its execution, and in sum, we believe it is unfeasible for implementation.
Recommendation 5c: SMEs and Scaleup Stream
The proposal to link ongoing RDTI access to revenue growth above CPI, with on and off ramps, is poorly suited to the context of these individual businesses. Revenue trajectories are shaped by market conditions, capital structures, product cycles and many other factors. Tying access to a growth benchmark introduces uncertainty into a program that companies need to be able to plan around. Moreover, companies that choose to sacrifice existing product revenue to invest in new innovations requiring R&D, are likely to see subdued revenue growth. This is not the right carve-out for a program like this, and it risks penalising exactly the resilient, innovation-active companies we should be supporting.
On the other hand, lifting the refundable offset threshold from $20 million to $50 million in turnover is the single recommendation in this chapter that I would prioritise above all others.
The $20 million wall is a policy own-goal. Scaleups that hit that figure are those most capable in developing new technologies successfully, commercialising it, and are typically growing but not yet profitable. For example, Canva has continued to innovate and changed an entire industry at multi-billion-dollar revenues for over a decade, while still burning cash in losses. If Australia wants to produce more globally renowned innovative companies like Canva, we need to back scaling companies through their most capital-intensive years, not cut them off at the first sign of commercial traction.
Crucially, this is also the simplest change in the entire chapter to implement. It is a threshold change to an existing rule. It requires no new form, no new eligibility test, no new administrative process. That combination of high impact, low effort is what separates it from almost everything else in Chapter 3.
A note on the data
86%
of claimants use R&D advisors — and that's a good thing
The report cites DISR analysis showing 86% of RDTI claimants rely on R&D tax consultants. It uses this as evidence that the program is too complex. I'd push back on that interpretation.
In our experience, companies use advisors because they want the job done properly by a dedicated specialist they can rely on. That is rational professional behaviour, not a symptom of a broken program. Accountants file tax returns. Lawyers draft contracts. RDTI advisors support R&D claims.
The 86% figure tells us the market for specialist advice is healthy and well-utilised. It does not, on its own, tell us the program is broken.
In summary
This is a goliath task and we need to move quickly. But the scale and urgency of the problem calls for a blunt instrument – not the scalpel approach recommended. We need solutions that are high-impact and straightforward to implementation, and very few of these Chapter 3 recommendations land in that space.
The ones that do:
Removing clawback rules. High impact on founder confidence and claim ambition. Low legislative and administrative complexity.
Lifting the refundable threshold to $50 million. High impact on the most proven cohort. Single threshold change. No new infrastructure required.
Simplifying supporting activities for software claims. A form adjustment that removes the most contested section of the most common claim type. Implementable without significant structural change.
Everything else in Chapter 3 belongs in a longer-term reform agenda; one that is properly resourced, carefully sequenced, and developed in significant consultation with the people who actually work in this program day to day.
Which brings me to my closing point. The community most qualified to advise on what's broken and what's fixable (the R&D advisors, tax agents and founders at the coalface) need to be meaningfully in the room before recommendations of this magnitude are made. The gap is visible in the output.
I had high hopes for this report. I still do for what comes next. But getting there requires listening to the right people first.
If you have useful ideas, or would like to discuss the above, I’d welcome your outreach. Please email Alex at hi@kashcade.com.
About Kashcade
Kashcade is Australia’s fastest R&D lender, providing non-dilutive funding to innovative Australian companies by lending against their R&D Tax Incentive refunds. We've deployed nearly $100 million across more than 400 loans, with a 48-hour funding promise. Our team includes former R&D tax advisors, commercial lenders and lending infrastructure engineers.
Reviewed by:
Josh Sanders - Head of Customer at Kashcade and Ex-R&D Consultant.
