Innovator Founder ILR: which revenue counts, and how do you prove exports?

01 / The period

Start with the relevant year, not the most attractive dashboard.

INNF 17.1(f)(iv) and (v) are separate listed achievements. Their reference to the last full year covered by accounts matters: a strong quarter annualised to 12 months, lifetime sales and contracted future income are not interchangeable with that period. A change of accounting reference date or an unusually long first accounting period requires a clear explanation of the annual figure relied upon.

Consider a company approaching a March settlement date with a December year end. The finance team may be working from monthly management information while the completed year's accounts are still being prepared. Resolve with the accountant and endorsing body which completed period will be assessed and when the necessary accounts will be available. A Companies House filing deadline should not be mistaken for the date on which an immigration evidential requirement becomes satisfied.

The choice of application date should follow the evidence and permission expiry. It should not depend on silently substituting an older favourable year or presenting a forecast as completed revenue. If the available period does not support the proposed criterion, assess another achievement or an extension strategy in time.

02 / The accounts

The £1 million criterion carries a specific 2 year evidence expectation.

Under its Gross Revenue Increase heading, the Home Office endorsing body guidance requires accounts prepared by a UK regulated accountant and 2 years of accounts: the last full year before the settlement application and the preceding baseline. For the export criterion, it calls for credible revenue evidence, such as accountant prepared accounts, supplemented by export records. These guidance requirements should be distinguished from the wording of the Rules.

The guidance refers to a rise in revenue. The Rule itself does not prescribe a separate percentage increase. A founder with flat or declining revenue above the threshold should therefore put the baseline and explanation before the endorsing body, addressing business progress and sustainability, rather than inventing a growth percentage or omitting the comparative year.

A useful accountant's reconciliation identifies the accounts used, the accounting framework, the relevant period and the ledger totals supporting the claim. It explains adjustments and unusual transactions. It should establish the financial facts; the legal analysis should then connect those facts to the immigration requirement. A short letter merely repeating the founder's chosen number adds little.

03 / The number

Gross revenue does not mean every pound passing through the bank.

Subscription businesses should reconcile annual recurring revenue, bookings, invoices, cash collected and revenue recognised in the accounts. A contract paid in advance may cover services delivered over more than 1 accounting period. That is a question for the applicable accounting policy, not a reason to count the same receipt whenever it produces the preferred immigration result.

Marketplaces and intermediaries face a different issue. A platform may process £1.4 million of customer payments while earning a much smaller fee. Under FRS 102's revenue provisions, the principal or agent assessment can affect whether revenue is recognised gross or as the fee or commission. The accountant must identify the framework and version actually applicable to the period. The immigration adjective 'gross' does not itself resolve that accounting assessment.

The FRC's 2024 periodic review has a principal effective date of 1 January 2026, with the detailed commencement and transition provisions in the standard. A year ending during 2026 does not, by itself, tell the reader which requirements the company applied. Where a change of accounting policy affects the comparison, explain the effect rather than presenting an apparent commercial increase without qualification.

Separate financing from trading. A share subscription or loan receipt should not be added to sales merely because it funded operations. Refunds, credit notes, taxes collected and amounts handled for others should be reconciled according to the relevant accounting treatment. The immigration submission should be faithful to the accounts and contracts, including where the resulting figure is less impressive than the pitch deck.

04 / The entity

Group success needs a bridge to the endorsed business.

Our assessment is that consolidated group turnover should never be assumed to be the qualifying figure without analysing the endorsed venture. A UK company may employ the founder and develop the product while an overseas company owns customer contracts and books sales. Common ownership does not explain which activity and revenue the settlement endorsement is assessing.

Prepare an entity map showing the seller, customer, product or service, contractual responsibility, intellectual property arrangements and destination of payment. Reconcile entity accounts to any consolidated presentation, identifying intercompany charges and eliminations. This gives the endorsing body a basis on which to examine the actual venture rather than a headline about a worldwide group.

The cited immigration provisions do not supply a general group consolidation formula. Nor do they justify a blanket assertion that every related party sale is excluded. A genuine supply to an overseas affiliate and a circular charge created to improve the settlement total call for very different scrutiny. Material group arrangements should be put to the endorsing body transparently and before the application timetable depends upon their treatment.

05 / The exports

An overseas connection is not a substitute for evidence of the export.

The guidance gives invoices and shipping manifests as examples of supporting export evidence. Physical goods may leave a clear trail through orders, delivery terms, transport and customs records. Reconcile that trail to the seller's ledger and the amount included in the accounts. Do not assume that a customer's foreign address proves where goods were delivered.

For software or services, a shipping manifest may be irrelevant. A sensible evidence file instead identifies the overseas customer, the contract, the service supplied, its delivery or access records, the invoice and the accounting entry. This is a practical response to the evidence question, not an additional Home Office checklist. The absence of a physical shipment does not, by itself, dispose of a services export claim.

Nationality, payment currency and export destination are different facts. Payment in dollars does not establish an export. Equally, sterling invoicing does not by itself defeat one. A UK sale to a distributor that later exports the product should not automatically be described as the founder's own overseas export. The contractual chain needs analysis.

Construct a transaction schedule that ties the claimed exports to the same accounting period as the revenue assessment. Record the customer, country, supply, invoice value, currency conversion, relevant adjustments and supporting documents. Where related parties, resellers or overseas delivery teams intervene, explain the role of each. The reader should be able to follow the claim without relying on a colour coded sales map.

06 / The application

Revenue should support the settlement strategy, not conceal its remaining conditions.

The caseworker guidance separately requires an active trading business, an active key founder role, progress against the endorsed plan and sustainability over the following 12 months. A large historic contract with no renewal may therefore leave a question about the future, even where the revenue figure is established. Explain customer concentration, renewal evidence, cash collection and operating commitments on their merits.

The 2 revenue limbs should not be confused with using 1 criterion twice. On the wording of the Rules, a single applicant whose business meets both listed revenue tests has a basis to seek endorsement under both; the submission should identify each limb expressly. That is a reading of the published provisions, not a guarantee about an individual endorsement. The separate rule against founder team members sharing the same means remains material where more than 1 applicant seeks settlement.

For a team, agree a documented allocation of achievements before preparing individual applications. Do not simply attach the same accounts and identical success narrative to each founder's file. The endorsing body must be able to explain the basis for each endorsement. Personal eligibility and the settlement timetable also require their own review.

Practical questions.