To navigate this rule change, the approach would be name investors who have intent to fund your business, and are willing for their names to be disclosed to HMRC.
What HMRC says in the Venture Capital Schemes Manual:
"We will not provide an advance assurance on speculative applications. We will only provide an opinion where the request names the individual(s) who are expected to make the investment or the fund manager or other promoters who are to provide the investors. Though we do not expect the company making the application to have formalised offers of investment, we do expect the company to have approached potential investors before making the advance assurance application to determine the likelihood that they will attract actual investment." You can read this in full here: https://www.gov.uk/hmrc-intern...
HMRC are taking a tougher stance on advance assurance applications and it seems the aim is to reduce the volume of applications, for those who have applied. We're here to help you get investment ready, help enter the details of your potential investors, complete the application and cover letter, ready to send to HMRC.