Transparency data

April 2025: report on GLO Compensation Scheme progress

Updated 6 June 2025

The information contained in this report is correct as at 31 March 2025.

1. Introduction

These reports were commissioned by the then Minister Hollinrake following discussion with the Horizon Compensation Advisory Board. Dentons produces the report when the Department for Business and Trade (DBT) requests it.

This report focuses on our current observations on progress and related data for the GLO Compensation Scheme (‘the scheme’). Please refer to our first published report, which sets out an overview of our role, the process involved in the scheme and the definitions of any terms not stated in this report.

2. Observations

The vast majority of claims have now been submitted. For the handful of claims that have not yet been submitted, there are particular reasons behind their delayed submission. We understand that DBT is working with the relevant legal representatives in relation to these claims.

As shown in the GLO scheme data section of this report, from the pool of 492 eligible GLO scheme claimants, a total of 446 full claims^{[footnote 1]} (including claims for Fixed Sum Award^{[footnote 2]} have been submitted. Of those 446 full claims, DBT has issued offers on 432 claims (approximately 97% of full claims submitted) and offers have been accepted on 287 of those claims (approximately 64% of full claims submitted).

As at 31 March 2025, there have been under 10 referrals to the Independent Panel. Also, per our previous report, the scheme’s Independent Reviewer function has been utilised. Our view continues to be that the Independent Panel and Independent Reviewer procedures are efficient and work well.

2.1 Influences on pace

Over recent months, we have observed some positive influences on the pace of the scheme. Some of the key factors are noted below.

Delivery target for initial offers

DBT continues to meet, or be close to meeting, its delivery target of issuing its initial offer to 90% of claimants who have submitted a full claim for individual assessment^{[footnote 3]} within 40 working days. Over the lifetime of the scheme to 31 March 2025, DBT achieved this benchmark in 89.6% of cases.

Delivery target for Challenge Cases^{[footnote 4]}

Following DBT’s introduction of a delivery target for the provision of a substantive response within 40 working days to 90% of claimants who submit a complete^{[footnote 5]} challenge – which took effect on 1 December 2024 – we have observed an improvement in DBT’s response times to claimants’ challenges.

As at 31 March 2025, 90% of claimants (36 out of 40) who submitted complete challenges after 1 December received their substantive response within 40 working days of doing so. 

Notwithstanding DBT’s achievement of its delivery target in respect of Challenge Cases, we are aware of instances where it has taken longer than 40 working days for DBT to substantively respond to a complete challenge and, on occasion, significantly longer than 40 working days. We understand that, at the time the delivery target for Challenge Cases was introduced, DBT had a significant number of Challenge Cases to work through. As a result of additional resources being directed to Challenge Cases, and the imposition of the delivery target, significant progress appears to have been made on clearing the existing cases and response times to complete challenges received after 1 December 2024 have been quicker.

We are continuing to monitor the progress of Challenge Cases closely.

New facilitation measures to assist with speedier resolution of claims

As set out in our previous report, we introduced case management calls to address slower progress on certain Challenge Cases. Most recently, we have also implemented ‘stocktake’ calls. The aim of these calls – which are attended by the DBT, the claimant’s legal representative and Dentons – is to facilitate early post-challenge discussion between the parties to ensure each party understands the position of the other. In appropriate cases, we consider that case management calls and/or stocktake calls will positively impact the time it takes for Challenge Cases to reach resolution.

Requests for further information

We are aware that some claimants have expressed concern around DBT’s issuance of requests for further information (RFIs) late in the 40-working-day target window for issuing offers.

In order to allay the concerns around this, DBT has agreed that when it identifies the need for an RFI, it will – where possible – also issue a partial offer alongside the RFI. If that is problematic (because, for example, the RFI affects multiple heads of loss), DBT will consider making a further substantial interim payment to the claimant.

We welcome this development which should see claimants receiving offers (even if partial) or substantial interim payments more quickly than they otherwise would have.

GLO scheme data type	Position as at 30 April 2024	Position as at 31 May 2024	Position as at 28 June 2024	Position as at 31 October 2024	Position as at 29 November 2024	Position as at 3 January 2025	Position as at 31 March 2025
GLO claimants eligible for GLO scheme	492	492 (-)	492 (-)	492 (-)	492 (-)	492 (-)	492 (-)
GLO claimants eligible for GLO scheme who have registered intention to submit a claim	486	489 (+3)	489 (-)	489 (-)	489 (-)	489 (-)	489 (-)
Claims submitted***, of which	187*	198 (+11)*	221 (+23)*	306 (+85)*	334 (+28)*	370 (+36)*	446 (+76)*
Claims for Fixed Sum Award
Submitted	148*	151 (+3)*	153 (+2)*	159 (+6)*	162 (+3)*	164 (+2)*	169 (+5)*
Offers accepted/settled	143**	147 (+4)**	148 (+1)**	151 (+3)**	153 (+2)**	153 (-)**	155 (+2)**
Claims for individual assessment
Submitted	39*	47 (+8)*	68 (+21)*	147 (+79)*	172 (+25)*	206 (+34)*	277 (+71)*
Offers accepted/settled	10*	25* (+15)	31* (+6)	77 (+46)*	82 (+5)*	90 (+8)*	132 (+42)*
At Claims Facilitation stage	12	13 (+1)	16 (+3)	43 (+27)	54 (+11)	67 (+13)	102 (+35)
At Panel stage	0	0	0	Fewer than 10	Fewer than 10	Fewer than 10	Fewer than 10
At Reviewer stage	0	0	0	0	Fewer than 10	Fewer than 10
First offer within 40 working days of submission of full claim (for individual assessment)	90%*	91%*	92%*	90%*	89%*	89%*	89.6%*

*Given the definition of a ‘full claim’, these figures are necessarily determined by DBT.

**This figure includes offers accepted before the introduction of the Fixed Sum Award and subsequently topped up to £75,000. The figure is provided by DBT as data relating to the topping up of any settled claims to the Fixed Sum Award amount is not recorded on our system.

***This comprises claims for the Fixed Sum Award and claims for individual assessment which are considered to be ‘full claims’. Further claims may have been received, but not yet assessed to determine whether they are ‘full claims’.

3. Glossary of Terms for GLO scheme data

(in the order referred to in table)

Full claims	Claims which DBT considers, with advice from its legal advisers (Addleshaw Goddard), do not need any further evidence to in order to assess every element of the claims.
Claims for Fixed Sum Award	Claims for the total fixed sum of £75,000 (inclusive of interest) per the option given to all eligible GLO claimants to settle their claims on a full and final basis at this level. This is instead of making a claim for individual losses to be assessed in accordance with the GLO scheme Guidance and Principles. The number of ‘submitted’ claims for the Fixed Sum Award include both claims initially submitted for the Fixed Sum Award, as well as claims originally submitted for individual assessment that have since moved to the Fixed Sum Award track.
Claims for individual assessment	Claims for full assessment of all heads of claim (not limited to £75,000 inclusive of interest).
Claims Facilitation stage	The stage to which a claim moves if the claimant rejects DBT’s initial offer of settlement. During this stage, Dentons Claims Facilitators will facilitate discussions and consider appropriate next steps (for example, an alternative dispute resolution (ADR) call or a Senior Session).
Panel stage	The stage to which a claim may move if, after the Claims Facilitation stage, the parties are unable to settle the claim. It is at this stage that the claim will come before the Independent Panel.
Reviewer stage	The stage at which a claim and the Independent Panel’s final assessment in relation thereto may be considered by the Independent Reviewer. The GLO scheme Guidance and Principles sets out the Review Criteria for an application to the Independent Reviewer.

1. See section in this report entitled Glossary of Terms for GLO scheme data for the definition of a ‘full claim’. ↩

2. See section in this report entitled Glossary of Terms for GLO scheme data for the definition of ‘claims for Fixed Sum Award’. ↩

3. See section in this report entitled Glossary of Terms for GLO scheme data for the definition of ‘claims for individual assessment’. ↩

4. Those claims where DBT’s (first or subsequent) offer has not been accepted in full. ↩

5. A challenge is considered to be ‘complete’ if DBT does not require any more information from the claimant or their legal representative in order to provide a substantive response. ↩