Transparency data

June 2025: report on GLO Compensation Scheme progress

Updated 12 September 2025

The information contained in this report is correct as at 30 June 2025.

1. Introduction

This report was 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’). 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 460 full claims^{[footnote 1]} (including claims for Fixed Sum Award^{[footnote 2]}) have been submitted. Of those 460 full claims, DBT has issued offers on 452 claims (approximately 98% of full claims submitted) and offers have been accepted on 336 of those claims (approximately 73% of full claims submitted).

As at 30 June 2025, there have been under 15 referrals to the Independent Panel. Also, per previous reports, 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

The following factors continue to have a positive impact on the pace of the scheme.

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 30 June 2025, DBT achieved this benchmark in 89.4% of cases.

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

As at 30 June 2025, approximately 94% of claimants (107 out of 114) who submitted complete challenges after 1 December 2024 received their substantive response within 40 working days of doing so^{[footnote 5]}. This is a 4% improvement against the 90% figure for the period to 31 March 2025.

In our previous report, we noted instances where DBT took longer than 40 working days to substantively respond to a complete challenge. As reflected by the data, DBT has improved in this regard. We are seeing notably fewer instances of claimants’ legal representatives raising concerns about DBT exceeding the 40-working-day period.

Case management measures to assist with speedier resolution of claims

We previously reported on measures to address slower progress on certain Challenge Cases. Specifically, case management calls and the more recently introduced ‘stocktake’ calls. There have been several stocktake calls on appropriate Challenge Cases. These have been productive and efficient in helping DBT and the claimant to understand each other’s positions at an early stage in the facilitation period.

We are also actively considering the introduction of further case management measures to speed up the resolution of certain complex Challenge Cases.

Negotiation sessions

In appropriate cases, DBT and the claimant can attend a Negotiation Session – chaired by a senior lawyer at Dentons – in an attempt to resolve a Challenge Case. We are liaising with some of the claimants’ legal representatives as to which Challenge Cases might be suitable for a Negotiation Session.

2.2 The Independent Panel

Claimants are increasingly utilising the Independent Panel to assist with the resolution of their claims. There has been a 60% increase in the number of Independent Panel referrals since 31 March 2025.

The Independent Panel continues to assist with the swift resolution of claims. As of 30 June 2025, on average, claimants received a first Independent Panel decision in under 23 working days from formal referral to the Independent Panel. Furthermore, in cases where the Independent Panel decision was provided to the parties between 31 March and 30 June 2025, all these claims settled following the first Independent Panel decision. We anticipate, given the success of the Independent Panel process in assisting with the resolution of claims, the number of referrals to the Independent Panel will continue to increase.

3. GLO scheme data as at 30 June 2025

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	Position as at 30 June 2025
GLO claimants eligible for GLO scheme	492	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 (-)	489 (-)
Claims submitted***, of which	187*	198 (+11)*	221 (+23)*	306 (+85)*	334 (+28)*	370 (+36)*	446 (+76)*	460 (+14)
Claims for Fixed Sum Award
Submitted	148*	151 (+3)*	153 (+2)*	159 (+6)*	162 (+3)*	164 (+2)*	169 (+5)*	170 (+1)
Offers accepted/settled	143**	147 (+4)**	148 (+1)**	151 (+3)**	153 (+2)**	153 (-)**	155 (+2)**	157 (+2)
Claims for individual assessment
Submitted	39*	47 (+8)*	68 (+21)*	147 (+79)*	172 (+25)*	206 (+34)*	277 (+71)*	290 (+13)
Offers accepted/settled	10*	25* (+15)	31* (+6)	77 (+46)*	82 (+5)*	90 (+8)*	132 (+42)*	179 (+47)
At Claims Facilitation stage	12	13 (+1)	16 (+3)	43 (+27)	54 (+11)	67 (+13)	102 (+35)	77 (-25)
At Panel stage	0	0	0	Fewer than 10	Fewer than 10	Fewer than 10	Fewer than 10	Fewer than 15
At Reviewer stage	0	0	0	0	Fewer than 10	Fewer than 10	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%*	89.4%*

*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 the Dentons 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’.

4. Glossary of terms for GLO scheme data

(in the order referred to in the table)

Term	Definition
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. ↩