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June 2026: report on GLO, HCRS and HSSA progress

Updated 6 October 2026

The information contained in this report is correct as at 26 June 2026.

A report in respect of the Group Litigation Order (GLO) Compensation Scheme was initially commissioned from us by the then Minister for Enterprise, Markets and Small Business, Kevin Hollinrake MP, following discussion with the Horizon Compensation Advisory Board.

Upon request by the Department for Business and Trade (DBT), and given our independent roles across a number of schemes, we now produce a periodic report covering the progress of the:

  • GLO Scheme
  • Horizon Convictions Redress Scheme (HCRS)
  • Horizon Shortfalls Scheme Appeals (HSSA)

1. Group Litigation Order Compensation Scheme

1.1 Introduction

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

1.2 Observations

With the exception of a very small number of claims, all claims have now been submitted to the GLO Scheme. There are specific reasons for the delayed submission of claims that are yet to be submitted and DBT continues to work with claimants’ 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 485 full claims (including claims for Fixed Sum Award) have been submitted. Of those 485 full claims, DBT has issued offers on 483 claims (over 99% of full claims submitted) and offers have been accepted bringing about a full resolution on 452 of those claims (approximately 93% of full claims submitted).

As at 26 June 2026, there have been under 55 referrals at the first Independent Panel stage, under 10 referrals at the second Independent Panel stage and under 10 referrals at the preliminary issue stage. Also, as set out in previous reports, the GLO Scheme’s Independent Reviewer function has been utilised and, as at 26 June 2026, there have been less than 5 referrals to the Independent Reviewer. The Independent Panel and Independent Reviewer processes continue to be efficient and effective in supporting the overarching aim of delivering full, fair and swift redress to GLO claimants.

1.3 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 within 40 working days. Over the lifetime of the scheme to 26 June 2026, DBT achieved this benchmark in 88% of cases.

Delivery target for Challenge Cases[footnote 1]

As at 26 June 2026, DBT continued to exceed its 90% delivery target in respect of Challenge Cases. Approximately 92.8% of claimants who submitted complete[footnote 2] challenges after 1 December 2024 received their substantive response within 40 working days of doing so. 

Case management measures to assist with speedier resolution of claims

The case management measures we have implemented continue to be effective in expediting the resolution of claims or referral of claims to the Independent Panel. Such measures include:

  • ‘stocktake calls’ attended by DBT and a claimant’s legal representative, and chaired by Dentons
  • continued active consideration of Challenge Cases by the Dentons Claims Facilitation team
  • regular meetings with the GLO Scheme’s Independent Reviewer, Sir Ross Cranston, at which Sir Ross issues guidance on certain Challenge Cases

Negotiation Sessions

Negotiation Sessions – chaired by a senior lawyer at Dentons – remain available to parties in appropriate Challenge Cases.

1.4 The Independent Panel

Claimants are continuing to utilise the Independent Panel to support the resolution of their claims, though the number of referrals made to the Independent Panel between 31 March 2026 and 26 June 2026 was lower than the referrals made during the previous period. We anticipate that this reduction in referrals to the Independent Panel is due to a reduction in the overall number of live claims remaining in the scheme.

The Independent Panel continues to be an effective process that supports the efficient resolution of claims. On average, as of 26 June 2026, claimants received a first Independent Panel decision in under 33 working days from formal referral to the Independent Panel. We anticipate that further referrals to the Independent Panel will be made in light of the speed at which such decisions are provided.

1.5 GLO Scheme data

Scroll to the right to see all of the data in the table.

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 Position as at 30 September 2025 Position as at 19 December 2025 Position as at 31 March 2026 Position as at 26 June 2026
GLO claimants eligible for GLO Scheme 492 492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
492
(-)
GLO claimants eligible for the GLO Scheme who have, or previously had, registered intention to submit a claim^ 486 489
(+3)
489
(-)
489
(-)
489
(-)
489
(-)
489
(-)
489
(-)
491
(+2)
491
(-)
490
(-1)
491
(+1)
Claims submitted*** 187* 198*
(+11)
221
(+23)
306*
(+85)
334*
(+28)
370*
(+36)
446*
(+76)
460*
(+14)
473*
(+13)
476*
(+3)
482*
(+6)
485*
(+3)
Claims for Fixed Sum Award                        
Submitted^ 148* 151*
(+3)
153*
(+2)
159*
(+6)
162*
(+3)
164*
(+2)
169*
(+5)
170*
(+1)
178*
(+8)
182*
(+4)
No longer reported^ No longer reported^
Offers accepted or settled 143** 147**
(+4)
148**
(+1)
151**
(+3)
153**
(+2)
153**
(-)
155**
(+2)
157**
(+2)
157**
(-)
158**
(+1)
158**
(-)
158**
(-)
Claims for individual assessment                        
Submitted^ 39* 47*
(+8)
68*
(+21)
147*
(+79)
172*
(+25)
206*
(+34)
277*
(+71)
290*
(+13)
295*
(+5)
294*
(-1)
No longer reported^ No longer reported^
Offers accepted or settled^ 10* 25*
(+15)
31*
(+6)
77
(+46)*
82*
(+5)
90*
(+8)
132*
(+42)
179*
(+47)
233*
(+54)
263*
(+30)
No longer reported^ No longer reported^
At Claims Facilitation stage 12 13
(+1)
16
(+3)
43
(+27)
54
(+11)
67
(+13)
102
(+35)
77
(-25)
65
(-12)
46
(-19)
36
(-10)
22
(-14)
At Panel stage 0 0 0 Fewer than 10 Fewer than 10 Fewer than 10 Fewer than 10 Fewer than 15 Fewer than 15 Fewer than 10 Fewer than 10 Fewer than 5
At Reviewer stage 0 0 0 0 Fewer than 10 Fewer than 10 Fewer than 10 Fewer than 10 Fewer than 10 0 Fewer than 10 Fewer than 5
First offer within 40 working days of submission of full claim (for individual assessment) 90%* 91%* 92%* 90%* 89%* 89%* 89.6%* 89.4%* 89%* 88.4%* 88.7%* 88%*

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

**The figures for ‘Claims for Fixed Sum Award – offers accepted or settled’ include 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.

***‘Claims submitted’ 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’.

^Since the last data publication (as of 19 December 2025), the reporting methodology and labelling have been updated, so the data may not align exactly with previous reports. However, no claims have been missed and the data remains accurate.

1.6 Glossary of terms for GLO Scheme data

Term Definition
Full claims  Claims which DBT considers, with advice from its legal advisors (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 Compensation 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 Compensation Scheme: guidance and principles sets out the Review Criteria for an application to the independent Reviewer.

2. Horizon Convictions Redress Scheme

2.1 Introduction

This section of the report focuses on our current observations on progress and related data for the HCRS. Please refer to our September 2025 report (published on 31 December 2025), which sets out an overview of our role in the HCRS, the process involved in the HCRS and the definitions of any terms not stated in this section of the report.

2.2 Observations

As at 26 June 2026, 529 full and final claims for financial redress have been received under the HCRS. Offers have been accepted in 501 of those claims.

As at 26 June 2026:

  • fewer than 5 claims have been formally referred for Alternative Dispute Resolution (ADR) Stage 1
  • across both claim-specific and scheme-wide matters, there have been fewer than 5 referrals for ADR Stage 2

Dentons continues to work with the Independent Panel Chair (Sir Gary Hickinbottom), DBT and claimants’ legal representatives to arrange roundtable meetings at which scheme-wide issues can be discussed.

2.3 HCRS data

HCRS Data Type Position as at 30 September 2025 Position as at 19 December 2025 Position as at 31 March 2026 Position as at 26 June 2026
Total full and final claims submitted 451 473
(+22)
504
(+31)
529
(+25)
Submitted 15 16
(+1)
13
(-3)
28
(+15)
Offer accepted or settled 436 457
(+21)
491
(+34)
501
(+10)
Claims eligible for the OC Scheme 111 111
(-)
111
(-)
111
(-)
Offer settled 71 71
(-)
71
(-)
71
(-)
Transferred to the HCRS 40 40
(-)
40
(-)
40
(-)
Claims for detailed assessment 0 0
(-)
0
(-)
Fewer than 5
At ADR Stage 1 0 0
(-)
0
(-)
Fewer than 5
At ADR Stage 2 0 Fewer than 5 Fewer than 5 Fewer than 5

2.4 Glossary of terms for HCRS data

Term Definition
Initial interim payment claims Eligible claims received for preliminary payment of £200,000.
Full and final claims Claims made for either acceptance of fixed sum amount or for detailed assessment.
Claims for individual assessment Claims for full assessment of all heads of claim.
ADR Stage 1  Case management and facilitated discussions led by the independent claims facilitator, Dentons.
ADR Stage 2  Referral to the Independent Panel – an independent decision-making body who will assess claims and make a recommendation on the redress payable.

3. Horizon Shortfall Scheme Appeals

3.1 Introduction

This section of the report focuses on our current observations on progress and related data for HSSA. Please refer to our September 2025 report (published on 31 December 2025), which sets out an overview of our role in HSSA, the HSSA process and the definitions of any terms not stated in this section of the report.

3.2 Observations

Dentons understands from data provided by DBT that, as at 26 June 2026:

  • DBT has received 571 separate entity registrations, of which 524 have passed eligibility checks
  • DBT has received all required information for 110 appeals, of which:
    • DBT has made offers on 67 appeals
    • 22 offers have been accepted

Fewer than 20 appeals have progressed to the Independent Panel stage. The HSSA Independent Reviewer function has been utilised and, as at 26 June 2026, there have been fewer than 5 referrals to the Independent Reviewer.

The number of referrals to the Independent Panel has notably increased. We anticipate that referral volumes will continue to increase over the coming months, as more appeals progress through the initial bilateral stages of the process.

We continue to be in regular contact with certain appellants’ legal representatives (and Addleshaw Goddard) to discuss progress on appeals and facilitate the resolution of any procedural issues arising. One matter that has impacted resolution of some appeals is the differing positions taken by DBT and the appellants’ legal representatives on certain heads of loss which are common to a number of appeals. These issues of legal principle arise in appeals that have been referred to the Independent Panel to assess. It is expected that the panel’s assessment of these appeals, which is expected to take place in the coming weeks, will assist to move forward other cases that involve the same heads of loss.

3.3 HSSA data

HSSA Data Type Position as at 30 September 2025 Position as at 19 December 2025 Position as at 31 March 2026 Position as at 26 June 2026
Total HSSA appeals registered 237 378
(+141)
570
(+192)
571
(+1)
Appeals registered 13 63
(+50)
65
(+2)
47
(-18)
Appeals passed eligibility check 224 315
(+91)
505
(+190)
524
(+19)
Total HSSA Appeals with offer made 6 31
(+25)
61
(+30)
67
(+6)
Accepted  1 1
(-)
10
(+9)
22
(+12)
Appeals for individual assessment 0 Fewer than 5 Fewer than 10 Fewer than 20
At panel stage 0 Fewer than 5 Fewer than 10 Fewer than 20
At reviewer stage 0 0
(-)
0
(-)
0
(-)
  1. Those claims where DBT’s (first or subsequent) offer has not been accepted in full. ↩

  2. 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. ↩