March 2026: report on GLO, HCRS and HSSA progress
Published 10 July 2026
© Crown copyright 2026
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The information contained in this report is correct as at 31 March 2026.
A report in respect of the Group Litigation Order (GLO) Compensation Scheme was initially commissioned from Dentons 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:
- GLO Scheme
- Historic Convictions Redress Scheme (HCRS)
- Horizon Shortfalls Scheme Appeals (HSSA) process
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 is working 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 482 full claims (including claims for Fixed Sum Award have been submitted. Of those 482 full claims, DBT has issued offers on 477 claims (approximately 99% of full claims submitted) and offers have been accepted bringing about a full resolution on 438 of those claims (approximately 91% of full claims submitted).
As at 31 March 2026, there have been under 50 referrals at the first Independent Panel stage, under five referrals at the second Independent Panel stage and under five 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 31 March 2026, there have been less than five referrals to the Independent Reviewer. The Independent Panel and Independent Reviewer processes continue to be efficient and are 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 31 March 2026, DBT achieved this benchmark in 88.7% of cases.
Delivery target for Challenge Cases[footnote 1]
As at 31 March 2026, DBT continued to exceed its 90% delivery target in respect of Challenge Cases. Approximately 93.9% 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 to the Independent Panel since 19 December 2025 has reduced when compared to 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 31 March 2026, claimants received a first Independent Panel decision in under 35 working days from formal referral to the Independent Panel. Further, in cases where the Independent Panel decision was provided to the parties between 19 December 2025 and 31 March 2026, over 72% of those claims settled following the first Independent Panel decision. The remainder of these claims are still within the claims facilitation period between the two Independent Panel stages. We anticipate that further referrals to the Independent Panel will be made in light of this demonstrated success.
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 |
|---|---|---|---|---|---|---|---|---|---|---|---|
| GLO claimants eligible for GLO Scheme | 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) |
| Claims submitted*** | 187* | 198* (+11) |
221* (+23) |
306* (+85) |
334* (+28) |
370* (+36) |
446* (+76) |
460* (+14) |
473* (+13) |
476* (+3) |
482* (+6) |
| 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** |
| Offers accepted or settled | 143** | 147** (+4) |
148** (+1) |
151** (+3) |
153** (+2) |
153** (-) |
155** (+2) |
157** (+2) |
157** (-) |
158** (+1) |
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** |
| Offers accepted orsettled** | 10* | 25* (+15) |
31* (+6) |
77* (+46) |
82* (+5) |
90* (+8) |
132* (+42) |
179* (+47) |
233* (+54) |
263(+30)* | 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) |
| 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 |
| 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 |
| 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%* |
*DBT determines the figures for:
- ‘Claims submitted’
- ‘Claims for Fixed Sum Award – submitted’
- ‘Claims for individual assessment – submitted’
- ‘Claims for individual assessment – offers accepted or settled’
- ‘First offer within 40 working days of submission of full claim (for individual assessment)’
** 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. These figures are 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 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. |
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, 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 31 March 2026, 504 full and final claims for financial redress have been received under the HCRS. Offers have been accepted in 491 of those claims, of which 476 have been settled through claimants accepting the fixed sum offer of £600,000.
As at 31 March 2026:
- no claims have been formally referred for ADR Stage 1
- across both claim-specific and scheme-wide matters, there have been fewer than five 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 |
|---|---|---|---|
| Total full and final claims submitted | 451 | 473 (+22) |
504 (+31) |
| Submitted | 15 | 16 (+1) |
13 (-3) |
| Offer accepted or settled | 436 | 457 (+21) |
491 (+34) |
| Claims eligible for the OC Scheme | 111 | 111 (-) |
111 (-) |
| Offer settled | 71 | 71 (-) |
71 (-) |
| Transferred to the HCRS | 40 | 40 (-) |
40 (-) |
| Claims for detailed assessment | 0 | 0 (-) |
0 (-) |
| At ADR Stage 1 | 0 | 0 (-) |
0 (-) |
| At ADR Stage 2 | 0 | 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 31 March 2026:
- DBT has received 570 separate entity registrations, of which 505 have passed eligibility checks
- DBT has received all required information for 95 Appeals
- of those 95 Appeals, DBT has made offers on 61 Appeals
- of those 61 offers, ten have been accepted
Fewer than 10 Appeals have progressed to the Independent Panel stage.
The number of referrals to the Independent Panel is increasing steadily. Now that Appeals have started to be referred to the Independent Panel following the initial bilateral stages of the process, we expect referral volumes to increase over the coming months.
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 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 |
|---|---|---|---|
| Total HSSA claims registered | 237 | 378 (+141) |
570 (+192) |
| Claims registered | 13 | 63 (+50) |
65 (+2) |
| Claims passed eligibility check | 224 | 315 (+91) |
505 (+190) |
| Total HSSA claims with offer made | 6 | 31 (+25) |
61 (+30) |
| Accepted | 1 | 1 (-) |
10 (+9) |
| Claims for individual assessment | 0 | Fewer than 5 | Fewer than 10 |
| At Panel stage | 0 | Fewer than 5 | Fewer than 10 |
| At Reviewer stage | 0 | 0 (-) |
0 (-) |