December 2025: report on GLO, HCRS and HSSA progress
Updated 11 March 2026
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The information contained in this report is correct as of 19 December 2025.
A report about the Group Litigation Order (GLO) Compensation Scheme (the GLO Scheme) was initially commissioned from Dentons by the then Minister Hollinrake 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
- Horizon Convictions Redress Scheme (HCRS)
- Horizon Shortfalls Scheme Appeals (HSSA) process
1. GLO 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. DBT is working with claimants’ legal representatives in relation to claims that are not yet submitted – there are specific reasons for the delayed submission in these instances.
As shown in the GLO Scheme data section of this report, from the pool of 492 eligible GLO Scheme claimants, a total of 476 full claims (including claims for Fixed Sum Award) have been submitted.
As of 19 December 2025, there have been:
- under 40 referrals at the first Independent Panel stage
- under 5 referrals at the second Independent Panel stage
- under 5 referrals at the preliminary issue stage
Also, as set out in previous reports, the GLO Scheme’s Independent Reviewer function has been utilised. The Independent Panel and Independent Reviewer processes continue to be efficient 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, the 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 19 December 2025, DBT achieved this benchmark in 88.4% of cases.
Delivery target for challenge cases[footnote 1]
As of 19 December 2025, DBT continued to exceed its 90% delivery target in respect of challenge cases. Approximately 93.5% 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. The number of referrals made at the first Independent Panel stage since 30 September 2025 has remained largely consistent with the number of referrals made during the previous period.
The Independent Panel continues to support the efficient resolution of claims. On average, as of 19 December 2025, claimants received a first Independent Panel decision in under 33.5 working days from formal referral to the Independent Panel.
In cases where the Independent Panel decision was provided to the parties between 30 September 2025 and 19 December 2025, over 75% of those claims were settled following the first Independent Panel decision. The remainder of these claims are either still within the claims facilitation period between the 2 Independent Panel stages or have been referred to the second Independent Panel stage for a final decision.
1.5 GLO Scheme data
Scroll to the right to see all of the data in the table
| GLO Scheme Data Type | Position as of 30 April 2024 | Position as of 31 May 2024 | Position as of 28 June 2024 | Position as of 31 October 2024 | Position as of 29 November 2024 | Position as of 3 January 2025 | Position as of 31 March 2025 | Position as of 30 June 2025 | Position as of 30 September 2025 | Position as of 19 December 2025 |
|---|---|---|---|---|---|---|---|---|---|---|
| GLO claimants eligible for GLO Scheme | 492 | 492 (-) |
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 (-) |
491 (+2) |
491 (-) |
| Claims submitted*** | 187* | 198* (+11) |
221* (+23) |
306* (+85) |
334* (+28) |
370* (+36) |
446* (+76) |
460* (+14) |
473* (+13) |
476* (+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) |
| Offers accepted or settled | 143** | 147** (+4) |
148** (+1) |
151** (+3) |
153** (+2) |
153** (-) |
155** (+2) |
157** (+2) |
157** (-) |
158** (+1) |
| Claims for individual assessment | ||||||||||
| Submitted | 39* | 47* (+8) |
68* (+21) |
147* (+79) |
172* (+25) |
206* (+34) |
277* (+71) |
290* (+13) |
295* (+5) |
294* (-1) |
| Offers accepted or settled | 10* | 25* (+15) |
31* (+6) |
77* (+46) |
82* (+5) |
90* (+8) |
132* (+42) |
179* (+47) |
233* (+54) |
263* (+30) |
| At Claims Facilitation stage | 12 | 13 (+1) |
16 (+3) |
43 (+27) |
54 (+11) |
67 (+13) |
102 (+35) |
77 (-25) |
65 (-12) |
46 (-19) |
| 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 |
| At Reviewer stage | 0 | 0 | 0 | 0 | Fewer than 10 | Fewer than 10 | Fewer than 10 | Fewer than 10 | Fewer than 10 | 0 |
| 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%* |
*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’.
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 (HCRS)
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 of 19 December 2025, 473 full and final claims for financial redress have been received under the HCRS. Offers have been made in all of those claims, with 457 claims having been settled through claimants accepting the fixed sum offer of £600,000.
While we have been assisting with the case management of several claims which transitioned from the Overturned Convictions (OC) Scheme, no claims have been formally referred for ADR stage 1 as of 19 December 2025.
There were fewer than 5 referrals of claims in the period 30 September 2025 to 19 December 2025 to ADR stage 2. These were subsequently withdrawn because the parties achieved a resolution.
Dentons continues to actively engage with claimants’ legal representatives and DBT to identify and assist in the resolution of issues arising in the HCRS process.
We also continue to coordinate roundtable meetings chaired by the Independent Panel Chair, Sir Gary Hickinbottom. The meetings are also attended by DBT, the claimants’ legal representatives and Dentons. Two roundtables took place in the period 30 September 2025 to 19 December 2025. Both meetings were productive in addressing scheme-wide issues.
2.3 HCRS data
| HCRS data type | Position as of 30 September 2025 | Position as of 19 December 2025 |
|---|---|---|
| Total full and final claims submitted | 451 | 473 (+22) |
| Offer accepted or settled | 436 | 457 (+21) |
| Claims eligible for the OC Scheme | 111 | 111 (-) |
| Offer settled | 71 | 71 (-) |
| Transferred to HCRS | 40 | 40 (-) |
| Claims for detailed assessment | 0 | 0 (-) |
| At ADR stage 1 | 0 | 0 (-) |
| At ADR stage 2 | 0 | 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 (HSSA)
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 of 19 December 2025:
- DBT has received 378 separate entity registrations, of which 315 have passed eligibility checks
- 208 claims have transferred from the Horizon Shortfall Scheme (HSS) Dispute Resolution Process
- DBT has received all required information for 80 appeals
- of those 80 appeals, DBT has made offers on 31 appeals
- of those 31 offers, one has been accepted
Fewer than 5 appeals have progressed to the Independent Panel stage.
There continues to be a period of transition during which participants in the HSSA process become familiar with the operation of the scheme. Also, it has naturally taken some time for appeals to progress through the initial bilateral stages of the process to an Independent Panel.
Now that appeals have started to be referred to the Independent Panel, 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 issue that has affected the pace of appeals progressing is the further disclosure that Post Office Limited are providing for appeals (it being recognised that disclosure previously provided was incomplete). While it is positive that appellants will have a greater amount of disclosure to assist in their appeals, this disclosure exercise is impacting the ability of appellants to decide whether or not they wish to accept any offers made in HSSA.
3.3 HSSA data
| HSSA data type | Position as of 30 September 2025 | Position as of 19 December 2025 |
|---|---|---|
| Total HSSA claims registered | 237 | 378 (+141) |
| Claims passed eligibility check | 224 | 315 (+91) |
| Total HSSA claims with offer made | 6 | 31 (+25) |
| Accepted | 1 | 1 (-) |
| Claims for individual assessment | 0 | Fewer than 5 |
| At Panel stage | 0 | Fewer than 5 |
| At Reviewer stage | 0 | 0 (-) |