Transparency data

September 2025: report on GLO, HCRS, and HSSA progress

Published 31 December 2025

1. Introduction

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

A report in respect of the Group Litigation Order (GLO) Compensation Scheme (the GLO Scheme) was initially commissioned from us 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
• the Historic Convictions Redress Scheme (HCRS)
• the Horizon Shortfalls Scheme Appeals (HSSA) process

2. Group Litigation Order Compensation Scheme

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.

2.1 Observations

There remains only a handful of claims that have not yet been submitted. From our regular discussions with claimants’ legal representatives, we understand that there are particular reasons behind the delayed submission in those cases. DBT is working with the relevant legal representatives in relation to these claims and we are also on hand to assist if desired.

As shown in the GLO Scheme data section of this report, from the pool of 492 eligible GLO Scheme claimants, a total of 473 full claims^{[footnote 1]} (including claims for Fixed Sum Award^{[footnote 2]}) have been submitted.

Of those 473 full claims:

• DBT has issued offers on 471 claims (approximately 99.6% of full claims submitted)
• offers have been accepted on 390 of those claims (approximately 82% of full claims submitted)

As at 30 September 2025, there have been:

• under 30 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 and work well in supporting the overarching aim of delivering full, fair and swift redress to GLO claimants.

2.2 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 September 2025, DBT achieved this benchmark in 89% of cases.

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

As at 30 September 2025, DBT exceeded its 90% delivery target in respect of Challenge Cases. Approximately 94% of claimants (174 out of 186) who submitted complete^{[footnote 5]} 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

We have seen increased use of ‘stocktake’ calls on Challenge Cases. These have been productive and, in most cases, have expedited the resolution of claims or referral of claims to the Independent Panel.

As part of our continued active consideration of case management measures that might assist to expedite the resolution of certain complex Challenge Cases, we have introduced regular meetings with the GLO Scheme’s Independent Reviewer, Sir Ross Cranston. At these meetings, certain Challenge Cases are discussed and the Independent Reviewer provides procedural guidance on them. A good number of the Challenge Cases on which the Independent Reviewer has provided guidance have settled shortly following the guidance being issued to the parties.

Negotiation sessions

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

2.3 The Independent Panel

An increasing number of claimants are utilising the Independent Panel to support the resolution of their claims. Since 30 June 2025, there has been:

• a 100% increase in the number of referrals at the first Independent Panel stage
• a 50% increase in the number of referrals at the preliminary issue stage

The Independent Panel continues to support the efficient resolution of claims. On average, as of 30 September 2025, claimants received a first Independent Panel decision in under 28 working days from formal referral to the Independent Panel.

Further, in cases where the Independent Panel decision was provided to the parties between 30 June and 30 September 2025, over 85% of those claims settled following the first Independent Panel decision, with the remainder being referred to the second Independent Panel stage for a final decision.

Given the demonstrated success of the Independent Panel in resolving claims, we expect that referrals to the Independent Panel will continue to rise.

2.4 GLO Scheme data

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 at 30 September 2025
GLO claimants eligible for GLO scheme	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)
Claims submitted***, of which	187*	198 (+11)*	221 (+23)*	306 (+85)*	334 (+28)*	370 (+36)*	446 (+76)*	460 (+14)	473 (+13)
Claims for Fixed Sum Award
Submitted	148*	151 (+3)*	153 (+2)*	159 (+6)*	162 (+3)*	164 (+2)*	169 (+5)*	170 (+1)	178 (+8)*
Offers accepted/settled	143**	147 (+4)**	148 (+1)**	151 (+3)**	153 (+2)**	153 (-)**	155 (+2)**	157 (+2)	157 (-)**
Claims for individual assessment
Submitted	39*	47 (+8)*	68 (+21)*	147 (+79)*	172 (+25)*	206 (+34)*	277 (+71)*	290 (+13)	295 (+5)*
Offers accepted/settled	10*	25* (+15)	31* (+6)	77 (+46)*	82 (+5)*	90 (+8)*	132 (+42)*	179 (+47)	233 (+54)*
At Claims Facilitation stage	12	13 (+1)	16 (+3)	43 (+27)	54 (+11)	67 (+13)	102 (+35)	77 (-25)	65 (-12)
At Panel stage	0	0	0	Fewer than 10	Fewer than 10	Fewer than 10	Fewer than 10	Fewer than 15	Fewer than 15
At Reviewer stage	0	0	0	0	Fewer than 10	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%*	89%*

*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’.

2.5 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.

3. Horizon Convictions Redress Scheme

The HCRS was launched on 30 July 2024. The redress scheme is open to all postmasters who have had convictions quashed under the Post Office (Horizon System) Offences Act, Post Office (Horizon System) Offences (Scotland) Act, or by a court ruling.

Since 3 June 2025, responsibility for administrating claims under the Overturned Convictions scheme (the OC Scheme) transferred from the Post Office to DBT and those claims are now managed under the HCRS.

Our role is to act as independent claims facilitators for the administration of the HCRS and we undertake the following responsibilities:

• case management of claims where an agreement is not reached bilaterally between claimants and DBT
• facilitating discussions between the parties with the aim of reaching a mutually acceptable resolution as swiftly as possible (known as Alternative Dispute Resolution: Stage 1 (ADR Stage 1))
• procuring the Independent Panel of legal, accounting, medical and retail experts, and the Independent Panel Chair, Sir Gary Hickinbottom
• assisting with the submission of claims to the Independent Panel (known as Alternative Dispute Resolution: Stage 2 (ADR Stage 2))
• supporting the Independent Panel Chair on oversight of scheme-wide processes and issues

This report focuses on our current observations on progress and related data for the HCRS.

3.1 Process overview

The HRCS process begins with an eligible postmaster (the claimant) registering for the scheme and completing ID verification checks. Once the claimant’s identification documents have been verified, the claimant is eligible to apply for a preliminary payment of £200,000 (unless the claimant has already received an equivalent primary payment through the previous OC Scheme).

Claimants will then have a choice to accept a final fixed sum settlement offer of £600,000, or to request a detailed assessment of their claim. Where the fixed sum settlement is accepted, DBT will make a final payment of £400,000 to the claimant.

Where claimants request a detailed assessment of their claim, claimants submit a detailed application form with supporting evidence to DBT for consideration. Upon receipt of the application form, claimants will receive a further payment of £250,000.

DBT will assess the application form and will issue the claimant with a detailed assessment offer. The offer will include an explanation on how the amount offered has been calculated. Claimants will have 3 months from the date of this offer to decide whether they wish to return to accept the fixed sum offer of £600,000.

Where a claimant does not accept DBT’s initial detailed assessment offer (or the fixed sum offer), the claimant and DBT enter into bilateral negotiations to seek to reach a resolution of the claim. Where bilateral negotiations do not result in a settlement being reached, the claim may be referred for Alternative Dispute Resolution (ADR) facilitated by Dentons as independent claims facilitators.

There are 2 stages of ADR:

• ADR Stage 1: this involves case management and facilitated discussions between the claimant and DBT, led by Dentons
• ADR Stage 2: referral to the Independent Panel. The Independent Panel will be made up of a group of experts who will assess the claim and make a recommendation on the level of redress that should be payable to the claimant

3.2 Observations

As at 30 September 2025, 451 full and final claims^{[footnote 6]} for financial redress have been received under the HCRS. Of those claims, 436 claims have settled with claimants accepting the fixed sum offer of £600,000^{[footnote 7]}. Offers have been made in a further 13 claims and 2 claims are being assessed by DBT.

No claims have been referred for ADR Stage 1 or ADR Stage 2 as of 30 September 2025. We have been assisting with the case management of several claims which transitioned from the OC Scheme.

Dentons has actively engaged with claimants’ legal representatives and DBT to identify and assist in the resolution of issues arising from the HCRS process. We have also been working with DBT and claimant representative firms to arrange roundtable discussions, which are chaired by Independent Panel Chair, Sir Gary Hickinbottom, and which discuss scheme-wide issues.

3.3 HCRS data

HCRS data type	Position as at 30 September 2025
Total full and final claims submitted	451
Submitted	15
Offer accepted/settled	436
Claims eligible for the OC Scheme	111
Offer settled	71
Transferred to the HCRS	40
Claims for detailed assessment	0
At ADR Stage 1	0
At ADR Stage 2	0

3.4 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.

4. Horizon Shortfall Scheme Appeals

This section of the report focuses on our current observations on progress and related data for the DBT-administered HSSA process.

HSSA was launched in September 2024 as an independent avenue for applicants to the Horizon Shortfall Scheme (HSS) (a Post Office-run scheme) to challenge their initial compensation offers in HSS^{[footnote 8]}.

The central goal, and the overarching principle, of HSSA is to deliver compensation to eligible sub postmasters that is full and fair, restoring them to the position they would have been in had it not been for the Horizon-related actions of Post Office.

Our role in HSSA is to act as the Independent Panel and Independent Reviewer Secretariat. This means that we are the independent, central point of contact for both parties (the appellants and DBT) and responsible for:

• establishing and managing the Independent Panel, which will issue decisions on cases in the event that settlement discussions between the appellant and DBT do not conclude in agreement during the initial stages of the HSSA (the Panel Stage)
• establishing and managing the Independent Reviewer to – amongst other things - issue a final determination where the case is eligible for exceptional review of the Independent Panel’s assessment during the Panel Stage
• supporting the Independent Reviewer on oversight of scheme-wide processes and issues

4.1 Process overview

The HSSA process begins with the appellant submitting an application form to appeal their HSS compensation offer (the Appeal). The Appeal is considered by DBT with advice from its legal representatives, Addleshaw Goddard. DBT will make a fresh assessment of the Appeal and, where it considers the HSS offer was too low, DBT can make a fresh offer to the appellant.

Alternatively, DBT can maintain the original HSS offer, if it is higher. In the event that DBT issues a fresh offer, the appellant can accept or reject it. If the offer is rejected, the parties will engage in bilateral discussions in an attempt to resolve the Appeal and avoid escalation to the Independent Panel. During these discussions, DBT may consider making a revised offer.

In the event the parties are unable to come to an agreement within a reasonable amount of time, in appropriate cases, the Appeal may be referred to the Independent Panel. The Independent Panel is an impartial group of legal, forensic accountancy, medical and retail experts with the skills and experience to appraise Appeals.

The Independent Panel constituted for an Appeal will collectively make an assessment on the Appeal to determine a suitable financial redress sum. The Independent Panel’s decision is then provided to both parties. The final offer the appellant will receive from DBT will be the highest total offer, considering the Independent Panel’s assessment and DBT’s earlier offer. If the total offer is still lower than the highest offer the appellant received from the Post Office in its full assessment of their HSS claim, they can revert to that offer.

The final step in the process is exceptional review, conducted by the Independent Reviewer. If, after the conclusion of the Independent Panel process, the appellant (or DBT) considers there has been a manifest error, procedural irregularity or substantive error of principle in the Panel’s final assessment of the claim, or if the Panel’s final assessment is substantially inconsistent with the HSSA Guidance and Principles, an application for reference to the Independent Reviewer can be made.

In its response to Volume 1 of the Post Office Horizon IT Inquiry’s final report on 9 October 2025, DBT has confirmed it is considering the implementation of a new mechanism to allow HSS claimants who opted for the £75,000 Fixed Sum Offer to apply for permission to appeal their award. If an application for permission to appeal is successful, the HSS claimant will be able to make an application in HSSA to have their compensation offer reconsidered.

4.2 Observations

Dentons understands from data provided by DBT that, as at 30 September 2025:

• DBT has received 237 separate entity registrations, of which 224 have passed eligibility checks
• 156 claims have transferred from the HSS Dispute Resolution Process
• DBT has received all required information for 34 Appeals
• of those 34 Appeals, DBT has made offers on 6
• of those 6 offers, 1 has been accepted

No Appeals have progressed to the Independent Panel stage.

As with the introduction of any new process, there has been (and continues to be) an initial transition period whereby participants become familiar with the HSSA process and its operation. This inevitably means that the pace of the scheme is slower to begin with as teething issues are identified and resolved.

We are in touch regularly with certain appellants’ legal representatives (and Addleshaw Goddard) to discuss progress on Appeals and facilitate the resolution of any procedural issues arising on HSSA. We remain ready and willing to assist in any way we can.

4.3 HSSA data

HSSA data type	Position as at 30 September 2025
Total HSSA claims registered	237
Claims registered	13
Claims passed eligibility check	224
Total HSSA claims with offer made	6
Accepted	1
Claims for individual assessment, of which	0
At Panel stage	0
At Reviewer stage	0

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. ↩

6. See section in this report entitled Glossary of terms for GLO Scheme data for definition of the “full and final claims”. ↩

7. 431 claimants had received the full payment with a further 5 claimants awaiting payment. ↩

8. HSSA has been open for applications since the end of April 2025. ↩