Guidance

Proposed fixed sum offer permission to appeal: process guide 

Published 20 May 2026

The Fixed Sum Offer Process is not yet open for applications. Please do not submit any documentation or registrations until the process is live

Introduction

Recommendation 9 of Volume 1 of the Post Office Horizon IT Inquiry’s final report advised that postmasters who previously accepted the Horizon Shortfall Scheme (HSS) Fixed Sum Offer (FSO) “should be afforded the opportunity to appeal against their acceptance of such an offer if they are granted permission to do so” by an independent person. 

If you accepted the £75,000 FSO through the HSS, the FSO Permission to appeal process allows you to request permission to have your case reconsidered through the independent Horizon Shortfall Scheme Appeals (HSS Appeals) process, offering an impartial review mechanism for claims which were potentially undervalued. You can only have your claim reconsidered in the HSS Appeals process if you are granted permission through the Permission to Appeal process (outlined in this guidance).

You will be granted permission to appeal if your case meets the “threshold test” by satisfying an assessor that there is a real prospect that taking the FSO amount of £75,000 resulted in an under-settlement of your claim. For example, you may not have understood the full and fair value of your claim or what you could claim for. Examples of what may be considered an under-settlement can be found in the illustrative examples section of this guidance. 

If you are considering whether to apply for entry into HSS Appeals via the FSO Permission to Appeal process, we strongly encourage you to seek advice from a legal representative on whether you have a viable claim. The Department for Business and Trade (DBT) will fund reasonable legal fees for such advice. More information about how to obtain this legal advice can be found in this guidance.

This guide explains the principles, process and expectations governing the FSO Permission to Appeal process. It is intended to support you and your representatives to understand how the FSO Permission to Appeal process operates and how decisions are reached.

It also explains the basis on which decisions are made, including the threshold test and the roles of DBT, the supplier (an independent legal firm), and the independent assessors.  More information about all parties involved in the FSO Permission to Appeal process can be found in the parties involved section. The parties operate independently of DBT and the Post Office is not involved in this process beyond assisting with eligibility checks.

Eligibility

To be eligible for the FSO Permission to Appeal process you must be eligible for HSS. Additionally, you must: 

• have accepted and received the £75,000 FSO either in full or as a top-up of a previous HSS offer

• be seeking permission to appeal based on under-settlement – meaning you believe your claim would have been worth more than £75,000 had it been fully assessed

You will be deemed ineligible if one of the following applies:

• you previously entered HSS Appeals but later withdrew for any reason

• you received a fully assessed HSS offer after the HSSA was announced on 9 September 2024 and decided to revert to the FSO, with the benefit of legal advice

• you received a fully assessed HSS offer after the FSO Permission to Appeal Scheme was announced on 20 May, and decided to revert to the FSO with or without the benefit of legal advice

• you received a nil offer in the FSO process

If you are unsure whether you are eligible for the FSO Permission to Appeal process, we encourage you to speak to a legal representative who will be best placed to advise you on whether you should consider applying. You can also refer to the illustrative examples section for guidance on what may be considered under-settlement.

Personal representatives

You can apply for the FSO Permission to Appeal process on behalf of a postmaster if you have legal authority to act on their behalf - for example, if you are an executor, personal representative, attorney or deputy of the person on whose behalf you are making the application. Please note that you will need to provide proof of this legal relationship.

Directors and partnerships which no longer exist

If you were a director of a company or a partner in a partnership which held a contract with Post Office Limited and has ceased to exist, you can make an application as a linked individual. 

Timeline

The FSO Permission to Appeal process will open to registrations from postmasters later this year.

You will have:

• 3 months to register for the FSO Permission to Appeal process and complete ID verification and eligibility checks, starting either from the date on which the FSO Permission to Appeal process is launched or when you accepted a FSO offer, whichever is later

• a further 3 months to submit your full application for permission to appeal from the date that your eligibility has been confirmed

If, for any reason, there are issues with these timelines being met, please contact the individual handling your case to discuss further as soon as possible. An exception to these timeframes may be possible where there are circumstances that are unpredictable and/or unavoidable, directly affecting your ability to submit the registration form by the deadline.

If you or your legal representative do not provide a valid reason for the delay and the deadline is missed, your application for permission to appeal will not be considered. We will write to you at this point to inform you of this.

How to apply

If you are eligible and wish to appeal against your £75,000 HSS FSO, your lawyer should complete the registration form once the process has opened to applications.

The application form should then be emailed to hssappeals@businessandtrade.gov.uk, or sent by post to:

Horizon Shortfall Scheme Appeals

Post Office Team
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Only if you choose to represent yourself should you fill in your own registration form.

How your application will be considered

Permission to appeal will be granted where you can successfully demonstrate that the threshold test is met i.e. that there is a real prospect that settling for the £75,000 HSS FSO resulted in an under-settlement of your claim. 

There will be no requirement for you to provide additional evidence other than your written narrative to support your permission to appeal application, but you can if you want to. Additionally, the supplier and the independent assessors will be able to ask for further information or clarification of your narrative, where necessary. Expert reports will not be required, and the department will not provide funding for them.

If you accepted the FSO, you can ask the Post Office for details about the value of your shortfalls. However, the FSO Permission to Appeal process is designed to be light touch and does not require this information, so any delays in receiving it will not extend your application deadline. If your request is granted and you transfer to HSS Appeals, we will request full disclosure from the Post Office, including shortfall analysis, to thoroughly review your case.

For the avoidance of doubt, if your application to the FSO Permission to Appeal process is approved, you are not guaranteed any uplift in your award in the HSS Appeals process. The Permission to Appeal stage is a gateway to allow those with a real prospect of receiving a higher award on a full assessment into the HSS Appeals process. Meeting the threshold test at the Permission to Appeal stage does not mean that your full claim will be assessed over £75,000 in HSS Appeals.

The HSS Appeals process operates on a ‘best total offer’ principle with HSS. This means that if your application for permission to appeal is successful and your appeal is considered in HSS Appeals, there is no risk of receiving less redress than the £75,000 you have already received.  If the FSO Permission to Appeal Process concludes that your case may proceed to HSS Appeals and the outcome is an offer that is worth less than £75,000, you will keep the £75,000 previously paid to you (except in the unlikely event of actual fraud taking place).

Illustrative Examples

Some (non-exhaustive) examples of how a case may meet the threshold test. These are illustrative only:

• you lost earnings during the period you were suspended or had your contract with Post Office wrongfully terminated because of Horizon shortfalls, and these earnings total over £75,000 or, together with other losses covered by HSS, would bring the value of your claim to over £75,000

• as a result of Horizon shortfalls, you were forced to sell your home or business and lost value in that asset worth over £75,000. Or other losses covered by HSS in addition to this loss would bring the total value of your claim to over £75,000

• you suffered personal injury (for example, psychiatric harm) because of Horizon shortfalls and/or other consequential losses, and the general damages sought as a result total over £75,000 or, together with other losses covered by HSS, would bring the value of your claim to over £75,000

• you were unaware that interest could be applied to your claim, which would have taken your final award amount to over £75,000

These examples are intended to provide you with a guide only of what kind of losses might be considered in assessing whether there is a real prospect that the £75,000 resulted in an undervalue of your claim. They do not restrict the kind of narrative you can submit or the assessor’s discretion in considering your application for permission to appeal. 

To be clear, applications that outline lost earnings, loss of property, and/or personal injury suffered and/or other losses may not necessarily meet the threshold test for permission to appeal. The above are examples only. It will depend on the facts of each individual application for permission to appeal, and assessment of the applications is on a case-by-case basis.

Legal advice

You are encouraged to obtain independent legal advice to support you with your application. This will be funded by DBT.

Legal advice can help you:

• assess whether your claim has a real prospect of being fully assessed at over £75,000 (the threshold test)

• understand the heads of loss for which you can claim

• ensure all relevant losses are identified

• present your narrative clearly and accurately.

Certain legal firms have agreed not to make any charges directly to postmasters for work on the FSO Permission to Appeal process: they will be paid directly by DBT at rates agreed with them, which are set out in a tariff of reasonable costs. For the avoidance of doubt, these legal fees will not be deducted from any additional redress you may receive if you successfully enter the HSS Appeals process.

Other firms can access the same rates and, if they wish, can be listed in the tariff document. To do this, firms should contact DBT at hssappeals@businessandtrade.gov.uk to discuss further and to allow appropriate assurance checks to be undertaken. To be listed in the tariff, firms and sole practitioners must be regulated by either the Solicitors Regulation Authority (SRA), the Law Society of Scotland or the Law Society of Northern Ireland.

You should not engage any firm which asks you for money now or later, or which offers a ‘no-win, no-fee’, conditional fee or litigation funding agreement. 

DBT encourages you to access DBT-funded legal advice. However, legal representation is not mandatory, and you may choose to apply without representation if you wish. 

Engaging legal representation will not affect how the threshold test is applied. Applications submitted both with and without legal support will be assessed in the same fair, impartial, and proportionate manner.

You can also access the independent Information and Support Service (ISS) if you choose not to engage legal representation but would like some support through the FSO Permission to Appeal process.

The ISS can provide impartial information about the different processes and options available to you. The service can also support you through the application process and beyond, should you wish.

The ISS does not provide legal advice.

Stages of the FSO Permission to Appeal Process

Once you or your legal representative has submitted your registration form for the FSO Permission to Appeal process, the following stages will apply:

Stage 1: Verification 

Alongside your registration form, you or your legal representative will need to provide:

• 1 piece of photo identification

• 2 proof of address documents

If you do not have a legal representative, then you will also need to provide verification of your identity from a third-party counter signatory.

If you have legal authority to act on behalf of an applicant (see ‘Eligibility’ section), then you will also need to provide documentation to prove you are legally authorised to act, along with your 3 forms of ID.

See the full details of the ID and verification documentation required in different circumstances.

Once you have provided documentation to prove your identity we will carry out the ID verification process for the FSO Permission to Appeal process and let you know the outcome. 

The identity documentation required for the FSO Permission to Appeal process is the same as the HSS Appeals process. If you are granted permission to appeal, in most circumstances you will not need to re-verify your identity when your case is transferred to the HSS Appeals process.

Stage 2: Eligibility Check

The supplier will use the information provided on your registration form to check with Post Office that you meet the FSO Permission to Appeal process eligibility criteria (outlined above). The supplier will inform you or your legal representative whether you are eligible for the FSO Permission to Appeal process or not.

If you are deemed to be ineligible, but you believe you meet the criteria, then you or your legal representative can ask an Independent Assessor to review this decision (see Stage 4).

Stage 3: The Supplier’s Review

If you are deemed eligible, you or your legal representative will have 3 months from the date of confirmation of your eligibility to submit your application for permission to appeal, including your supporting narrative. The information to be included in the application form is outlined in more detail under ‘How to submit your application’.

A first review will be carried out by the supplier. The supplier will determine whether your claim meets the threshold test of having a real prospect of being fully assessed at over £75,000. 

At this point the supplier may:

• approve your application for permission to appeal, at which point it will be transferred into the HSS Appeals process

• reject your application for permission to appeal, at which point you or your legal representative can ask for the case to be referred to an independent assessor

• refer particularly complex or borderline cases to an independent assessor

Stage 4: independent assessor review

If your case is referred to an independent assessor, they will carry out a fresh assessment of your application for permission to appeal. If you are unsuccessful at the Eligibility Check stage (stage 2), you or your legal representative can also ask for your eligibility decision to be reviewed by an independent assessor. 

The independent assessor can request clarification of your narrative or additional information in relation to your case. This will only be sought where necessary, such as where an aspect of your narrative is missing or unclear, or otherwise requires further information for a decision to be made.

The Independent assessor can then:

• in the case of the eligibility check, confirm that you are eligible to submit your application for permission to appeal, or reject your application on the basis that you do not meet the eligibility criteria

• in the case of the FSO Permission to appeal process, approve your application if it meets the threshold test for permission to appeal or reject it if it does not

The independent assessor’s decisions will be binding in all cases.

How to submit your narrative form

Narrative form

Once the supplier has confirmed your eligibility for the FSO Permission to Appeal process, they will provide you or your legal representative with a narrative form. This will be a link to download a blank template form. However, if you are unable to access or download the template form, the supplier will send a hard copy by post to you upon request. 

Alongside your narrative form you must also sign a statement confirming that to the best of your knowledge and belief, the information provided in the narrative is accurate and truthful.

Narratives must:

• be clear, concise and no more than two pages. Longer narratives will be returned and will not be considered

• be on the template provided by the supplier, which includes formatting guidance

• identify the relevant heads of loss

• explain why those losses are likely to exceed the £75,000 FSO amount

• be signed by you and, if applicable, your legal representative

Head of loss refers to the type of loss that a postmaster may have suffered as a result of the Horizon IT scandal, and the subsequent compensation they claim through the HSS Appeals process. There is no exhaustive list of the types of loss that can be claimed. Certain examples are detailed in the HSS Consequential Loss Principles and Guidance which are also applied to HSSA.

Submission method

If you are unrepresented, you must submit the narrative form to the supplier. 

If you are represented, your legal advisor must upload the narrative forms to a secure platform, to which they will be given access once your registration form for permission to appeal has been transferred to the supplier and the supplier has deemed you eligible (see Stage 2).

We will provide further detail on where to send submissions and how to reference them when the process launches.

What happens if I am granted permission to appeal?

If you are successful, your case will be transferred into the HSS Appeals process and will be assessed according to the HSS Appeals guidance and principles. More information about HSS Appeals can be found in the guidance and principles. At that point, as your ID and eligibility will have already been confirmed in the FSO Permission to Appeal process, full disclosure of your case will be requested from Post Office straight away.

Once disclosure has been received, you or your legal representative will have 6 months to submit your full claim in HSS Appeals.

As outlined above, you will not necessarily receive a higher offer from HSS Appeals on a full assessment of your claim, but in line with the “total best offer principle”, you will retain the funds already received if your HSS Appeals assessment is less than the £75,000 FSO amount. The HSS Appeals full assessment is more thorough and detailed than the Permission to Appeal threshold test and the FSO process, including a full causation assessment for each head of loss. There is therefore no guarantee that being granted permission to appeal will result in any uplift to your claims on a full assessment in HSS Appeals. 

Parties involved in the process and its monitoring

Once identity and eligibility have been confirmed, applications for permission to appeal will be assessed by the supplier in the first instance. They will refer cases to the Independent Assessors where necessary, and provide overall administration of the process. 

If a case is deemed to be complex (meaning it is not clear whether it has a real prospect of being fully assessed at over £75,000), it will be passed to an independent assessor for assessment. The independent assessors will be members of the HSS Appeals independent panel. You can find more information about who makes up the Panel in the HSS Appeals guidance and principles. 

Lord Carnwath of Notting Hill, CVO, the Independent Reviewer on HSS Appeals, will also have an oversight role on the FSO Permission to Appeal process. He will be kept informed of issues and trends arising from the process but will not have a role in individual cases. 

The Horizon Compensation Advisory Board advises ministers generally on the overall progress and delivery of HSS Appeals, including delivery of the FSO Permission to Appeal process. It cannot consider individual cases, but will monitor the overall progress of the process, ensuring that it is working well.

Transparency of progress of the process

Information and statistics about the number of applications made to the FSO Permission to Appeal process and appeals granted will be published each month alongside main HSS Appeals statistics on the GOV.UK website. The names of applicants will remain confidential. 

Further information 

If you or your legal representative have a query or need more information you can email hssappeas@businessandtrade.gov.uk.