Guidance

Horizon Shortfall Scheme: independent Senior Lawyer scope of work

Published 16 December 2025

Appointment of an independent Senior Lawyer (ISL) 

In Volume 1 of the Horizon IT Inquiry report, the Inquiry Chairman recommended (recommendation 6) that a suitably qualified senior lawyer be appointed to the Horizon Shortfall Scheme (HSS).

The independent Senior Lawyer (ISL) will be appointed by the ISL Secretariat, Dentons.

We expect that the ISL will take on a high-level advisory role within the HSS. They will provide input into complex issues which may arise in the HSS.

Recommendation 7 of the Post Office Horizon IT Inquiry confirms that the appointed person will be given appropriate powers to ensure this can happen.

The ISL will not duplicate any existing roles undertaken within the HSS.

They will not conduct reviews of individual cases, except for anonymised case reviews described in the ‘Anonymised case reviews’ section.

All powers granted to the ISL shall be limited by the scheme terms of reference. The ISL will not be permitted to take any step or act contrary to those terms of reference.

Rights of applicants to alternative dispute resolution processes

The ISL is being appointed to facilitate the resolution of scheme-wide issues which may arise in the HSS. The existence of the ISL does not deprive applicants of their right to issue a court claim or agree on an alternative dispute resolution process should they wish to.

All available routes to redress remain open to HSS applicants, including through the Horizon Shortfall Scheme Appeals (HSSA) process if applicants are eligible.

Role of the ISL

Identifying scheme-wide issues

The ISL will provide directions as necessary to the Post Office to ensure their actions are consistent with the terms of the HSS. This includes ensuring the independence of the independent panel.

The ISL will also investigate complex issues. Where required, they will also investigate certain types of cases to determine whether the management of the cases on a scheme-wide basis is consistent with the goals of full, fair, and prompt redress.

If the ISL identifies any issues in respect of a particular type of case, they will raise these to ensure they are rectified. The aim will be to ensure full, fair, and prompt redress within the HSS and, as far as possible, across the wider Horizon redress schemes.

This will include the overall progress of cases within the scheme’s Dispute Resolution Process (DRP) and any issues negatively affecting the pace of claims in the DRP.

Reporting on investigations

The ISL will publish a document on GOV.UK following each investigation. The reports will be found on the scheme’s collection page. Each report will also be sent to those who raised relevant issues with the ISL.

More information about how to raise issues for investigation can be found in the ‘Referral and procedure’ section.

The report will:

• outline the issues and, where relevant, classes of cases investigated
• detail the representations received
• identify any ‘lessons learned’ from the ISL’s assessment
• explain the conclusions reached and directions given by the ISL

Before producing each report, the ISL will be encouraged to speak with other independent senior lawyers engaged on other Horizon redress schemes. The ISL will then be able to incorporate any relevant reflections into their report.

Advising on eligibility, due diligence and late applications

The ISL may advise:

• if there are any questions relating to the interpretation of the eligibility criteria applicable to HSS applicants
• the Department for Business and Trade (DBT) on their approach to carrying out due diligence on the Post Office
• on the approach to late applications to the HSS

Advising on other issues

The ISL will also advise on scheme-wide issues raised by legal representatives. Anyone can raise an issue with the ISL as explained in the ‘Referral and procedure’ section.

Recommending amendments to the scheme

The ISL can recommend amendments to the scheme’s principles when they consider the amendments necessary to achieve full, fair and prompt redress.

Any decisions and recommendations issued by the ISL will be binding to the Post Office.

What the ISL will not do

The ISL will not make findings or comments on the merits of individual cases.

Applicants will not have the right to refer their cases to the ISL in any circumstances.

The ISL will not have any power to revise panel assessments, settlement offers or agreements in any individual case.

Anonymised case reviews

While the ISL will not make findings on individual cases, the ISL can conduct a review of a number of anonymised cases to strengthen their understanding of scheme-wide issues.

The number of anonymised cases required for review is to be decided by the ISL. The Post Office will provide the anonymised cases at the ISL’s request.

Referral and procedure

Anyone can contact the ISL about scheme-wide issues within HSS. To do so, email hss.islsecretariat@dentons.com.

When contacting the ISL, include:

• a short summary of the issue you wish to raise
• the HSS principles, policies or criteria you would like the ISL to look at
• any relevant correspondence or supporting documents
• the outcome you want from the ISL

The ISL will only look at issues that affect the scheme as a whole. The ISL cannot comment on or decide the merits of individual cases.

What happens after someone raise an issue

Once they receive an email, the ISL Secretariat will review everything submitted. They will consult with the ISL to determine if there is a scheme-wide issue to be considered.

If they determine that there is a scheme-wide issue, they will contact those potentially affected by the issue (relevant parties). This can include applicants’ legal representatives, the Post Office and DBT. It will not include applicants that are not legally represented.

The ISL Secretariat will send relevant parties a copy of the original email raising the issue.

The ISL Secretariat will invite relevant parties to email:

• a concise summary of their position, relating to the issue
• any additional relevant correspondence and supporting documents

All the emails, correspondence and documents received from each relevant party will be shared with:

• whoever raised the issue
• the other relevant parties

The ISL will consider all the written information and make a recommendation or decision. They will only hold a hearing in exceptional circumstances and at the ISL’s discretion.

If the ISL requires further information, the ISL will communicate this in writing.

The ISL’s recommendations or decisions will be binding on the Post Office, and they will be documented in writing by the ISL.

Independence

The ISL is independent of the Post Office, DBT and HSS applicants.

The ISL is also neutral and impartial and does not owe any liability to any party, in the scheme or otherwise.

The ISL’s appointment is of significant public importance in ensuring the fair and efficient conduct of the HSS.

While the ISL is not strictly speaking a public office holder, the ISL will throughout their appointment uphold the Seven Principles of Public Life: selflessness, integrity, objectivity, accountability, openness, honesty, and leadership.