Guidance

Network Transformation Programme investigation: terms of reference

Published 15 April 2026

1. Investigation purpose 

The Department for Business and Trade (DBT) has commissioned an independent investigation into the implementation of Post Office Limited’s (POL) Network Transformation Programme (NTP). The programme ran from 2010 to 2019, and this is the time period being covered by the investigation.

The investigation will be conducted by an independent legal team. More information about the team can be found in section 4.1. The investigation will receive support from DBT, POL and UK Government Investments (UKGI), in terms of obtaining documentary evidence and access to relevant individuals as potential witnesses. The legal team will seek to engage in detail with postmasters and postmaster representative groups.

The investigation will examine and establish whether the implementation involved any improper behaviour including, but not limited to, allegations made against POL and its representatives of:

• coercion
• bullying
• the provision of unregulated financial advice

The independent legal team will provide an assessment of the available evidence, as well as identify potential next steps in the light of that evidence. DBT will use this assessment to decide whether and, if so, what further action may be needed.

2. Structure and objectives  

2.1 Phase 1: evidence-gathering 

In phase 1, the independent legal team will gather and examine evidence from:  

• postmasters 
• postmaster representative groups 
• POL
• DBT 
• UKGI
• any other relevant stakeholders related to how POL’s NTP was conducted 

The evidence gathering should also include oral and written testimony from some of the postmasters affected by the NTP.  

2.2 Phase 2: analysis 

The independent legal team will analyse the evidence to establish whether POL or its representatives engaged in improper behaviour aimed at forcing postmasters onto new contracts during the implementation of NTP. 

The independent legal team will also establish whether POL or its representatives provided unregulated financial advice.  

If there is evidence of improper behaviour, the independent legal team will identify and estimate the effect that this may have had on postmasters. 

2.3 Phase 3: assessment 

The independent legal team will provide an assessment of the available evidence, as well as identify potential next steps in the light of that evidence. DBT will use this assessment to decide whether further action may be needed and, if so, what that further action should be.

3. Scope of investigation 

3.1 Areas of concern to be examined 

The independent legal team will examine the following 5 areas.  

Clarity of contractual changes 

This means examining whether the transition from fixed to variable remuneration and its implications were set out clearly and transparently to postmasters.  

Implementation practices  

This will involve investigating the conduct of POL and its representatives and any allegations of improper behaviour. It will also include investigating the conduct of POL representatives when engaging with postmasters (including ‘hard-to-place’ postmasters) about signing of new contracts, in the context of financial incentives offered to them by POL.

‘Hard-to-place’ postmasters are postmasters who wished to leave the Post Office network but for whom no suitable replacement operator could be found. They remained in post because, under earlier rules, they could not receive a leaver’s payment until a replacement was secured. 

Financial advice 

This will entail examining information given to postmasters and allegations of unregulated financial advice being provided by POL and its representatives.

Misrepresentation  

This means investigating what was said to postmasters about financial advantages linked to the new contracts being offered by POL, whether this constituted misrepresentation and, if so, the character or nature of that misrepresentation.

Impact assessment  

If improper behaviour is found, the independent legal team will identify and estimate the effect that this may have had on postmasters (for example, financial impacts and mental health effects).

3.2 Exclusions 

The independent legal team will not investigate any matters relating to the Horizon IT system, which is already covered by a separate statutory inquiry, or any previous IT systems.

Broader POL operations not directly linked to NTP, including wider questions concerning the governance structure between DBT and POL, will also not be included in the investigation. 

4. Methodology 

4.1 Investigation model 

The investigation will be conducted by an independent legal team, led by Adam Tolley King’s Counsel (KC). 

If any secretariat or other support from officials in DBT is required, they will work under the direction of the KC lead and in line with the Civil Service Code. 

4.2 How to get involved

If you have been affected by the Post Office’s NTP and would like to submit evidence, please email it to: NTPInvestigation@businessandtrade.gov.uk.

If you do not have access to or do not wish to use email, please submit evidence by writing to:

NTP Investigation
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

4.3 Data selection methodology and storage 

In all cases, evidence will be collated and reviewed by the KC and their team based on its relevance to the implementation of the NTP. 

Any data gathered and processed will be kept on a secure platform in line with the General Data Protection Regulation (GDPR).

4.4 Publication, confidentiality and anonymity

The final report of the investigation will be published.

While the investigation is ongoing, evidence submitted will be treated as confidential. It will only be used for the investigation for the purposes set out in the Privacy Notice, pending publication of the final report.

Evidence submitted may be referred to in the published final report. Names and identifiable personal details will be anonymised so far as reasonably possible. After the investigation has concluded, the evidence will be retained by DBT to inform future policy making.

Requests for anonymity during the investigation itself will be considered on a case by case basis, but it is unlikely to be possible for the investigation to rely on any evidence which is provided on the basis of a request for anonymity.

Anyone who submits evidence to the investigation can also request at any point that their evidence is not retained by DBT following the investigation. Please see the privacy notice for further information.

4.5 Disclosure and co-operation

If at any time the investigation lead, Adam Tolley KC, is not satisfied with the level of co-operation (including as to the disclosure of evidence) by POL, DBT or UKGI, he can write to the minister with responsibility for the Post Office to raise this.

5. Expected evidence (non-exhaustive) 

Oral testimonies and written statements will be provided by postmasters and other affected parties to the independent investigation team.

The evidence will be gathered directly through the investigation and will also include evidence held by the postmaster representative groups, legal representatives, DBT and POL. 

DBT expects the independent legal team to gather and use: 

• correspondence between the National Federation of SubPostmasters (NFSP), government ministers and senior officials 
• correspondence between POL and government, including DBT, UKGI and their predecessor bodies  
• evidence from other departments and government bodies if deemed relevant 
• papers, minutes and any accompanying information or annexes from POL board meetings from 2010 to 2019, any other POL meetings established to monitor progress or steer work related to NTP and any relevant meetings between POL and government 
• scripts for field change advisors, who were specialized staff responsible for delivering face-to-face support to postmasters, managing the conversion of branches into new operating models (such as ‘Main’ or ‘Local’ models) and facilitating the integration of post office services within retail environments 
• any information packs or standard documentation made available to postmasters, including any frequently asked questions (FAQ) documents or modelling available on financial impacts that postmasters could use 
• POL reporting systems for risk and issue management, where NTP is mentioned
• data on financial outcomes for transitioned and non-transitioned branches (these will only to be reviewed if improper behaviour is found or suspected) 

Evidence should also include written summaries from POL about:  

• how Network Transformation was implemented, how decisions were made and how progress was monitored
• what the key decision points were in the programme’s lifecycle (for example its set up, funding from government, initial implementation, the decision to make conversion mandatory, the change to the exit package offered and programme closure)  

Evidence should include oral testimonies and written statements from relevant POL employees and representatives, including: 

• senior decision-making and operational leads (senior responsible officer or equivalent) responsible for NTP from 2010 to 2019 
• area managers and field change advisors (if different to the leads)