Independent report

Special Representative on UK victims of Qadhafi-sponsored IRA terrorism: terms of reference

Published 20 October 2025

1. On 6 March, the Foreign Secretary appointed William Shawcross as his Special Representative on UK victims of Qadhafi-sponsored IRA terrorism (SR). The following sets out further detail on the nature of this role.

A. Scoping exercise

2. The SR should undertake an initial scoping exercise to inform the next stage of his work, below. This should involve:

• consultation with relevant UK government departments in order to inform himself about the potential policy, legal and technical challenges, policy cross-over, and political sensitivities of subsequent stages. Relevant departments include the Foreign and Commonwealth Office (FCO); Ministry of Defence (MOD); Northern Ireland Office (NIO); HM Treasury (HMT); Home Office (HO); Ministry of Justice (MoJ), including the Criminal Injuries Compensation Authority (CICA); Cabinet Office (CO); No.10; Security and Intelligence Agencies (SIA) and the Police
• meeting with victims’ groups, victims’ representatives and parliamentarians in order to gather information regarding the numbers of victims and different types of loss suffered, their views on the purpose(s) to be served by compensation and their desired outcomes
• investigating the feasibility of calculating a precise number of people affected and the amount of compensation due to them from the Libyan government
• considering precedents for compensation payments by third parties (i.e. parties that have assisted terrorist acts, but not directed or undertaken them) and the nature of compensation arrangements already reached with Libya
• considering any potential negative impacts on victims that might arise and how these might best be managed, including by promoting a clear understanding of the purposes and limits of the SR’s work and its focus on providing advice to the Foreign Secretary

3. The SR will submit an internal report on the outcome of this scoping phase to the Foreign Secretary within six months of agreement of these terms of reference. The Foreign Secretary, following agreement with relevant government departments, will decide whether to make any public announcement at this stage, including whether to publish any elements of the SR’s report and/or to make them available to any stakeholders.

B. Potential review

4. Upon the successful completion of the scoping phase, the Foreign Secretary will consider the precise terms of reference and timescale of the review phase, following consultation with other government departments.

5. The decision to proceed to the review and its objectives will be subject to the outcome of the scoping phase but the SR may, potentially, be asked to:

• assess the viability of establishing the compensation for which the Libyan government is liable according to the SR’s findings. This could incorporate:
  • an assessment of the number of people who might be eligible for compensation, drawing on best practice under other compensation programmes
  • consideration of the legal liability of the Libyan government
  • an assessment of the options for compensation due to victims from the Libyan government, and, in the case of monetary compensation, an appropriate amount
• provide any comments on the difficulties of establishing metrics including: the number of people affected, the sum of compensation, and the legal liability of the Libyan government
• abide by the principles of existing UK government policy, including the UK government’s position on non-espousal of victims’ claims

C. Next steps

6. Following successful completion of the review phase, the Foreign Secretary would take a view on next steps in consultation with other government departments. This would inform current and ongoing lobbying by Ministers and officials to facilitate the claims of the British victims of Qadhafi-sponsored IRA terrorism.

7. Any consideration of direct engagement of the Libyan government by the SR at this stage would be agreed in advance with the SR and have to take into account the likely impact on the wider bilateral relationship, as well as legal constraints flowing from the UK government position that it does not formally espouse the claims of the victims in a state-to-state negotiation.

General arrangements and principles for all phases

8. Resources: In order to be effective, the SR will require:

• access to relevant FCO records
• the ability to engage with (but not instruct) other government departments on request
• the ability to engage with contacts outside the UK government on request
• the active support and cooperation of victims’ representatives and MPs in providing and, where appropriate, collating information
• support from one external consultant (part-time) and one civil servant (part-time) funded by the FCO
• per diem and travel budget funded by the FCO
• desk space, as required

9. Independence: the SR is expected to carry out his role independently within the agreed terms of reference. The SR’s conclusions and recommendations will not represent government policy but will be considered by the Foreign Secretary.

10. Previous UK Government Activity: The SR’s role should be forward-looking; the SR should not draw conclusions about previous UK government activity in this area.

11. Contacts: The SR will need to make contacts in order to gather information relevant to his objectives, including but not limited to the following groups: FCO, MOD, NIO, HMT, HO, MoJ (including CICA), CO, No.10, SIA, Police, MPs (including All-party parliamentary groups), victims’ groups, and the US and Libyan governments.

12. Engagement with government departments: It is envisaged that the SR will engage with government departments by request. This will be in order to gather information relevant to his objectives. The SR should not comment on, nor seek to influence the work of government departments.

13. Reporting: The SR will be accountable to the Foreign Secretary. The Foreign Secretary will receive the requested reports, which will be internal. The Foreign Secretary will decide on next steps after each phase, seeking cross-Whitehall agreement including that of all relevant Minsters.

14. Disclosure of Data: FCO will be responsible for the handling of data generated by the SR and will agree appropriate protocols with other departments and agencies to ensure any sensitivities are managed appropriately. At the end of the SR’s work data and information generated will be considered for transfer to The National Archive, with personal data protected/anonymised as appropriate. The SR should not independently share details of his findings with non-governmental parties.