Horizon Shortfall Scheme Appeals process guidance and principles
Guidance for making an appeal under the Horizon Shortfall Scheme Appeals (HSSA) process and the underlying principles of how cases are assessed.
Introduction
The Post Office established the Horizon Shortfall Scheme (HSS) to address past issues regarding its point-of-sale accounting software system, Horizon. The purpose of that scheme is for current and former postmasters who, in good faith, believe they may have been affected by shortfalls which relate to previous versions of Horizon (sometimes referred to as Legacy Horizon, Horizon Online or HNG-X) (Horizon Shortfalls). The scheme does not deal with issues arising with the current version of Horizon (HNG-A, sometimes referred to as the ‘Branch Technology Upgrade’).
In September 2024, the government announced that it would be introducing an independent Horizon Shortfall Scheme Appeals (HSSA) process. This is to ensure that HSS claimants have the full opportunity to receive fair redress and reflects a recommendation from the Horizon Compensation Advisory Board.
Department for Business and Trade (DBT) will deliver the appeals process. The central goal, and the overarching principle, of the process is to deliver compensation to eligible 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 the Post Office.
This page sets out the underlying principles that will govern the assessment of any appeals under the process and provides guidance in relation to such appeals.
Eligibility
To be eligible for the HSSA process you must be eligible for HSS and meet one of the following criteria. You must have either:
- settled your claim in the HSS without entering the Dispute Resolution Process (DRP)
- rejected your initial HSS offer without entering the DRP
- settled your claim in the DRP before mediation stage without legal advice funded by the Post Office, other than for reasonable allowances to consider your offer
- be within the DRP – with or without legal advice – but not have requested or be awaiting a mediation meeting, upon scheme opening
On October 9 2025, the government announced that those who accepted the £75,000 Fixed Sum Offer (FSO) will be able to seek permission to appeal to HSSA. This process is not available yet. Details on the permission to appeal criteria will be published on this page once the process opens.
If you have not yet submitted an HSS claim, or received an offer, read the HSS guidance on the Post Office website.
If you are currently in the Dispute Resolution Process (DRP), and you have not yet agreed to or arranged a mediation meeting, you or your lawyer will have been contacted and asked to decide whether to remain in the DRP or to transfer to Horizon Shortfall Scheme Appeals (HSSA). If you decide to remain in the DRP, you will not be eligible to transfer to HSSA.
HSSA is open to applications from all eligible postmasters. The following timescales in Table 1 will apply to registering and making an application to the HSSA process. We encourage you to make your appeal as soon as possible, after seeking legal advice.
Table 1
| Eligible group | Timescale |
|---|---|
| Settled your claim in the HSS without entering the DRP | You will have 3 months to make an application. The 3 months is from either the date of settling your HSS panel offer or from the date a letter is sent to you from the Post Office inviting you to apply to appeal, whichever is later. After this time you will not be able to launch an appeal. |
| Rejected your initial HSS offer without entering the DRP | You will have 3 months to make an application. The 3 months starts on either the date of rejecting your HSS panel offer or on 9 October 2025, whichever is later. After this time you will not be able to launch an appeal. If you wish to dispute your offer after this time you will need to move your case forwards with the HSS DRP. |
| Settled your claim in the DRP before mediation stage without legal advice funded by the Post Office, other than for reasonable allowances to consider your offer | You will have 3 months to make an application. For claims settled on or after 9 October 2025, you have 3 months to apply from the date of settling your claim in the HSS DRP. If you accepted your HSS DRP offer before 9 October 2025, you have until 9 January 2026 to apply. After this time, you will not be able to launch an appeal. |
| Within the DRP – with or without legal advice – but not have requested or be awaiting a mediation meeting, upon scheme opening | You will have 3 months to make an application. The 3 months starts on either the date of your invitation letter or 9 October 2025, whichever is later. After the 3 months you will no longer be eligible for HSSA and will remain within the DRP. |
Your lawyer will have to submit all relevant information and evidence related to your appeal within a specified timeframe following the date the Post Office’s disclosure is made available to them. We are currently discussing a suitable timeframe for this submission with claimant’s representatives. We will update this page once a position has been reached.
If for any reason there are issues with these timelines being met, contact hssappeals@businessandtrade.gov.uk to discuss further as soon as possible. DBT is willing to consider exceptions to these timeframes where there are reasonable extenuating circumstances that prevented you or your lawyer from submitting the information within the timeframe.
If DBT do not hear back from you or your lawyer after expiry of the above time periods, then your appeal will not be taken forward to assessment. DBT will write to you at this point to inform you of this, and you will not be able to enter HSSA.
You can apply 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. Note that you will need to provide proof of this legal relationship.
If you were a shareholder or a director of a company or a partner in a partnership which has ceased to exist, you can make an appeal as a linked individual. If appropriate, an offer will be made to you and any other shareholders and directors of the company or partners of the partnership, who may have a legitimate interest in that payment. It is your responsibility to seek an agreement with them as to who will be the recipient of the payment and how it should be split between yourselves. If the company or a partnership has ceased to exist, it will not be necessary to restore it except in a limited number of circumstances, for example, when the company was set up as a community interest company.
If you are unsure whether you are eligible for the HSSA process, contact hssappeals@businessandtrade.gov.uk.
You do not need to have any new information to submit an appeal, but DBT will accept any new information you wish to submit within the timescales set out in Table 1.
If you are participating in more than one redress scheme, the principle that you cannot claim twice for the same loss applies.
Approach to offers in HSSA
The process operates on a ‘best total offer’ principle. This means that by entering the scheme there is no risk of receiving less redress than the highest offer you received from the Post Office in its full assessment of your case on HSS (excluding the FSO).
The ‘best total offer’ approach compares the total offers on each scheme (HSS and HSSA). It does not compare individual heads of loss.
It is possible that DBT will reassess a particular head of loss and determine that a lower amount is appropriate than that offered by the Post Office on HSS. In some cases, the HSS Appeals total offer may be lower than the HSS total offer. If this happens, you can revert back to the HSS offer you received from the Post Office. In other cases, DBT’s offer may still be the ‘best total offer’ and will replace the HSS offer.
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.
There is a recent publication of what “full and fair” means in terms of redress. DBT will always look to apply the definition set out in that statement when assessing appeals and making HSSA offers.
To help postmasters and their representatives decide whether DRP or HSSA would be the best dispute process for their individual circumstances, read more about the main differences between the 2 processes.
Parties involved
The Horizon Compensation Advisory Board advises ministers on how best to manage delivery of the HSSA process. It will not have any role in individual cases, but will monitor the overall progress of the process, ensuring that it is working well and identifying any blockages.
DBT has appointed:
- Addleshaw Goddard as external legal advisors to advise DBT on individual cases
- Dentons as the Independent Panel and Reviewer Secretariat who will support the progress of disputed appeals and seek a final and fair settlement
Dentons (the ‘Secretariat’) will subcontract:
- an Independent Panel comprising legal, accounting, medical and retail experts (the ‘Independent Panel’). The composition of the Independent Panel appointed in respect of individual claims will depend on the nature of the claim. See the ‘Referral to Independent Panel’ section for an explanation as to the role of the Independent Panel.
- a ‘Reviewer’ – an independent senior lawyer, expected to be a retired or semi-retired judge or King’s Counsel (KC), who will undertake exceptional review of cases. See the ‘Review process’ section for an explanation as to the role of the Reviewer. The person will be different from the independent person that advises on the HSS.
Overview of HSSA process
How to apply
If you are not currently legally represented, you are strongly urged to engage lawyers as soon as possible. Certain legal firms have agreed not to make any charges directly to postmasters for work on the entire HSSA process: they will be paid by government at rates agreed with them, which are set out in a tariff of reasonable costs. Other firms can access the same rates. Firms should contact DBT at hssappeals@businessandtrade.gov.uk to discuss this further and to carry out appropriate assurance checks. This legal advice will be funded by DBT and will not be deducted from any redress you receive.
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. Firms instructed on this basis will not be paid.
If you are eligible and wish to appeal against your HSS redress offer, your lawyer should complete the registration form.
This 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.
ID verification and eligibility check
When you submit an HSSA registration form, your lawyer will need to provide DBT with:
- 1 piece of photo identification
- 2 proof of address documents
If you are unrepresented, 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 your identity has been verified, DBT will use the information provided on the registration form to check with Post Office that you meet the eligibility criteria for entering HSSA. DBT will inform your lawyer whether you are eligible for HSSA and ask for confirmation that you wish to continue with the process.
If you are deemed to be ineligible, but you believe you meet the criteria, then your lawyer should email hssappeals@businessandtrade.gov.uk asking for an independent person to review this decision.
Once eligibility has been confirmed, you will be transferred over to HSSA and DBT will request information relating to your claim by a secure method from the Post Office.
DBT will minimise the amount of information that postmasters need to submit – so you will not need to resubmit any information that has already been submitted to Post Office. Secure disclosure of information relating to your claim from Post Office is in line with our data sharing agreement. A privacy statement will also be sent to you.
The information received will be made available to you and your lawyer. For eligible postmasters not already within DRP, your lawyer will then be invited to fill out a full application form.
Submission of an appeal
Your lawyer will submit your full application form. This 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 and submit your own application form.
Your lawyer will need to confirm if you do not wish to submit any additional evidence as part of your application.
All eligible postmasters, including those transferring from the HSS DRP, will need to fill out an application form to explain why you wish to appeal your offer or settlement. You can appeal:
- the whole offer or settlement
- a singular head of loss
- multiple heads of loss
Once your eligibility is confirmed, DBT will provide an application form for your legal representative to complete.
You are requested to provide all relevant information to support your appeal, or confirm if you do not wish to submit any additional evidence, within the timescales set out in Table 1. If DBT do not hear back from you or your lawyer after expiry of this period, then your appeal will not be taken forward to assessment. DBT will write to you at this point to inform you of this, and you will not be able to re-enter DRP or HSSA.
Assessment of your claim
For consistency, the main principles and types of loss within the HSS Consequential Loss Principles and Guidance (on the Post Office website) will also be applied to HSSA. They set out the underlying principles that will govern the assessment of any appeals for Consequential Loss under the process.
In addition to the application of these principles the process will also consider what is fair in all the circumstances.
Appeals will initially be considered by caseworkers in DBT, with advice from Addleshaw Goddard as the contracted legal casework adviser. Your lawyer will receive regular updates regarding your claim via DBT.
DBT may ask your lawyer for further information which would help the assessment of your appeal. However, DBT expect that these requests will be minimal, as cases will have already been assessed. Where new documentation relevant to a claim cannot be obtained without a fee, for example where current property valuations or forensic accountancy analysis is required, your lawyer may request that DBT reimburse the reasonable costs of obtaining that new documentation as per the HSSA tariff of reasonable legal costs. DBT will not reimburse costs that are not pre-approved.
DBT has also set out further information and guidance for expert reports, which will ensure that any documentation relevant to a claim provides the appropriate evidence to support your appeal.
DBT will make a fresh assessment of your case. If that assessment concludes that your HSS offer was too low, DBT will send a fresh offer to your lawyer with an explanation, including the reasons for any difference from the amount claimed.
DBT may make a higher offer than your original HSS offer. Alternatively, you will be able to revert to the HSS offer if it remains the highest total offer after DBT’s assessment. Refer to the ‘Approach to offers in HSSA’ section above for more information.
DBT aims to issue such a response in 90% of cases within 40 working days of submission of a substantially complete appeal (or your full response to any request for further information).
If you wish to dispute part or all of any fresh DBT offer, your lawyer should write to DBT to explain why as soon as possible. DBT will then carry out settlement discussions directly with your lawyer in an attempt to resolve the disagreement and avoid escalation. During these discussions, DBT will consider whether a revised offer could be made in accordance with these guidance and principles.
Referral to Independent Panel
If those settlement discussions do not lead to agreement within a reasonable amount of time – and no more than 2 months – the Secretariat will have discretion as to whether a case should be referred to the Independent Panel.
The Secretariat is unlikely to refer a case to the Independent Panel in any of the following circumstances:
- if there is not a substantial difference between the last claim and offer exchanged by the parties
- further evidence is required
- there is no issue on which it would be helpful to obtain the views of the Independent Panel, for example, if the only areas of disagreement between the parties relate to a principle which the Independent Panel has already determined
If DBT’s offer is lower than the offer you received on HSS, you will have an automatic right to refer your case to the Panel.
The Secretariat will put a case to the Independent Panel for assessment.
If your claim is referred to the Independent Panel, you will have the option to make an oral statement, limited to one hour, to the Independent Panel before it makes its decision. The Independent Panel may ask you further questions in relation to your claim during the oral statement session.
The Independent Panel will apply judgement to individual cases, guided by considerations of fairness and legal principles. It may recommend a specific award or request further evidence or analysis.
If the Independent Panel considers that an eligible claim requires further evidence to allow it to recommend an outcome, the Independent Panel can recommend further evidence is sought in accordance with the procedure set out in the terms of reference. The Independent Panel’s binding assessment – including its reasoning – will be recorded in writing and made available to you and your lawyer.
There will be an informal process where DBT can ask the Panel for clarification before making its offer. This will only be used where DBT believes an award has been made for which it does not have funding powers for. For example, where DBT believes there has been a calculation error, an award which constitutes double recovery or an award which is outside the scope of the scheme. This clarification process will only be used in limited circumstances.
Once the Panel assessment and the clarification process (if needed) is complete, the highest total offer will represent the final offer in the scheme. If the total offer resulting from the Panel assessment is still lower than the highest offer you received from the Post Office in its full assessment of your claim on HSS, then you can still revert back to the higher offer offered by Post Office.
Review process
You can apply to refer your case to the Reviewer for exceptional review if you have arguable grounds that either:
- there has been a manifest error, procedural irregularity or substantive error of principle in the Independent Panel’s assessment of the appeal
- the Independent Panel’s assessment is substantially inconsistent with the Guidance and Principles (the ‘Review Criteria’)
If you are not currently legally represented, you are strongly urged to engage lawyers as soon as possible.
DBT will have the same right to seek exceptional review of a case. This power would allow DBT to challenge the Independent Panel’s assessment if it believed that the Independent Panel had departed from the established framework for assessing appeals which is intended to achieve consistency and fairness when making offers to postmasters.
Any such application must be made within 15 working days of the communication of the Independent Panel’s assessment. Any case submitted for the review should be made using the form ‘Template Review Application’ provided by the Secretariat.
If the Reviewer concludes that a prima facie case exists and there is sufficient evidence in support of a review, the Secretariat will notify you and DBT accordingly and will invite you and DBT to prepare written submissions. The review application will then be referred to the Reviewer for consideration.
The Reviewer will consider the Review Application alongside any comments on it which they may invite from the Independent Panel and the parties’ written submissions.
The Reviewer may uphold the Independent Panel’s assessment or, in the event of finding that the review criteria apply, make a revised award of compensation. The Reviewer’s decision will be sent to you and your lawyer and to DBT and Addleshaw Goddard, together with a written explanation. The Reviewer will aim to provide their decision within 2 weeks of receiving instruction from the Secretariat to review the appeal. The Reviewer’s finding will be the final stage to determine your appeal. DBT will not consider any further offers or changes to the offer after this.
Acceptance of the offer
If your DBT offer is higher than your HSS offer, DBT will pay you the amount of redress that is offered by DBT (or, where necessary, the Independent Panel or the Reviewer). This will happen once DBT has received your agreement to settle by way of a signed and returned offer letter.
DBT remains committed to making payment under those processes as quickly as possible.
Any previous payments already made by the Post Office for your HSS settlement will be deducted before the DBT payment is made.
Payments will be made directly to you where appropriate, after your payment details have been provided by you and verified by DBT.
Transparency of progress of the process
Information about the progress of the process will be published each month on the GOV.UK website. It will include statistics about the number of appeals submitted, offers made and acceptances, as well as the total amounts paid.
Taxation
No Income Tax, Capital Gains Tax, National Insurance contributions, Corporation Tax, or Inheritance Tax will be payable by any party in respect of any payment through the HSSA process. Interest applied to claims will not be subject to any tax deductions.
When calculating awards in HSSA, the amount of tax that would have been paid on relevant losses at the time will be factored into the award. This means that taxable heads of losses will be calculated net of tax.
These exemptions only apply to the HSSA process. For advice and guidance about taxation under the HSS, refer to the guidance published by Post Office.
When considering whether to transfer to the HSSA process you may wish to take legal advice about any implications of transferring.
Interest
If it is decided that you are due more redress, then compound interest will be applied in relation to shortfall claims at a standard rate of 3.45%. You do not need to calculate the interest in your application form. DBT will calculate the interest to every offer made.
Interest will only be paid for payments on which you have not previously had interest applied during your original HSS claim.
Additionally, if the decision is that that no further redress is due, compound interest will not apply.
Interest on specific heads of loss will be applied from the starting points in line with those currently used in HSS.
Bankruptcy and liquidation
All or part of the claim may pass to the relevant insolvency practitioner (IP) if:
- you have been made bankrupt or subject to an Individual Voluntary Arrangement (IVA)
- your claim is on behalf of a company or partnership which entered liquidation or administration
In this case, you should contact the relevant IP to find out whether they have any interest in the claim. If the IP does not have any interest in the claim, then you will need to provide a written letter from the IP disclaiming any interest in the claim before DBT will be able to consider it. If the IP has already provided a disclaimer in connection with the HSS claim, then it will not normally be necessary for them to provide a further disclaimer for HSSA.
If the IP does have an interest in the claim, then it will be for them to conduct any appeal to the HSSA and they will receive any award in the first instance.
Further information
If you have a query or need more information you can email the HSSA team hssappeals@businessandtrade.gov.uk.
Updates to this page
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Guidance updated to reflect the government announcement on 9 October 2025 that those who accepted the £75,000 Fixed Sum Offer (FSO) will be able to seek permission to appeal to HSSA. Information has been added to the HSSA application timescales table, the approach to offers in HSSA section, the submission of an appeal section, the referral to independent panel section, the taxation section, and the bankruptcy and liquidation section.
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'Eligibility’ section updated to signpost users to ‘Main differences between the Dispute Resolution Process (DRP) and HSS Appeals process’ page.
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'Eligibility' section updated to indicate that Horizon Shortfall Scheme Appeals is now open to all eligible postmasters. Timescale in table 1 amended to clarify that 'May 2025' refers to '31 May 2025'. 'Review process' section updated to clarify criteria for applying to refer a case for exceptional review.
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'Eligibility' section updated to remove guidance on waivers which is misleading.
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First published.