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a; GOV.UK
Guidance
How to apply to the Horizon Shortfall
Scheme Appeals (HSSA) process
Guidance for postmasters and their representatives on the
Horizon Shortfall Scheme Appeals process.
From: Department for Business and Trade
(/government/organisations/department-for-business-and-trade)
Published 8 April 2025
Last updated 10 April 2025 —
Contents
— Timelines for opening
— An independent HSS appeals process
— Who can make an appeal under HSSA
— Make an appeal under the HSSA process
— Scope of the appeals process
— Choose whether to make an appeal
— Withdrawing from HSSA
— Providing documents and evidence
— How appeals are assessed
— Length of appeal process
— Possible assessment outcomes
— Deductions from final payment
— Impact on tax and benefits
— Interest applied to HSSA compensation
— Further information
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Timelines for opening
The Department for Business and Trade (DBT) has written to potentially
eligible postmasters’ representatives (or where they are not represented,
directly to postmasters) currently in Post Office’s Dispute Resolution
Process (DRP), inviting them to transfer to HSSA.
We will open HSSA to all other eligible postmasters shortly after inviting
those currently in the DRP.
An independent HSS appeals process
At the time of HSSA opening to appeals, over 5,000 claimants have settled
their Horizon Shortfall Scheme (HSS) claim, and many will be satisfied with
the outcome. However, some individuals may not have been aware that
they could claim for certain losses or they did not receive legal support to
dispute their offer.
The government agrees that it is appropriate to implement the Horizon
Compensation Advisory Board’s June 2023 recommendation
(https://www.gov.uk/government/publications/horizon-compensation-advisory-board-
2023-meetings) that an independent appeals process should be introduced
for HSS. As advised by the board, HSSA’s focus is “assessing whether
settlements were fair based on the evidence provided, while allowing
consideration of elements of a claim which had been missed or not included
on the original form”.
DBT oversees the appeals process with the independent Horizon
Compensation Advisory Board (https://www.gov.uk/government/groups/horizon-
compensation-advisory-board) providing advice on its delivery. Although we
request the disclosure of information relating to your HSS case from Post
Office, they are not involved in any assessment of your appeal.
The board is made up of:
e 2 academic experts in the field of alternative dispute resolution and legal
ethics
e 2 parliamentarians recognised for their past involvement in pursuing the
resolution of the Horizon scandal
Who can make an appeal under HSSA
You are eligible for HSSA if you meet one of the following criteria:
e you have settled your claim in the HSS without entering the DRP
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e you have rejected your initial HSS offer without entering the DRP
¢ you have settled your claim in the DRP before mediation stage without
legal advice funded by Post Office, other than for reasonable allowances
to consider your offer
¢ you are within the DRP (with or without legal advice) but have not
requested or be awaiting a mediation meeting at the time of HSSA
opening
HSS claimants who have accepted the £75,000 fixed sum payment
If you have accepted the £75,000 Fixed Sum Offer, you are not eligible for
HSSA.
When a HSS claimant considers the Fixed Sum Offer, it is made clear to
them in their offer letter that accepting this would mean they cannot then
enter an appeals process.
This is because the Fixed Sum Offer is intended to be an option for
postmasters to settle their claim quickly and £75,000 is above the average
offer made by the independent HSS panel.
If you have not accepted the Fixed Sum Offer and you make an appeal in
HSSA, you will not be able to then accept the Fixed Sum Offer at a later
stage.
HSS claimants who decline the £75,000 fixed sum payment but get a
lower HSSA offer
If you decline the £75,000 fixed sum, you are not able to return to it ata
later stage, even if your HSSA offer is below the fixed sum amount.
However, if you disagree with your HSSA offer, you can reject it and enter
the HSSA panel and review stages. You can find more information about
this process in the How appeals are assessed section of this page.
Making an appeal on behalf of a deceased postmaster
You can make an appeal on behalf of the postmaster if they would have
been eligible and you can prove that you fulfil certain legal criteria, such as,
you are an executor of the person on whose behalf you are making the
appeal.
We will need to verify this at the start of the process, before the appeal can
progress to assessment.
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Find out more about the !D verification process
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
proving-your-identity).
Making an appeal on behalf of a former postmaster who is unable to
apply
You can make an appeal on behalf of the former postmaster if they are
eligible and you fulfil certain legal criteria, such as, you are a personal
representative, have power of attorney or are a deputy of the person on
whose behalf you are making the appeal.
We will need to verify this at the start of the process, before the appeal can
progress to assessment.
Find out more about the !D verification process
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
proving-your-identity).
Ineligible appeals
Eligibility for HSSA is determined by reference to the criteria in the HSSA
guidance and principles (https://www.gov.uk/guidance/horizon-shortfall-scheme-
appeals-process-guidance-and-principles). If your claim is found to be ineligible,
DBT will explain why this is the case.
If you are found to be ineligible, but you believe this decision is incorrect,
you can ask your lawyer to dispute it by emailing
hssappeals@businessandtrade.gov.uk, and asking for a review of the
decision. If you are not represented, you may dispute the decision yourself.
Make an appeal under the HSSA process
Get legal support to make your appeal
If you are thinking about whether to make an appeal, we strongly encourage
you to engage a lawyer to support you with the process. They can support
you in deciding whether to appeal, and then in making your appeal.
You should not engage any firm which asks you for money now or later, or
which offers a ‘no-win, no-fee’ agreement, a conditional fee or a litigation
funding agreement.
You should not engage any firm which does not agree to limit its fees to the
amounts set out in the tariff (https://www.gov.uk/government/publications/horizon-
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shortfall-scheme-appeals-hssa-tariff-of-reasonable-legal-costs). Any fees above
the tariff will not be paid by DBT and you will be responsible for paying
them.
DBT funds legal advice for postmasters in HSSA in accordance with a tariff
and the cost will not be taken from any redress you receive. Certain legal
firms have agreed to the tariff and not to charge postmasters for this work.
We strongly advise against making an appeal without seeking legal
representation.
How to make an appeal
Your legal representative should fill out the relevant registration form
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
hssappeals; GRO
Horizon Shortfall Scheme Appeals
Post Office Team
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
You should only fill in your own registration form if you do not have a
legal representative, as this could slow down the process. If you are
representing yourself, we recommend that you take time to read the
shortfall-scheme-appeals-process-guidance-and-principles) before making an
appeal.
Deadline for making an appeal in HSSA
We encourage you to make your appeal as soon as possible, after seeking
legal advice. The following timescales will apply depending on your situation
when making an appeal:
Eligible group Timescale
Settled your claim in the HSS You will have 9 months to make an
without entering the DRP. application, starting on either the date of
settling your HSS panel offer, or from
Eligible group
Rejected your initial HSS offer
without entering the DRP.
Settled your claim in the DRP
before mediation stage without
legal advice funded by Post
Office, other than for reasonable
allowances to consider your
offer.
Within the DRP — with or without
legal advice — but not have
requested or be awaiting a
mediation meeting, upon
scheme opening.
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Timescale
May 2025, whichever is later. After this
time you will not be able to launch an
appeal.
You will have 9 months to make an
application, starting on either the date of
rejecting your HSS panel offer, or from
May 2025, whichever is later. After this
time you will not be able to launch an
appeal.
You will have 9 months to make an
application, starting on either the date of
settling your claim in the HSS DRP, or
from May 2025, whichever is later. After
this time you will not be able to launch
an appeal.
You will have 9 months to make an
application, starting on the date of your
invitation letter, after which time you will
no longer be eligible for HSSA and will
remain within the DRP.
You, or your lawyers, must submit all relevant information and evidence
related to your appeal within these timeframes. If for any reason there are
If you register for HSSA and we do not hear back from you within these
timeframes, then we will assume that you no longer wish to proceed with
your appeal. If this situation occurs, we will not continue to process your
appeal.
Making a late appeal
Unfortunately, DBT will not be able to accept any HSSA appeals made after
these timescales.
Cost involved in making an appeal
There is no cost to make an appeal. There is also no risk of you losing any
money you were awarded in Post Office’s HSS or receiving less than you
were awarded by Post Office.
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The only possible cost that you could incur is if you engage in a legal firm
offering a ‘no-win, no-fee’ arrangement, a conditional fee or a litigation
funding agreement, or a firm which does not agree to limit its fees to the
amounts set out in the tariff (https://www.gov.uk/government/publications/horizon-
shortfall-scheme-appeals-hssa-tariff-of-reasonable-legal-costs).
As outlined, we recommend against engaging such firms.
Scope of the appeals process
Shortfalls related to previous versions of Horizon
HSSA is designed to address shortfalls related to previous versions of
Horizon (sometimes referred to as Legacy Horizon, Horizon Online or HNG-
X).
If you have experienced a more recent discrepancy and have concerns or
queries about the way in which it was or is being resolved, contact Post
Office directly at casereviewteam, :
If you experience an operational issue when using the current version of
Horizon, please report it to Post Office Branch Support Centre.
Claims for distress, ill-health and financial losses caused by shortfall
repayment
You may appeal your award for all the losses claimed in your original HSS
claim.
Additionally, if you believe you have suffered any further losses not claimed
in your original HSS application, these can also be considered in HSSA.
Your legal representative will be able to advise you about any other losses
you may be able to claim.
Guidance about what consequential losses you may be able to claim can be
found in the HSSA guidance and principles
(https://www.gov.uk/guidance/horizon-shortfall-scheme-appeals-process-guidance-
You should provide as much information and evidence as you can in your
appeal about any further losses you want to claim.
Choose whether to make an appeal
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If you are content with your HSS settlement, you are under no obligation to
appeal it. The choice is entirely yours.
Transferring from DRP to HSSA
You do not have to transfer from DRP to HSSA. We encourage you to make
the decision that is best for you.
However, it is important to note that if you transfer from DRP to HSSA, you
will not then be able to return to DRP.
We encourage you to discuss this decision with your legal representative.
As per the HSSA tariff of reasonable legal costs
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
hssa-tariff-of-reasonable-legal-costs), DBT will fund the costs of legal advice to
support with this decision.
Withdrawing from HSSA
You can withdraw. vour appeal at any. time by emailing
hssappealg GRO ‘or by writing to:
Horizon Shortfall Scheme Appeals
Post Office Team
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
If you do request to withdraw your appeal, we will discuss this with you, and
what it will mean for your appeal going forward.
If you withdraw from HSSA, you will not be able to re-enter it at a later
stage. You are also unable to transfer to Post Office’s DRP if you have
entered HSSA.
Providing documents and evidence
Although we are happy to accept any new or additional information that you
want to submit for us to consider as part of your case, you do not need any
new evidence to make an appeal.
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DBT aims to minimise the burden on postmasters in HSSA when it comes to
submitting evidence.
You do not need to resubmit any information that has already been
submitted as part of your initial HSS claim, as we request this directly from
Post Office.
You can upload further supporting material should you deem it necessary,
and if you are making any new claims in your appeal, we would encourage
you to provide as much detail and evidence as you can.
You may be required to provide additional information to help progress your
appeal at the assessment stage. DBT will only ask for further information
where this is considered reasonable or necessary to properly assess your
claim.
Getting expert advice to support your appeal
If your appeal involves losses which require technical or specialist
knowledge to assess, you and your legal representative may wish to seek
expert evidence to support it. This could include a report from a medical or
accounting expert, for example.
DBT will cover the costs of obtaining expert evidence. The process you, or
your legal representative, will need to follow to can be found in the HSSA
tariff of reasonable legal costs
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
hssa-tariff-of-reasonable-legal-costs).
How to submit documents and evidence
Please submit any documents and evidence electronically where possible.
You and your legal representative will be given access to an online platform
where you can do this once you have made your appeal.
If you are unable to scan documents, DBT can accept photographs of
documents if they are good enough quality for us to:
e read the detail in the document
e be certain that the document is genuine
If you are submitting more than one image, you must ensure the link
between the images is clear.
If you do not have any internet access, your legal representative should
able to upload the documents on your behalf.
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We accept hard copies of the documents but only if you do not have both
legal representation and access to the internet. Send these to:
Horizon Shortfall Scheme Appeals
Post Office Team
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
How appeals are assessed
DBT has procured the services of an external legal firm, Addleshaw
Goddard, who are responsible for undertaking a fresh assessment of your
case. Once they have come to a determination, they will provide a
recommended offer to DBT.
Your appeal will be assessed using the information available, with
considerations of fairness and applying the relevant legal principles outlined
in the HSSA guidance and principles (https:/Awww.gov.uk/guidance/horizon-
shortfall-scheme-appeals-process-guidance-and-principles).
The assessment will depend on the individual circumstances of each
appeal, and the information and evidence supporting it.
If you disagree with our offer
If you disagree with our offer, and we cannot come to a solution through
discussions, your appeal may be referred to an Independent Panel who
could recommend another offer amount.
If your case is referred to the Independent Panel
The Independent Panel is made up of experts with a variety of relevant
backgrounds, including legal, accounting, medical and retail experts. The
panel is not the same as the panel who made your initial offer in Post
Office’s HSS.
The panel appointed in respect of your appeal will depend on the nature of
your claim.
If you still disagree with an offer made by the Independent Panel, your case
may be escalated to the Reviewer in specific circumstances. Any decision
made by the Reviewer is considered final.
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The full process is set out in the HSSA guidance and principles
(https://www.gov.uk/guidance/horizon-shortfall-scheme-appeals-process-guidance-
and-principles).
If your case is escalated to the Reviewer
The Reviewer is an independent senior lawyer.
If you remain unsatisfied with the outcome of your appeal after it has been
assessed by the Independent Panel, you can ask the Reviewer to consider
your appeal if you believe one of the following criteria apply:
e there has been a manifest error, procedural irregularity or substantive
error of principle in the Independent Panel’s final assessment of the
appeal
e the Independent Panel’s final assessment is substantially inconsistent
with the HSSA Guidance and principles
(https://www.gov.uk/guidance/horizon-shortfall-scheme-appeals-process-
guidance-and-principles)
Your legal representative will be best placed to advise you on whether your
case meets the criteria for escalation.
Meaning of a ‘manifest error’
In the context of escalating a HSSA case to the Independent Reviewer, a
manifest error is an error that is obvious or easily demonstrable without
extensive investigation and which had a material effect on the Independent
Panel's assessment.
This would include:
e a decision that went beyond the scope of what the Independent Panel
was permitted to assess
e adecision so obviously irrational that no person, acting reasonably, could
have made it
¢ anerror on the part of the Independent Panel in taking account of clearly
irrelevant matters or failing to consider clearly relevant matters
¢ anerror in the mathematical calculation of the compensation sum
awarded by the Independent Panel in its assessment (but not the
assumptions on which that calculation was based provided that such
assumptions are not factually incorrect or irrelevant).
Meaning of a ‘procedural irregularity’
In the context of escalating a HSSA case to the Independent Reviewer, a
procedural irregularity is an irregularity in the procedure or decision-making
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process that the Independent Panel has adopted while making its
assessment, which made a material difference to that assessment.
Circumstances where a procedural irregularity might arise include:
e where the Independent Panel has not correctly followed the Independent
Panel terms of reference
e where the Independent Panel has not properly observed the principles of
natural justice in the decision-making process
A failure to comply with the timeframes set out in the Independent Panel
terms of reference is unlikely to amount to a procedural irregularity.
Meaning of a ‘substantive error of principle’
In the context of escalating a HSSA appeal to the Independent Reviewer, a
substantive error of principle would arise where the Independent Panel’s
assessment involved the application of a principle identified in the guidance
and principles:
e in away which is obviously inconsistent with generally accepted legal
principles (either existing at the time the guidance and principles were
finalised or after that date)
* where the principle used to assess a case was Clearly inappropriate in the
circumstances
Length of appeal process
The time taken to investigate and assess each appeal is heavily dependent
on the facts of that appeal and the volume of documentation involved.
DBT progresses all appeals as quickly and efficiently as possible. We aim to
issue an initial offer in 90% of cases within 40 working days of making a
substantially complete appeal.
You will receive regular updates regarding your appeal.
Information about the progress of HSSA is published each month on
GOV.UK. It includes statistics about the number of appeals made, offers
made and acceptances, as well as the total amounts paid.
‘Substantially complete’ appeals
We consider your appeal ‘substantially complete’ when we have all the
information and evidence that you want us to consider. This puts us in the
best possible position to make a full and fair assessment of your case. This
includes any necessary requests for further information.
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We will ask you, or your legal representative, if we hold all the information
pertaining to your appeal. Once you confirm that we do, Addleshaw
Goddard will review the information and let us know whether any further
information is required from you.
Possible assessment outcomes
The assessment outcome will depend on:
e the individual circumstances of your appeal
e the information that is provided in support of it, including both the
evidence provided to Post Office in your original HSS application
* any new information you have provided to DBT
You will either be offered a higher amount than your initial HSS settlement,
or it will be determined that the original settlement was correct. If a fresh
offer is not made, your appeal will automatically be referred to the panel.
The assessment will take into account any payments that you have already
received in relation to Horizon. But you will never be asked to repay any
money you may have received from your original settlement.
Deductions from final payment
Any payment that you have already received in Post Office’s HSS will be
deducted from your final HSSA award amount, to ensure that compensation
is not mistakenly paid twice.
Impact on tax and benefits
Any compensation that you receive in HSSA is exempt from:
« Income Tax
¢ Capital Gains Tax
e National Insurance contributions
¢ Corporation Tax
e Inheritance Tax
Compensation paid in the appeals process is disregarded for the purposes
of means-tested benefits. It will not impact your eligibility for any of the
following benefits:
e Universal Credit
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e Pension Credit
e Housing Benefit
e Housing Benefit for pensioners
e Income Support
e income-based Jobseeker’s Allowance
e income-related Employment and Support Allowance
Interest applied to HSSA compensation
If you are awarded compensation in HSSA, interest is usually applied to it,
although some types of loss do not attract interest. Further information
about the types of loss which you can claim for is set out in the HSS
Consequential Loss principles and guidance
(https://www.onepostoffice.co.uk/scheme).
Postmasters making an appeal will be in different situations depending on if
they have already received full or partial payment of a HSS award, or not,
and if interest was paid on that award.
For that reason, we take a bespoke approach to paying interest in HSSA
depending on your individual payment situation.
Periods of time covered by interest payments
In HSS, interest is awarded on certain HSS heads of loss with start dates
for the interest payments being determined in accordance with the case
assessment principles.
For HSSA, interest is applied where appropriate up until the relevant points
in your case, as calculated by your DBT caseworker. Depending on your
individual situation, the relevant points would be as follows:
¢ receipt of your final offer in the HSS plus 28 days — this would likely apply
in situations where you have not yet received any payment due to
rejecting the original panel offer made to you by Post Office, but where
you were not found to be due any uplift in HSSA
e receipt of your final offer in HSSA plus 28 days — this would likely apply in
situations where you either received an uplift to your initial panel offer
awarded by Post Office (but to the uplift awarded in HSSA only where you
had accepted your HSS offer) or where you are receiving a full award for
the first time (because you rejected your HSS offer) and have received an
uplift granted in HSSA
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* receipt of an interim payment — this would likely apply in situations where
you received an interim payment in HSS, which did not have interest
applied. On that interim payment only, interest would be calculated up to
the point of its payment.
Further information
team at hssappeals: GRO
Published 8 April 2025
Last updated 10 April 2025 + show all updates
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