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a; GOV.UK
Guidance
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.
From: Department for Business and Trade
(/government/organisations/department-for-business-and-trade)
Published 8 April 2025
Last updated 10 April 2025 —
Contents
— Introduction
— Eligibility
— Parties involved
— Overview of HSSA process
— ID verification and eligibility check
— Submission of an appeal
— Assessment of your claim
— Referral to Independent Panel
— Review process
— Acceptance of the offer
— Transparency of progress of the process
— Taxation
— Interest
— Further information
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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 meet one of the following
criteria. You must have either:
e settled your claim in the HSS without entering the Dispute Resolution
Process (DRP)
¢ rejected your initial HSS offer without entering the DRP
e 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
You cannot appeal if you have accepted the £75,000 Fixed Sum Offer
(FSO). By registering with the HSSA process you will not be able to later
accept the FSO.
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If you have not yet submitted an HSS claim, or received an offer, read the
HSS guidance on the Post Office website
(https://www.onepostoffice.co.uk/scheme)
If you are currently in the DRP, and you have not yet agreed to or arranged
a mediation meeting, you will be contacted and asked to decide whether to
remain in the DRP or to transfer to HSSA. If you decide to remain in the
DRP, you will not be eligible to transfer to HSSA.
When the scheme launches, 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
Settled your claim in the HSS
without entering the 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
Within the DRP — with or without
legal advice — but not have
requested or be awaiting a
mediation meeting, upon scheme
opening
Timescale
You will have 9 months to make an
application, starting on either the date of
settling 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
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
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issues with these. timelines beina.met..contact
hssappeals! GRO 'to discuss further. 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.
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 ina
partnership which has ceased to exist, you can make an appeal as a linked
individual. If appropriate, an offer of an ex-gratia payment 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 uns!
hssappealsi__
le for the HSSA process, contact
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.
The process operates on a ‘best offer’ principle, and by entering the scheme
there is no risk of receiving less redress than offered in the HSS Panel
Stage. If you are in the DRP, there is no risk of receiving less redress than
the best offer received during the DRP.
Parties involved
The Horizon Compensation Advisory Board
(https://www.gov.uk/government/groups/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:
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e Addleshaw Goddard as external legal advisors to advise DBT on
individual cases
e 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:
e 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.
e 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.
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
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
hssa-tariff-of-reasonable-legal-costs). Other firms can access the same rates.
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
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
hssa-registration-form).
This should then be emailed to hssappea
sent by post to:
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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
e 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
(https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-
proving-your-identity) 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 i
asking for a review of this decision. ~
For DRP transfer cases, 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 Post Office. For all other eligible
postmasters, once eligibility has been confirmed, DBT will ask you to
confirm that you wish to continue with the application process and will only
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request information relating to your claim from Post Office once you have
confirmed your wish to continue.
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 (https://www.gov.uk/government/publications/horizon-shortfall-
scheme-appeals-hssa-privacy-notice) 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.vour.full_apnlication form. This should then be
emailed to hssappealsi GRO ‘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.
For the purposes of clarity, all eligible postmasters not already within DRP
will need to provide information to explain why you wish to appeal your offer
or settlement. You can appeal the whole settlement, a singular head of loss,
or multiple heads of loss. For DRP transfers, DBT will assume your dispute
is on the same basis as the one you raised in DRP unless otherwise stated
in your application form.
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.
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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)
(https://www.onepostoffice.co.uk/scheme) 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 (https://www.gov.uk/government/publications/horizon-
shortfall-scheme-appeals-hssa-tariff-of-reasonable-legal-costs). DBT will not
reimburse costs that are not pre-approved.
DBT will 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. Alternatively, the DBT caseworker will inform your
lawyer that DBT agrees with the original HSS offer.
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.
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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:
e if there is not a substantial difference between the last claim and offer
exchanged by the parties
e further evidence is required
e 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
Cases in which DBT has decided not to make a fresh offer will be
automatically referred 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.
The Independent Panel may make an award which is less than any earlier
offer made by DBT for your appeal. DBT will be bound by the Independent
Panel's decision and once the Independent Panel has made its final
decision on the offer, you will not be able to return to this earlier offer.
However, you will never receive any less than your HSS or DRP offer.
Review process
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You can make an application to refer your case to the Reviewer for
exceptional review if you believe one of the following criteria apply:
e if you have arguable grounds that there has been a manifest error,
procedural irregularity or substantive error of principle in the Independent
Panel’s assessment of the appeal
e if 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
DBT will pay you the amount of redress that is agreed or determined by the
Independent Panel or the Reviewer once one of the following has occurred:
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e the parties have agreed in writing on an amount of redress for some or all
heads of claim
e the Independent Panel has issued an assessment and you have not
referred it for exceptional review within 15 working days
e the Reviewer has issued a decision
If it is determined that you should have received a higher amount than
offered in your original HSS claim, one payment will be made to you.
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, 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.
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 (https://www.onepostoffice.co.uk/scheme).
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.
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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.
Further information
If you have a query or need more information you can email the HSSA
team hssappeals}
Published 8 April 2025
Last updated 10 April 2025 + show all updates
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