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IN THE MATTER OF THE INQUIRIES ACT 2005
AND IN THE MATTER OF THE INQUIRY RULES 2006
THE POST OFFICE HORIZON IT INQUIRY
WRITTEN SUBMISSIONS ON BEHALF OF
THE DEPARTMENT FOR BUSINESS AND TRADE
HSS APPEALS PROCESS
Introduction
1. These written submissions are provided on behalf of the Department for Business and
Trade (“DBT”) in response to the Chair’s invitation dated 2 May 2025. They set out the
developments that have taken place in relation to the new HSS Appeals (“HSSA”) process.
Creation of the HSS Appeals process
2. DBT has taken seriously the criticisms of the Post Office-run HSS scheme, as raised by
postmasters and their representatives and summarised by the Chair in his Progress Update
on Issues relating to Compensation! and his First Interim Report: Compensation.’
3. In response to these criticisms, Ministers accepted the Horizon Compensation Advisory
Board’s proposal that DBT should create an independent appeals process. The Secretary
of State for Business and Trade, Rt Hon. Jonathan Reynolds MP, announced on 9
I https:/ /www.postofficehorizoninquiry.org.uk/sites/default/ files /2022-
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2 https://www.postofficehorizoninquiry.org.uk/sit
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September 2024 that the Government would introduce this new appeals mechanism, to be
delivered by DBT.
4. Following a period of engagement with postmasters’ legal representatives, postmaster
organisations, and the Advisory Board on the design of the appeals process, on 8 April
2025 the Minister for Services, Small Businesses and Exports, Gareth Thomas MP, made
a statement to Parliament announcing the launch of the new HSSA.* The process opened
to applications from eligible postmasters within the HSS Dispute Resolution Process
(“DRP”) on 28 April 2025, and to all eligible postmasters on 9 May 2025. DBT set this
scheme up at pace, working with Post Office and procuring independent contractors to
deliver the new process. Links to the relevant documents can be found here:
https://www.gov.uk/government/collections/horizon-shortfall-scheme-appeals-hssa-
5. Post Office’s commitments under the GLO settlement deed mean that the DRP must
remain open and cases cannot be compulsorily transferred into the new process. DBT
wrote to eligible postmasters within the DRP on 28 April 2025 to invite them to transfer
to the HSSA. On 9 May 2025, Post Office circulated (via postmasters’ organisations) an
invitation to other eligible postmasters to enter the process.
Eligibility
6. The HSSA process is open to postmasters who:
. have settled a claim in the HSS without entering the DRP;
. have rejected an initial HSS offer without entering the DRP;
. have settled a claim in the DRP before the mediation stage without legal advice
funded by the Post Office, other than for reasonable allowances to consider an
offer; or
3 https://hansard.parliament.uk /commons/2024-09-09 /debates/855A696A-7CC7-4F DE-ACBD-
871C8D7309D0/PostOfficeHorizonRedress# contribution F9ACFF4A-1728-4BB3-8DEB.
AOF2194658
4 https://hansard.parliament.uk/commons/2025-04-08/debates/ ATASDIEC-5F40-4069-8238-
2 BEO1284C8E /HorizonRedressAndPostOfficeUpdate. This followed a statement updating Parliament
on 30 January 2025: https:/ /questions-statements.parliament.uk/written-statements/detail/ 2025-01
30/hews399
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. are within the DRP — with or without legal advice — but have not requested a
mediation meeting.
7. Initially, it was proposed that postmasters would be required to submit new information
to enter the HSSA process, but this was removed from the eligibility criteria in light of
stakeholder representations, including from postmasters and Members of both Houses.
8. Some stakeholders requested that those who have accepted the £75,000 Fixed Sum Offer
should also be eligible for the HSSA. However, as the Secretary of State explained when
giving evidence in Phase 7 of the Inquiry, DBT decided against this, because “that would
result in insufficient capacity in that scheme to deal with the kinds of cases we're most interested in making
sure have again had that full, speedy and effective redress.”* This position has been made clear in
all communications to postmasters at the point when they are considering whether to
accept the £75,000 fixed sum offer and DBT has asked Post Office to ensure that no
pressure is exerted on Postmasters to accept the Fixed Sum Offer.
Funding for reasonable legal costs
9. DBT is encouraging postmasters to access legal support throughout the entire HSSA.
process, and will provide funding for reasonable legal costs in line with a published tariff."
10. This tariff was designed and agreed with postmasters’ legal advisors, and includes an
allowance to support postmasters with their decision of whether to remain in the DRP or
to transfer to the HSSA process.
Assessment Process
11. The Guidance and Principles for the process have been published,’ following engagement
with postmasters’ legal representatives, postmaster organisations, and the Advisory Board.
5 Transcript, 11 November 2024, page 25, line 19. ‘The Inquiry has also been provided with extensive evidence
concerning the reasons the Department decided to introduce Fixed Sum Offers.
6 https://www.gov.uk/government/publications/horizon-shortfall-scheme-appeals-hssa-tariff-of-
reasonable-legal-costs/hotizon-shortfall-scheme-appeals-hssa-tatiff-of-reasonable-legal-costs
7 https://www.gov.uk /guidance/horizon-shortfall-scheme-appeals-process-guidance-and-principles
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They set out the underlying principles governing the assessment of any appeals and provide
guidance in relation to such appeals.
12. DBT aims to determine cases more quickly in the HSSA process than claims in the DRP,
setting a public target to issue an offer in 90% of cases within 40 working days of
submission of a substantially complete appeal (or a full response to any request for further
information). DBT will make a fresh assessment of each case, but in no event will a
postmaster receive a lower settlement than their initial HSS offer.
13. DBT is also working with the Post Office to facilitate the disclosure of the original HSS
claim and assessment to ensure that postmasters do not need to repeat information already
provided to the Post Office. This should make the HSSA process as simple and easy as
possible for postmasters, and should speed up the pace of redress. If the postmaster
disputes the offer made through the HSSA process, DBT will engage in settlement
discussions to attempt to resolve the disagreement. The postmaster may then make a
request to refer this to an independent panel before making an application to refer their
case to an independent reviewer, similar to the role carried out by Sir Ross Cranston on
the GLO scheme. Cases where DBT has decided not to make a fresh offer will be
automatically referred to the panel. The panel will be appointed depending on the nature
of the claim, and may include legal, accounting, medical and retail experts. Postmasters will
have the option to make an oral statement to the panel.
14. In keeping with the other redress schemes run by DBT, 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.
15. The new HSSA process is intended to ensure that eligible postmasters can be assured of:
. a simple and easy application process;
. fair redress;
. which is decided independently of the Post Office;
. with support for the costs of legal advice; and
8 The Horizon Shortfall Scheme Appeals (Tax Exemptions and Relief) Regulations 2025
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. resolved with the minimum of further delay.
Progress
16. DBT has written to all eligible postmasters within the DRP, and it continues to advertise
that the HSSA process is now open, including through postings on its social media
platforms on 12 May 2025. The Department has already received several applications from
both postmasters in the Post Office’s DRP process who have chosen to move over to the
HSSA process, and also those who have not entered the DRP but wish to dispute their
HSS offer.
17. It is hoped that these written submissions will be useful to the Inquiry. The Department
will continue to work with postmaster representatives on implementing the scheme and
will publish monthly data on progress.
14 May 2025