Reports & recommendations
27 recommendations from 2 reports, each with the government response on the record. Filter by government response, report or delivery status.
Reports (2)
| Title | Volume | Publication Date | Recommendations | Links |
|---|---|---|---|---|
| First Interim Report: Compensation | - | 17 Jul 2023 | 8 | |
| Post Office Horizon IT Inquiry: Volume 1 Report | 1 | 08 Jul 2025 | 19 |
Recommendations (27)
Respond to recommendations by 10 October 2025
HM Government and/or the Department and where appropriate the Post Office and Fujitsu shall provide written responses to my recommendations by 10 October 2025.
The Inquiry asked the government, Post Office, and Fujitsu to respond by October 2025. In an update of February 2026, published in March 2026, Cabinet Office recorded that the Department for Business and Trade (DBT) fulfilled the recommendation by publishing its October 2025 response (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee noted the government met the requirement by publishing its response (Business and Trade Select Committee, Jan 2026). In October 2025, Nigel Railton, Chair of Post Office Limited, submitted its response, while Morrison Foerster (UK) LLP, solicitors for Fujitsu Services Limited, stated it would not respond to recommendations 2 to 18 (Nigel Railton response, Oct 2025; Morrison Foerster (UK) LLP for Fujitsu Services Limited response, Oct 2025). That month, Blair McDougall, Minister for Small Business and Economic Transformation, stated the department's full response will be laid as a Command Paper after the final inquiry volume is issued (Blair McDougall, Oct 2025).
Define and publish meaning of full and fair financial redress
The Minister and/or the Department in conjunction with the Post Office shall make a public announcement explaining what is meant by the phrase "full and fair financial redress". Such an explanation should indicate that claimants should be awarded sums which are equivalent to those which they would receive in civil litigation brought before a judge in England and Wales, assuming that the judge hearing the civil claims awarded damages at the top end of the appropriate range of damages. The explanation should also include a statement to the effect that, if fairness demands it in a particular case, a decision maker may depart from the established legal principles which would normally govern the assessment of damages in civil litigation.
The Inquiry asked the government to publish a definition of full and fair redress. In a February 2026 dashboard update published in March 2026, the Cabinet Office reported that the Department for Business and Trade (DBT) published an explanatory statement on 9 October 2025 (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee examined whether the definition was applied consistently across compensation schemes, noting that over 4,000 claimants still awaited final settlement (Business and Trade Select Committee, Jan 2026). In October 2025, Nigel Railton, Chair of Post Office Limited, stated that the agreed guidance instructs decision makers to adopt "a generous approach" when assessing an appropriate range of damages (Nigel Railton response, Oct 2025).
Apply full and fair meaning consistently across all schemes
The Post Office, the Department and the Minister shall ensure that all decision makers in HSS, GLOS and OCS/HCRS apply the meaning to be given to the words "full and fair" when assessing the amounts to be awarded to individual claimants.
The Inquiry asked that full and fair compensation standards be applied across all redress schemes. In its February 2026 update, published in March 2026, the Cabinet Office reported that the Department for Business and Trade (DBT) and Post Office Limited had published a joint statement defining full and fair redress to be applied across all schemes (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee found that while the agreed definition was referenced in guidance, over 4,000 claimants remained unsettled, raising questions about whether it was consistently applied (Business and Trade Select Committee, Jan 2026).
Fund legal advice for HSS claimants before scheme choice
All claimants in HSS shall be entitled to obtain legal advice funded by the Department prior to choosing between accepting the Fixed Sum Offer or seeking financial redress which is assessed. The remuneration for such advice shall be in accordance with a scale of fees commensurate with the scale which is operative in GLOS.
The Inquiry recommended funded legal advice for Horizon Shortfall Scheme claimants before choosing redress. In an October 2026 update published by the Cabinet Office, the department stated that it will fund advice when claimants seek permission to appeal, has published the tariff of legal costs, and expects to launch the process in the autumn (Cabinet Office, Oct 2026). The Business and Trade Committee HC 1598 found in March 2026 that the government had not properly implemented the recommendation because advice is funded at the appeal stage rather than upfront (Business and Trade Committee HC 1598, Mar 2026).
Allow 3-month window to accept Fixed Sum Offer after assessment
Any claimant who opts to have a claim assessed when the claim is submitted to the Post Office or the Department may decide to accept the Fixed Sum Offer at any time thereafter up to and including the date which is three calendar months following the receipt by the claimant of a first assessed offer. For the avoidance of any doubt, (1) this recommendation applies to all relevant schemes i.e. HSS, OCS/HCRS and GLOS and (2) once the time period specified in the first sentence hereof has expired, the claimant will have no right to accept the Fixed Sum Offer.
The Inquiry recommended a three-month window to accept a fixed sum offer after assessment. In a February 2026 update published in March 2026, the Cabinet Office stated that the recommendation was implemented on 9 October 2025 for the Horizon Shortfall Scheme (HSS) and the Horizon Convictions Redress Scheme (HCRS), and that the Post Office was reviewing records to notify eligible claimants, while the Group Litigation Order Scheme (GLOS) was not mentioned (Cabinet Office, Mar 2026). Earlier, in January 2026, the Business and Trade Select Committee noted the measure had been implemented for HSS and HCRS, and found that over 4,000 claimants across all schemes were still awaiting final settlement (Business and Trade Select Committee, Jan 2026).
Appoint senior lawyer to ensure HSS offers are full and fair
A suitably qualified senior lawyer shall be appointed to HSS as soon as is practicable with the aim that any such appointee will take appropriate action to ensure that first offers to claimants (a) are "full and fair" (b) made to those who have submitted claims to the Post Office and which are to be assessed as soon as is reasonably practicable and (c) are made to future claimants whose claims are to be assessed within a reasonable time.
The Inquiry asked ministers to appoint a senior lawyer to the Horizon Shortfall Scheme. In June 2026, the Cabinet Office reported that Sir Gary Hickinbottom assumed the post of Independent Senior Lawyer in December 2025 and completed work on his first referral, with his full report to be published in due course (Cabinet Office, Jun 2026). In May 2026, Blair McDougall, Parliamentary Under-Secretary of State, stated to Parliament that the appointee's remit is to review generic issues and recommend actions to ensure prompt and fair redress (Blair McDougall, May 2026). In March 2026, the Business and Trade Committee HC 1598 acknowledged the appointment but found that assessed claims took an average of 450 days and were frequently undervalued (Business and Trade Committee HC 1598, Mar 2026).
Grant appropriate powers to HSS senior lawyer
The appointed person shall be given appropriate powers to ensure that these tasks can be performed and carried into effect. If it is considered necessary by the appointing authority, it should consult with the Advisory Board, Dentons, Sir Gary Hickinbottom, Sir Ross Cranston and an appropriate number of claimants' representatives (as well as its own advisors) before determining the appropriate powers.
The Inquiry recommended granting appropriate powers to the Horizon Shortfall Scheme senior lawyer. In a February 2026 update, the Cabinet Office reported that full details on the scope of the role had been published following consultation with Sir Ross Cranston, the Horizon Compensation Advisory Board, Dentons, claimants' legal representatives and the Post Office (Cabinet Office, Mar 2026). In March 2026, the Business and Trade Committee HC 1598 found that despite powers being granted to the senior lawyer, fully assessed scheme offers remained routinely undervalued, with major disparities between initial offers and eventual awards (Business and Trade Committee HC 1598, Mar 2026). The committee reported that thousands of claimants were still awaiting settlement and recommended transferring remaining cases to the Department for Business and Trade (DBT) (Business and Trade Committee HC 1598, Mar 2026).
Require HSS first offers match Independent Advisory Panel recommendation
In HSS the Post Office shall be obliged to make, and the Department shall be obliged to approve (when necessary) a first offer to a claimant which is no less than the sum recommended by the Independent Advisory Panel.
The Inquiry recommended that Historical Shortfall Scheme (HSS) first offers match panel recommendations. In a February 2026 update published in March 2026, the Cabinet Office reported that no first offer has ever been made below the sum recommended by the HSS Panel and claimants are informed of this upon receipt of their offer (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee heard that no first offer had been made below panel recommendations, meaning retroactive enforcement had not been needed (Business and Trade Select Committee, Jan 2026). The Department for Business and Trade stated in October 2025 that scheme documents had been amended to reflect this requirement (Department for Business and Trade response, Oct 2025).
Allow HSS Fixed Sum acceptors to appeal with independent permission
The Department following consultation with the Advisory Board, claimants' representatives and any other persons or bodies it thinks appropriate, shall give urgent consideration to whether claimants who have accepted the Fixed Sum Offer in HSS should be afforded the opportunity to appeal against their acceptance of such an offer if they are granted permission so to do. If a right of appeal with permission is introduced, the issue of permission to pursue such an appeal must be considered by a person who is wholly independent of the Department and the Post Office.
The Inquiry asked the Department for Business and Trade to consider independent fixed-sum appeals. The Cabinet Office reported in an October 2026 dashboard update that the department committed to providing independent appeals with funded legal advice, but opening registrations remains outstanding while operational arrangements are completed (Cabinet Office, Oct 2026). In March 2026, Business and Trade Committee HC 1598 found that the appeals route had become an essential second step due to routinely undervalued offers, leaving claimants waiting two to three years for redress (Business and Trade Committee HC 1598, Mar 2026).
Clarify best offer principle in HSSA guidance with examples
The Department shall issue a supplementary document/announcement clarifying the meaning and intent of the "best offer" principle in the Horizon Shortfall Scheme Appeal (''HSSA'') process demonstrating how it is intended to operate in practice with appropriate examples, if thought necessary.
The Inquiry recommended clarifying the best offer principle within scheme appeal guidance. In a February 2026 dashboard update published in March 2026, the Cabinet Office reported that the Department for Business and Trade (DBT) had updated the existing Horizon Shortfall Scheme Appeal (HSSA) guidance and principles (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee noted that the department had updated the guidance to clarify the principle as required (Business and Trade Select Committee, Jan 2026). In its October 2025 response, the department stated it had updated the guidance and would coordinate the principle across compensation schemes (Department for Business and Trade response, Oct 2025).
Apply best offer principle equally in GLOS
The "best offer" principle which will apply in HSSA, as explained in response to Recommendation 10, shall be equally applicable in GLOS.
The Inquiry recommended extending the best offer principle to the Group Litigation Order scheme. The Cabinet Office reported in an update of February 2026, published in March 2026, that the Department for Business and Trade had been implementing the policy at all panel stages since August 2025 (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee found that the department committed to applying the principle retrospectively, while over 4,000 claimants across all schemes were still awaiting final settlement (Business and Trade Select Committee, Jan 2026). In October 2025, the department stated that any postmaster who received a lower binding panel award would have redress topped up to the higher offer (Department for Business and Trade response, Oct 2025).
Amend GLOS to allow claimants oral submissions at panel hearings
The scheme documents governing GLOS should be amended so that a right is conferred upon claimants (exercisable by the claimants themselves or their recognised legal representatives) to make oral submissions in support of their claim at the hearing convened by an independent panel prior to that panel making a binding determination in respect of a claimant's claim or part thereof. The length of time afforded to claimants to make such oral submissions at the hearing should be no less than the time afforded to claimants for such submissions in HSSA.
The Inquiry recommended amending Group Litigation Order Scheme (GLOS) rules to allow claimants oral submissions. In an update of February 2026, published in March 2026, the Cabinet Office reported that claimants in the scheme already had the right to make oral submissions for up to one hour, and the panel's terms of reference had been amended to reflect this practice (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee found that claimants already possessed the right to make oral submissions, concluding that the recommendation was effectively already met (Business and Trade Select Committee, Jan 2026).
Close HSS Dispute Resolution Procedure when HSSA opens
The current Dispute Resolution Procedure in HSS should be closed once all claimants currently within the Procedure have either (a) settled their claims or (b) transferred to HSSA. No claimant who is not in the Dispute Resolution Procedure when HSSA opens should be eligible to join the Dispute Resolution Procedure.
The Inquiry recommended closing the Horizon Shortfall Scheme dispute resolution procedure once appeals open. In October 2025, Blair McDougall, Minister for Small Business and Economic Transformation, stated that the Department for Business and Trade rejected closing the procedure to avoid unfairly restricting postmasters' choices (Blair McDougall, Oct 2025). In March 2026, the Business and Trade Committee HC 1598 acknowledged the refusal without disputing it, while finding that the wider shortfall scheme suffered from operational problems (Business and Trade Committee HC 1598, Mar 2026). The committee reported that thousands of claimants were still awaiting settlement (Business and Trade Committee HC 1598, Mar 2026).
Post Office to engage in negotiations during HSSA appeal period
During the nine-month period afforded to claimants to submit an appeal to the Department in HSSA, the Post Office shall engage in negotiations and/or mediation with any claimants who notify the Post Office of a desire to seek a negotiated or mediated settlement of their claim.
The Inquiry recommended negotiations or mediation with claimants during their appeal window. In an update of February 2026, published in March 2026, the Cabinet Office reported that the Department for Business and Trade (DBT) had applied the recommendation by allowing claimants to hold good faith or escalation meetings with Post Office Limited during a revised three-month notification window (Cabinet Office, Mar 2026). In January 2026, the Business and Trade Select Committee questioned whether this three-month deadline gave claimants sufficient time, noting that over 4,000 claimants were still awaiting final settlement across all schemes (Business and Trade Select Committee, Jan 2026). In October 2025, Nigel Railton, Chair of the company, confirmed it was actively corresponding with legal advisers to resolve claims in that period (Nigel Railton response, Oct 2025).
Set deadline for HSS claims with guidance on late applications
No claims for financial redress under HSS shall be entertained after midnight 27 November 2025.
The Inquiry recommended closing the Horizon Shortfall Scheme to new claims by 27 November 2025. In a May 2026 update published in June 2026, the Cabinet Office reported that the scheme closed to new applications on 31 January 2026 (Cabinet Office, Jun 2026). It added that the Department for Business and Trade agreed with the Post Office on handling exceptional late cases, for which guidance had been published on the Post Office website (Cabinet Office, Jun 2026). Earlier, in January 2026, the Business and Trade Select Committee heard that the scheme would close later than recommended, with over 4,000 claimants across all schemes still awaiting final settlement (Business and Trade Select Committee, Jan 2026).
Clarify whether HCRS and OCS assessment processes differ
The Department shall make a public announcement in which (a) it clarifies whether there will be any differences in the process for assessing financial redress, between the merged HCRS and OCS, and the process currently operating in OCS and if so, (b) it explains what those differences in the process will be.
The Inquiry asked the Department for Business and Trade to clarify differences between redress schemes. In a February 2026 update published in March 2026, the Cabinet Office stated that the department addressed the recommendation in October 2025 by confirming the Horizon Convictions Redress Scheme (HCRS) applies the same principles as the Overturned Convictions (OC) scheme (Cabinet Office, Mar 2026). The Business and Trade Select Committee noted in January 2026 that identical principles apply, while reporting that over 4,000 claimants across all schemes were still awaiting final settlement (Business and Trade Select Committee, Jan 2026). In October 2025, the department had published guidance on alternative dispute resolution and independent panel terms of reference to reassure claimants of consistent treatment (Department for Business and Trade response, Oct 2025).
Establish standing public body to administer future redress schemes
As soon as is reasonably practicable, HM Government shall establish a standing public body which shall, when called upon to do so, devise, administer and deliver schemes for providing financial redress to persons who have been wronged by public bodies.
The Inquiry recommended establishing a standing public body to administer future financial redress schemes. In October 2026, the Cabinet Office reported that officials were exploring options to improve redress arrangements, though work assessing their implications remained ongoing (Cabinet Office, Oct 2026). It added that any new body was unlikely to be established in time to take over existing time-limited schemes (Cabinet Office, Oct 2026). Previously, in March 2026, the Business and Trade Committee HC 1598 found no progress on establishing the body and noted that the government had not committed to the proposal (Business and Trade Committee HC 1598, Mar 2026).
Devise redress process for affected family members
The Department shall devise a process for providing financial redress to close family members of those most adversely affected by Horizon. Such family members shall qualify for such redress only if they themselves, have suffered serious adverse consequences by reason of their family relationship with the person or persons directly affected by Horizon.
The Inquiry recommended creating a financial redress process for close family members affected by Horizon. In an October 2026 update, the Cabinet Office reported that registration opened in July 2026 for prospective applicants to submit assessment information (Cabinet Office, Oct 2026). It noted that claims processing is expected to begin once a third-party supplier has been appointed to deliver the scheme (Cabinet Office, Oct 2026). In March 2026, the Business and Trade Committee HC 1598 welcomed the scheme but urged the government to expand eligibility beyond spouses and children to include other relatives demonstrating adverse consequences (Business and Trade Committee HC 1598, Mar 2026).
Publish restorative justice programme by 31 October 2025
By 31 October 2025, the Department, Fujitsu and the Post Office shall publish, either separately or together, a report outlining any agreed programme of restorative justice and/or any actions taken by that date to produce such a programme. For the avoidance of any doubt, the word Fujitsu in this recommendation is intended to include both Fujitsu Services Limited and Fujitsu Limited.
The Inquiry asked three bodies to publish an agreed restorative justice programme. In its May 2026 dashboard update, published in June 2026, the Cabinet Office reported that the Department for Business and Trade (DBT), Post Office Limited and Fujitsu had published an update in March 2026 detailing plans for postmasters and their families to meet staff, with support shared for up to five years (Cabinet Office, Jun 2026). In March 2026, the Business and Trade Committee HC 1598 found that the company had accepted moral responsibility but had not provided an interim payment towards the redress bill (Business and Trade Committee HC 1598, Mar 2026). Earlier, in January 2026, the committee welcomed the pilot restorative justice project while questioning who it would cover (Business and Trade Select Committee, Jan 2026).
Allow Advisory Board to monitor individual cases and make full and fair monitoring a core duty
The Horizon Compensation Advisory Board should not be prevented from monitoring individual cases in which compensation has been or is to be determined by paragraph 4 of its Terms of Reference. It must be one of the core duties of the Board that it monitors whether compensation payments are full and fair.
The Inquiry asked that the advisory board monitor individual cases and compensation fairness. In October 2023, the Department for Business and Trade agreed that the Horizon Compensation Advisory Board could receive anonymised individual case information, but endorsed its view that monitoring whether payments are full and fair is not advisable (Department for Business and Trade response, Oct 2023). It noted that existing terms of reference already permit the board to advise ministers (Department for Business and Trade response, Oct 2023).
Publish Advisory Board meeting reports within 21 days
The Horizon Compensation Advisory Board shall produce written reports in respect of each of their meetings in relation to each of the three schemes and publish the same within 21 days of the date of each meeting.
The Inquiry recommended that Advisory Board meeting reports be published within 21 days. In October 2023, the Department for Business and Trade stated that written reports of board discussions were already published and were issued within a week unless the board agreed otherwise, noting earlier records for the Group Litigation Order Compensation Scheme Advisory Board but not mentioning the three schemes (Department for Business and Trade response, Oct 2023).
Advise Minister and Post Office on full and fair compensation at three monthly intervals
The Horizon Compensation Advisory Board shall, as part of its advisory role, consider whether, in its view, full and fair compensation is being paid out to applicants under the three schemes and shall advise the Minister and the Post Office accordingly at three monthly intervals.
The Inquiry recommended that an advisory board assess compensation fairness and advise ministers quarterly. In October 2023, the Department for Business and Trade agreed the board could receive anonymised data, but endorsed its view that it would not be possible to give an "opinion that full and fair compensation is being paid out to individuals" (Department for Business and Trade response, Oct 2023). It noted that reports are communicated to the Minister following six-weekly meetings, while advising the Post Office is not mentioned in the sources (Department for Business and Trade response, Oct 2023).
Increase Advisory Board membership if needed for capacity
If the Horizon Compensation Advisory Board as constituted consider it necessary, the number of persons appointed to the Board should be increased so as to ensure that the Board has sufficient capacity to perform the functions set out above.
The Inquiry recommended expanding Horizon Compensation Advisory Board membership if necessary for capacity. In its response published in October 2023, the Department for Business and Trade stated that it would "keep under review the case for expanding the board, in discussion with its current members" (Department for Business and Trade response, Oct 2023).
Seek court directions to resolve the DBT and Moore UK difference on bankrupt applicants
DBT shall take such steps as are necessary within 28 days of the date hereof, to seek appropriate directions under section 306 Insolvency Act 1986 so as to enable a court to resolve the difference of view between DBT and Moore UK and/or it shall take all appropriate steps (including providing appropriate legal funding) so as to enable a sub-postmaster to seek appropriate directions under that section.
The Inquiry asked the Department for Business and Trade to seek directions regarding bankrupt applicants. In October 2023, the department stated that it had instructed counsel to apply for expedited court directions resolving its dispute with Moore UK, and that it would ask for an affected postmaster to be named as an interested party (Department for Business and Trade response, Oct 2023). Its response did not mention providing legal funding for a postmaster to seek directions (Department for Business and Trade response, Oct 2023).
Publish proposals for equal tax treatment of compensation payments
DBT shall publish in as much detail as it reasonably can and as soon as it reasonably can, its proposals for ensuring that applicants to all schemes are treated equally and fairly so far as their liability to or exemption from income tax, capital gains tax and inheritance tax is concerned as the same relates to compensation payments under each scheme.
The Inquiry asked the government to publish proposals ensuring equal tax treatment across compensation schemes. In October 2023, the Department for Business and Trade (DBT) stated that payments under the Group Litigation Order (GLO) scheme and for overturned convictions were exempt from income tax, National Insurance contributions, and capital gains tax, while tax-exempt top-up payments were arranged for the Horizon Shortfall Scheme (HSS), with all three schemes exempt from inheritance tax (Department for Business and Trade response, Oct 2023).
Legislate to allow GLOS compensation payments after 7 August 2024 if necessary
HM Government shall bring forward and use its best endeavours to ensure that legislation is enacted so as to allow payments of compensation under GLOS to be made to applicants after 12 midnight on 7 August 2024 if that proves to be necessary.
The Department for Business and Trade stated in October 2023 that it was determined to deliver the scheme by August 2024 and would consider whether legislation was necessary if that deadline appeared likely to be missed (Department for Business and Trade response, Oct 2023). In January 2026, the Business and Trade Select Committee found that the Limitation Act amendment had not been brought forward as a standalone bill, with longer-term legislative options under consideration (Business and Trade Select Committee, Jan 2026). The committee noted that over 4,000 claimants across all schemes were still awaiting final settlement at that date (Business and Trade Select Committee, Jan 2026).
Set agreed closing date for Horizon Shortfall Scheme applications
No applications for compensation to HSS shall be entertained after such date as shall be agreed by the Minister/ DBT, the Post Office and the Horizon Compensation Advisory Board.
The Inquiry asked for an agreed closing date for Horizon Shortfall Scheme applications. In October 2023, the Department for Business and Trade stated that it would discuss and agree an appropriate closing date with the Post Office, seek advice from the advisory board, and notify the inquiry and potential claimants once a decision was made (Department for Business and Trade response, Oct 2023).