FDR Hearing Bundle: Documents, Format and Negotiating Position for 2026

Last updated: April 2026

This article provides general information only and does not constitute legal advice. Financial remedy proceedings are fact-sensitive and the consequences of a final order are typically lifelong. Consider seeking advice from a Resolution-accredited family solicitor on your specific circumstances.

Quick Answer

The Financial Dispute Resolution appointment (FDR) is the second substantive hearing in financial remedy proceedings, sitting between the First Directions Appointment (FDA) and any final hearing. Its purpose is settlement: the FDR judge gives a candid, without-prejudice indication of the likely outcome of a contested final hearing, helping the parties bridge the gap. Bundles for FDRs sit under Practice Direction 27A Chapter 6 — financial remedy bundles use Arabic numbering consecutively through the whole bundle (1, 2, 3 …), matched to the PDF page labels. (This is different from the Bates per-section-restart scheme that applies to most other Family proceedings under Chapter 7.) An FDR bundle typically runs 250–350 pages and contains the Form E exchange, replies to questionnaire, expert valuations, both parties' position statements, a draft order from each side, and a schedule of assets.

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What the FDR Is For

The FDR is, on the face of it, a court hearing. In substance it is a settlement meeting with judicial input. The judge reads both sides' position statements and offers, considers the disclosure and expert evidence, and gives the parties a non-binding view of how the case might be decided at a final hearing.

That indication is without prejudice — it cannot be referred to at any final hearing if the case does not settle, and the FDR judge is excluded from hearing the final hearing if the case proceeds. This is what makes the FDR work: judges can be candid, parties can negotiate freely, and offers can be made and accepted without the risk of "anchoring" the trial judge.

"The procedure for the FDR is set out at FPR rule 9.17. The FDR appointment is to be treated as a meeting held for the purposes of discussion and negotiation. Parties must use their best endeavours to reach agreement." — Family Procedure Rules Rule 9.17

A high proportion of cases settle at or shortly after the FDR. Even where a case does not settle on the day, the judicial indication often narrows the issues so that final-hearing exposure is reduced.

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Where the FDR Sits in the Process

For a comparison of the FDA and the FDR, see our FDA vs FDR explainer.

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PD27A and Financial Remedy Bundles — Arabic, Not Bates

A common point of confusion. The same Practice Direction governs all Family bundles, but it has two pagination schemes depending on the type of proceedings:

• Financial remedy (PD27A Chapter 6, paragraph 6.2) — Arabic numbering, consecutive through the whole bundle (1, 2, 3 …), with the page labels matching the PDF page labels.
• All other Family proceedings (PD27A Chapter 7) — Bates numbering, sections labelled with letters and the count restarting at 1 in each section (A1, A2, B1, B2, C1, C2 …).

The FDR bundle is a financial remedy bundle, so it uses the Arabic scheme. Sections are still divided by letter (A, B, C …) as physical dividers and reflected in the index, but the page labels themselves run unbroken from 1 to the end. For more detail, see our financial remedy bundle guide.

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Section Order for an FDR Bundle

The FDR judge will read sections A and D first — the case summary, schedule of assets, position statements and offers tell the judge what the dispute is and what each party is asking for. Get those right.

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Documents That Belong in the FDR Bundle

The Form E

Each party's most recent Form E. If updated, include both the original and the supplementary disclosure.

Replies to Questionnaire

The questionnaires raised at the FDA, and the replies. These often run to many pages — include only the questionnaire, the replies, and any supporting documents that have been formally produced. Working drafts and chasing correspondence belong in your own file, not the bundle.

Schedule of Assets (the "asset schedule")

A single-page schedule showing every asset, its value, the source of the valuation, and its allocation under each party's proposal. This is the single most-read document in the bundle. The judge will use it to test the proportionality of any settlement. Two columns — "Wife's case" and "Husband's case" (or the equivalents) — let everyone see the size of the gap at a glance.

Position Statement (for the FDR)

A short document — typically 6–10 pages — covering:

1. The shape of the case (jurisdiction, marriage length, ages, children).
2. The matrimonial pot — what the assets are, with reference to the schedule.
3. Each party's needs (housing, income, pension).
4. The s.25 factors that matter most on these facts.
5. The party's proposal for settlement, set against the FDA position.
6. The party's analysis of the other side's case and offers to date.

The FDR position statement is filed for the judge and exchanged. It is privileged insofar as it relates to without-prejudice negotiations and is excluded from any final hearing if the case does not settle.

Draft Order

Each party should bring a draft order reflecting their proposed terms. The drafts focus the discussion: rather than arguing about percentages of "the pot", the parties argue about the precise mechanics of the order — capital lump sum, property transfer, pension sharing percentage, periodical payments term, costs.

Expert Reports

Single joint expert reports on property, business or pension on divorce (a "PODE" report). These should already be agreed evidence by the time of the FDR — disputes about expert evidence usually need to be resolved before, not at, the hearing.

Open and Without-Prejudice Offers

Both parties' offers — open offers that may be referred to at any final hearing on costs, and without-prejudice offers that drive the negotiation on the day. The judge will want to see the trajectory: where each party started, where they are now, and where the gap is.

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The FDR Judge's Process

A workable mental model:

1. Pre-reading. The judge reads the bundle in advance — case summary, schedule of assets, position statements, offers, key parts of the Form Es and expert reports.
2. Brief opening submissions. Each side, typically 10–15 minutes. The judge interrupts with questions.
3. Indication. The judge sets out the range within which a final hearing is likely to fall, often as percentages or as figures, and identifies the key issues that drive the outcome.
4. Negotiation. Parties withdraw to negotiate, often with shuttle diplomacy through the judge's clerk or back into court for further input.
5. Outcome. Either:
   • Consent order drafted on the day — sealed by the FDR judge and the matter concludes; or
   • Heads of agreement — recorded and translated into a sealed order in the following days; or
   • No settlement — the case is listed for final hearing with directions.

A skilled FDR judge will name the discount that ought to apply, identify a likely lump-sum range, and tell each side what is realistic. That candour is exactly what the FDR was designed for.

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Settling at FDR vs Going to Final Hearing

Why settle:

• Costs of a contested final hearing typically run to many tens of thousands of pounds per side. Use the court fee calculator to scope the court fees alone, and add solicitor and counsel costs on top.
• Outcome is in your hands, not the judge's.
• Speed — closure within weeks rather than months.
• Privacy — terms are recorded but the case is not relisted.
• Tax planning is easier on a known timeline.

Why not settle:

• The judge's indication is genuinely outside what you can live with.
• A point of principle (e.g. arguments about non-matrimonial property, conduct, or s.25(2)(g)).
• A material point of disclosure remains unresolved.
• One party is acting unreasonably and the open-offer regime needs to do its work on costs.

A useful framework: settlement at FDR is right when the cost of risk plus the cost of fighting exceeds the gap between what is on offer and what you might get at trial. That calculus is what the FDR judge is helping you do.

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Producing the Bundle

For a financial remedy FDR bundle:

A core bundle of essential documents may be required by the directions order. The core bundle preserves its original page numbering from the full bundle.

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Common FDR Bundle Mistakes

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How BundleCreator Helps

BundleCreator.co is designed to produce financial remedy bundles aligned with PD27A Chapter 6:

You can also use the bundle checklist to track which documents are filed and which are still outstanding before the hearing.

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Frequently Asked Questions

What is an FDR hearing?

A Financial Dispute Resolution appointment — the without-prejudice settlement hearing in financial remedy proceedings. The judge gives a candid indication of the likely outcome of a final hearing to help the parties settle.

How long is an FDR?

Typically half a day, sometimes a full day. The hearing time is short — most of the day is spent in negotiation, with the judge available for further input as needed.

Do I have to attend the FDR?

Yes. Both parties are required to attend in person (or by video where directed), and to use their best endeavours to reach agreement under FPR 9.17.

What pagination does my FDR bundle use?

Arabic numbering, consecutive through the whole bundle. PD27A Chapter 6 paragraph 6.2 governs financial remedy bundles. This is different from the Bates per-section-restart scheme used in other Family proceedings under Chapter 7.

What if we settle at FDR?

The judge can seal a consent order on the day, or shortly after if the wording needs polish. Once sealed, the order is binding — typically subject to a 28-day appeal window.

Can I refer to the FDR judge's indication if we end up at final hearing?

No. The FDR is without prejudice. The indication, the position statements and the offers exchanged are excluded from the final hearing, which is heard by a different judge.

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Your FDR Bundle Checklist

• Index — hyperlinked, accurate page references
• Case summary — max 4 pages
• Chronology — neutral, dated
• Schedule of assets — dual-column, both parties' positions
• Statement of issues — what the FDR is to resolve
• Form A — and any supplementary applications
• FDA order — and any other directions orders
• Form E (each party) — and any updates
• Replies to questionnaire
• Single joint expert reports — property, business, PODE
• Open offers — chronological
• Without-prejudice offers — chronological
• Position statement — FDR-focused
• Draft order — your proposed terms
• Bank statements / payslips / mortgage offers — supporting current needs analysis
• Pagination — consecutive Arabic, matching PDF page labels
• Bookmarks — match index
• Filing — 14 days before FDR (verify directions)

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This guide provides general information about FDR hearings and bundles in England and Wales. It is not legal advice. For advice specific to your case, consult a Resolution-accredited family solicitor.

Sources:

• Practice Direction 27A
• Family Procedure Rules Part 9 (Financial Remedy)
• GOV.UK Family Court Statistics Q3 2025
• Resolution — Guidance on financial remedy proceedings
• Court fee calculator — BundleCreator
• Bundle checklist — BundleCreator