How to Prepare a Schedule of Loss for Personal Injury Claims

Author: Stevie Hayes | Last updated: March 2026

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Quick Answer

A schedule of loss (sometimes called a schedule of special damages) is the document that itemises every financial loss and expense arising from your injury. It is served alongside the particulars of claim and updated as your case progresses. The schedule must distinguish between past losses (already incurred) and future losses (projected costs), and every figure should be supported by documentary evidence. Getting your schedule right is critical — it directly determines the amount of compensation the court can award for special damages.

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Introduction

If medical evidence tells the court what happened to your body, the schedule of loss tells the court what happened to your finances. It is, in blunt terms, the document that puts a price on every consequence of your injury that can be measured in pounds and pence.

Yet despite its importance, the schedule of loss is one of the most commonly mishandled documents in personal injury litigation. Claimants either overstate losses without evidence (inviting judicial scepticism), understate them through ignorance (leaving money on the table), or fail to update the schedule as the case develops (creating inconsistencies that the defendant will exploit).

This guide explains how to prepare a schedule of loss that is accurate, persuasive, and properly supported by evidence. Whether you are a solicitor drafting a multi-track schedule with Ogden table calculations or a litigant in person preparing a small claims schedule, the principles are the same.

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What Is a Schedule of Loss?

A schedule of loss is a structured document that lists every head of financial damage (special damages) that the claimant seeks to recover. It is distinct from general damages, which compensate for pain, suffering, and loss of amenity — though the schedule may reference the Judicial College Guidelines to indicate the bracket of general damages claimed.

The Legal Basis

Under CPR Part 16.4, the particulars of claim in a personal injury case must include:

• Details of any injuries sustained
• A schedule of past and future expenses and losses claimed
• The claimant's date of birth (for calculation of future losses)

Practice Direction 16, paragraph 4.2 further requires that the schedule attaches or is accompanied by a medical report about the personal injuries alleged.

The schedule is a living document. Courts expect it to be updated — typically an amended schedule is served before trial reflecting the most current position.

Schedule vs Counter-Schedule

The defendant serves a counter-schedule in response, challenging individual items of loss. The counter-schedule either agrees the claimed amount, proposes a lower figure, or disputes the claim entirely. Both documents go into the trial bundle.

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The Structure of a Schedule of Loss

A well-drafted schedule follows a logical structure that mirrors the heads of damage recognised by the court.

Past Losses (Pre-Trial)

Past losses are financial losses and expenses already incurred between the date of the accident and the date of trial. They are relatively straightforward because they can be evidenced by receipts, invoices, and payslips.

Past Loss of Earnings

This is often the largest single item in the schedule. To calculate it accurately:

1. Establish your pre-accident earnings — Use payslips (at least three months, ideally twelve), P60s, or tax returns
2. Identify the period of absence — From employer letters, fit notes, or self-certification records
3. Calculate net lost earnings — The court awards net (after tax) earnings, not gross
4. Deduct any sick pay received — Statutory sick pay (SSP), contractual sick pay, and any insurance payments reduce the loss
5. Account for any earnings during recovery — If you returned to work part-time or in a reduced capacity, only the shortfall is claimed

For self-employed claimants, past loss of earnings requires more detailed evidence: tax returns, business accounts, invoices, and — ideally — an accountant's letter confirming the impact on revenue and profit.

Past Medical Expenses

Include every medical cost incurred as a result of the injury:

• Prescription charges
• Private physiotherapy or treatment fees
• Counselling or psychological therapy costs
• Medical equipment (crutches, braces, orthotics)
• Over-the-counter medication (supported by receipts where possible)

Even relatively small amounts should be included. They accumulate, and their inclusion demonstrates the thoroughness of your case.

Past Travel Expenses

Travel to and from medical appointments, hospital visits, and rehabilitation is recoverable:

• Mileage at HMRC approved rates (currently 45p per mile for the first 10,000 miles)
• Public transport fares (with tickets or bank statements as evidence)
• Parking charges
• Taxi fares where driving was not possible

Keep a travel log if possible — a simple spreadsheet recording each journey, its purpose, the distance, and the cost.

Past Care and Assistance

If family members or friends have provided care or assistance because of your injuries, this has a quantifiable value even though no money changed hands. The principle was established in Housecroft v Burnett [1986] 1 All ER 332 and affirmed in Evans v Pontypridd Roofing Ltd [2001] EWCA Civ 1657.

Care is typically valued at the National Joint Council (NJC) spinal column point rate or a reasonable commercial rate, discounted by 25-33% to reflect that the care was provided gratuitously.

Document the care by keeping a diary of what assistance was provided, by whom, for how long, and what it involved (cooking, cleaning, personal care, childcare, driving).

Miscellaneous Past Losses

Other commonly claimed past losses include:

• Damaged clothing or personal items
• Home adaptations (handrails, stairlifts for temporary use)
• Additional heating costs during recovery
• Cost of replacement services (gardening, decorating, household tasks)

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Future Losses (Post-Trial)

Future losses are projected costs and losses that will continue after the trial. They require more careful calculation because they involve prediction — and the court applies specific methodologies to ensure accuracy.

Future Loss of Earnings

This is where the schedule becomes more complex. If your injuries prevent you from returning to your pre-accident employment — or reduce your earning capacity permanently — you can claim future loss of earnings.

The calculation involves:

1. Annual net loss — The difference between what you would have earned and what you can now earn
2. Multiplier — A figure derived from the Ogden Tables that reflects the number of years of future loss, discounted for accelerated receipt and life contingencies
3. Result — Annual loss x multiplier = lump sum award

The Ogden Tables

The Ogden Tables (formally: Actuarial Tables with Explanatory Notes for Use in Personal Injury and Fatal Accident Cases) are published by the Government Actuary's Department and are used by courts throughout England and Wales to calculate future loss multipliers.

The tables account for:

• The claimant's age at trial
• Retirement age
• The discount rate (currently set by the Lord Chancellor)
• Reduction factors for contingencies other than mortality (Tables A-D)

The current discount rate is a critical variable. When the discount rate is low (or negative), multipliers increase significantly, resulting in higher awards. The rate is periodically reviewed and has been a source of considerable debate.

Future Medical Treatment

If you will need ongoing treatment, the cost must be quantified:

• Likely future surgical procedures (with expert evidence of cost and probability)
• Ongoing physiotherapy or pain management
• Psychological therapy
• Medication costs
• Future prosthetics or medical equipment

Each item requires supporting expert evidence — usually from the medical expert who prepared the initial report, or from a specialist in the relevant field.

Future Care and Assistance

For serious injuries, future care costs can be the largest head of damage. The calculation requires:

• A care expert's report detailing the type, frequency, and duration of care needed
• Costing at commercial rates (for professional care) or gratuitous rates (for family care)
• Ogden multipliers applied to the annual cost

Smith v Manchester Award (Loss of Earning Capacity)

Where the claimant has returned to work but their injuries make them more vulnerable in the labour market, the court may award a Smith v Manchester lump sum (named after Smith v Manchester Corporation (1974) 17 KIR 1). This is typically expressed as a multiple of the claimant's annual net salary — commonly between six months and two years — and reflects the risk that the claimant may lose their current job and struggle to find equivalent employment.

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General Damages

Whilst general damages (pain, suffering, and loss of amenity, or PSLA) are assessed by the judge rather than calculated arithmetically, your schedule should reference the bracket of general damages claimed by reference to the Judicial College Guidelines for the Assessment of General Damages in Personal Injury Cases.

The current edition provides brackets for virtually every type of injury. For example:

These figures are regularly updated. Always check you are using the most current edition.

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Evidencing Your Schedule

The golden rule of schedule drafting is this: every figure must be supported by a document in the bundle.

Cross-reference each line item in the schedule to the relevant page number in the trial bundle. For example:

Past loss of earnings: £8,450.00 (see payslips at [B/23-35], employer's letter at [B/36], fit notes at [B/37-39])

This approach achieves two things. First, it demonstrates that your claimed losses are real and documented. Second, it makes the judge's task easier — and judges appreciate efficiency.

What If You Have Lost Receipts?

For small items where receipts have been lost, a witness statement confirming the expenditure, supported by bank statements showing the payments, may suffice. However, the evidential weight will be lower than a contemporaneous receipt. For larger items, the absence of documentary evidence is a serious problem.

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Common Mistakes in Schedules of Loss

1. Claiming Gross Rather Than Net Earnings

Courts award net loss of earnings (after tax and National Insurance). Claiming gross figures overstates the loss and damages your credibility.

2. Failing to Give Credit for Payments Received

You must deduct statutory sick pay, contractual sick pay, and any insurance payments from your earnings claim. Failing to do so is misleading and will be challenged by the defendant.

3. Not Updating the Schedule

A schedule prepared six months before trial will be out of date. Always serve an updated schedule reflecting the current position. The judge needs current figures.

4. Omitting Future Losses

Claimants acting without legal representation sometimes focus exclusively on past losses and forget to claim future losses. If your injuries have ongoing consequences — reduced earning capacity, continuing treatment needs, or ongoing care — these must be quantified.

5. Failing to Apply the Ogden Tables Correctly

The Ogden Tables are technical, and misapplying them can significantly under- or over-state future losses. If your claim involves substantial future losses, consider instructing an actuary or forensic accountant.

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Preparing Your Schedule with Supporting Documents

Organising a schedule of loss alongside its supporting evidence is one of the most time-consuming aspects of personal injury litigation. Each figure needs a corresponding document, and each document needs to be in the right place in the bundle.

BundleCreator.co streamlines this process by providing structured personal injury bundle templates with dedicated sections for financial evidence. You can upload payslips, receipts, invoices, and medical expenses, organise them into the correct sections, and generate a paginated, indexed bundle where every document is easy to find — exactly what the judge needs.

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The Defendant's Counter-Schedule

Once you serve your schedule, the defendant must serve a counter-schedule responding to each head of loss. The counter-schedule will either:

• Agree the claimed amount
• Propose a lower figure with reasons
• Dispute the claim entirely (for example, denying that a particular loss was caused by the accident)

Review the counter-schedule carefully. Where the defendant has agreed figures, those items are effectively settled. Where figures are disputed, you know exactly what evidence to emphasise at trial.

Both the schedule and counter-schedule must be included in the trial bundle.

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Frequently Asked Questions

When should I serve my schedule of loss?

The initial schedule should be served with, or shortly after, the particulars of claim. An updated schedule should be served before trial — typically in accordance with the court's directions, which often require an updated schedule at least 14 days before the hearing.

Do I need to include general damages in my schedule of loss?

Strictly, general damages (pain, suffering, and loss of amenity) are assessed by the judge and not itemised in the schedule. However, it is common and helpful practice to include a section referencing the Judicial College Guidelines bracket for the claimed injuries, giving the court a starting point for its assessment.

What are the Ogden Tables and how do I use them?

The Ogden Tables are actuarial tables published by the Government Actuary's Department. They provide multipliers used to calculate lump sum awards for future losses. You select the appropriate table based on the type of loss, the claimant's age, and the retirement age, then apply reduction factors from Tables A-D to account for contingencies other than mortality. If your future loss claim is complex, consider seeking professional help with the calculation.

Can I claim for care provided by my family?

Yes. Under the principle established in Housecroft v Burnett, gratuitous care provided by family members or friends has a recoverable value. It is typically calculated at a reasonable hourly rate, discounted by 25-33% to reflect that no commercial transaction took place. You must evidence the care with a diary or log of what assistance was provided, when, and by whom.

What if the defendant does not serve a counter-schedule?

If the defendant fails to serve a counter-schedule, you should draw the court's attention to this failure. The judge may draw adverse inferences from the defendant's failure to engage with your claimed losses, though the court will still assess the evidence independently.

How detailed does my schedule need to be for a small claims track case?

Small claims track schedules are less formal but should still itemise each head of loss with supporting evidence. Judges in the small claims track appreciate clarity and brevity — a one- or two-page schedule with referenced supporting documents is usually sufficient.

Can I use BundleCreator to prepare my schedule of loss alongside my bundle?

Yes. BundleCreator.co provides personal injury bundle templates that include dedicated sections for the schedule of loss and its supporting financial documents. You can organise payslips, receipts, medical invoices, and other evidence into the correct sections and generate a fully paginated bundle with everything the judge needs in one place.

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Next Steps

Start your schedule of loss early — ideally as soon as you have a clear picture of your past losses. Keep a running record of every expense and every day of lost earnings, and store the supporting documents in an organised folder.

If you are preparing for trial, BundleCreator.co can help you bring your schedule and supporting evidence together into a professional, court-ready bundle. With structured templates for personal injury claims, automated pagination, and an intuitive document organiser, it takes the administrative burden off your shoulders so you can concentrate on presenting the strongest possible case.