Loss of Earnings and Future Loss Reports
Standalone and supporting loss of earnings reports across all negligence contexts. We reconstruct employment and earnings history, apply Ogden multipliers, and address pension loss using appropriate actuarial or Blamire approaches.
What This Service Covers
- Past loss of earnings and future loss of earnings and earning capacity across all negligence contexts.
- Employment records reconstruction, HMRC and payroll analysis, career trajectory modelling, Ogden multipliers, Smith v Manchester, and pension loss (Blamire and actuarial approaches).
- Standalone instructions where medical evidence exists but financial quantum is required.
When You Need This
- Any negligence claim where past or future loss of earnings is a component of damages.
- Instructions following medical expert reports that establish disability but not financial quantum.
- Rebuttal of opposing loss of earnings schedules in litigation.
Our Approach
- Review of employment, tax, and benefits records.
- Past loss of earnings calculation to trial date or agreed cut-off.
- Future loss modelling with Ogden Tables and stated assumptions on retirement and capacity.
- Pension loss and CPR Part 35 compliant report; joint statement if directed.
Earnings Reconstruction and HMRC Records
Past loss of earnings is reconstructed from PAYE records, accounts, contracts, and benefits history. Where earnings fluctuate, we analyse a representative period and explain the basis for the pre-injury earning level used as the multiplicand for future loss.
This standalone service is frequently instructed where medical experts have established disability but solicitors require specialist financial quantum analysis before exchange of expert evidence.
Ogden Multipliers and Discount Rate
Future loss of earnings uses Ogden multipliers applied to the net annual loss (multiplicand). The discount rate reflects the assumption that a lump sum award will be invested to meet future losses. Reports identify the rate used and reference the applicable table edition.
CPR Part 35 Compliance
Loss of earnings reports address pre-trial past loss, future multipliers, and pension loss methodology in accordance with CPR Part 35 and established case law on earning capacity.
Under CPR Part 35 and Practice Direction 35, the expert's duty is to the court. Reports must state qualifications, instructions, facts, assumptions, methodology, opinion, conclusions, and contain a statement of truth. Where proceedings are in the family court, FPR Part 25 applies to expert evidence.
Frequently asked questions
- Can I instruct a loss of earnings expert if I already have a medical report?
- Yes. This is a common instruction. We translate medical assumptions on capacity and prognosis into financial quantum, reconstruct past earnings, and model future loss using Ogden Tables and pension loss methodology as appropriate.
Related Services
Instruct a negligence loss expert witness for your case, or contact us in confidence to discuss requirements.
Need a financial loss expert for this type of claim?
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