A schedule of special damages is an itemised record of the financial losses and expenses connected with a personal injury claim. It helps explain what each amount is for and which documents support it. A total on its own does not show whether a cost arose from the injury or whether it has already been paid by somebody else.
This guide explains how to organise that information for an Irish claim. The working table below is an original record-keeping aid. It does not replace the Injuries Resolution Board’s form, a court document or advice about what can be claimed.
What belongs in a schedule of special damages?
The Injuries Resolution Board identifies medical expenses, lost earnings, other accident-related expenditure and vehicle damage among the possible financial losses. Serious cases can also involve future financial needs. Whether a particular item is recoverable depends on the facts and evidence; listing it does not guarantee payment. See the Board’s explanation of special damages.
Keep the financial record separate from your account of pain, symptoms and daily restrictions. The Board’s guidance on the Personal Injuries Guidelines confirms that the Guidelines do not set special damages such as actual medical expenses or lost wages.
Start with a working expense table
Use one row for each expense. Give its supporting documents the same reference so that the amount can be checked without searching through every receipt. Copy the following headings into a notebook or spreadsheet and add rows as needed.
| Reference and date | Item and injury-related reason | Amount and payment status | Evidence and anything to clarify |
|---|---|---|---|
| EXP01 / date | Describe the item, supplier and reason | €___; paid or unpaid | Receipt/invoice reference; reimbursement details |
| EXP02 / date | Describe the item, supplier and reason | €___; paid or unpaid | Receipt/invoice reference; reimbursement details |
| EXP03 / date | Describe the item, supplier and reason | €___; paid or unpaid | Receipt/invoice reference; reimbursement details |
Keep paid costs, unpaid invoices and estimates distinguishable. An estimate for proposed treatment should not appear as money already spent. Record who paid an expense and any payment received towards it, including payments from the respondent or insurer. Do not assume that every reimbursement or benefit is treated identically; flag it for review.
A fictional record-keeping example
Suppose someone has a €60 GP receipt, an €18 taxi receipt for that appointment and a €4 parking receipt for a separate hospital visit. The recorded expenditure is €82. A bank entry showing the same €18 taxi payment is supporting evidence, not a fourth expense. This is an arithmetic example only: it is not a client case, a suggested treatment price or a prediction of the amount recoverable.
Which supporting documents should you keep?
- Treatment and prescriptions: dated invoices, receipts and the relevant referral, prescription or appointment details.
- Travel: journey dates, destination, reason and tickets, taxi receipts or parking receipts. Explain how the journey relates to treatment or the injury.
- Equipment or paid help: the invoice, payment record and an explanation of why the injury made it necessary.
- Damaged property: photographs, repair estimates, invoices and details of any insurance payment, where relevant to the claim.
- Application and report charges: the payment confirmation and the doctor’s invoice for the report submitted with the application.
If a receipt is missing, ask the supplier for a duplicate or an itemised statement. Keep the payment record and explain the gap honestly. A bank entry may show that money was paid without showing what it bought. Do not create a replacement receipt yourself. Our personal injury evidence guide covers the wider records that may support a claim.
Keep earnings and future needs in separate sections
Lost earnings usually need their own calculation, supported by employment or business records and evidence of why the injury affected work. Record wages, sick pay and relevant benefits actually received; do not simply multiply days absent by a usual daily wage. Our loss of earnings guide explains employee and self-employed evidence in detail.
If treatment, assistance or reduced earnings may continue, identify those concerns separately. A past-expenses total cannot resolve future needs. Do not invent a future treatment schedule or apply an assumed annual care rate; the appropriate medical and financial evidence will depend on the case.
Using the official Injuries Resolution Board schedule
The Board’s official Schedule of Special Damages (PDF) asks for claim details, amounts, supporting receipts or vouchers and the position on a loss of earnings certificate. It also contains a claimant declaration concerning the completeness of the claim and payments from the respondent or their insurers. Read that declaration before signing and resolve any omission or uncertainty first.
The Board’s assessment guidance explains that it asks for a written list of expenses and supporting financial information. Keep a dated copy of what you submit. If another expense arises or an error is discovered, explain the change rather than silently replacing the earlier version.
Do not postpone dealing with a claim deadline while waiting for every receipt. The Board’s application guidance says expense details can be supplied after the application. That does not remove the separate requirements for a complete application or extend the legal time limit.
Check the figures before agreeing the claim
Reconcile the schedule against its documents: remove duplicated entries, identify unpaid amounts and check reimbursements and missing evidence. Keep a list of unresolved future needs alongside it.
Recording a fee does not mean it must be repaid in full. Section 44 of the Personal Injuries Assessment Board Act 2003 gives the Board discretion over specified fees and expenses reasonably and necessarily incurred in complying with its process. Professional legal fees and other outlays also need separate consideration; see our guide to legal costs.
A useful schedule makes each claimed loss understandable and checkable. If an assessment or settlement is being considered while expenses, earnings or future treatment remain unresolved, have those points addressed before deciding whether to accept it.
For related claimant information, visit Legal Updates.
