PODE documents in financial remedy cases

REVIEWED BY: Sean McNamara on 2026-09-01

PODE stands for Potential Outcomes, Disclosure and Experts — a document used in financial remedy proceedings in England and Wales to narrow the issues before a final hearing. If you are in financial remedy proceedings, your legal team will almost certainly talk about the PODE. This guide explains what it is and why it exists.

What a PODE contains

A summary of each party's case on the key financial issues (housing needs, income, pension division, liquidity, any conduct arguments).
The potential outcomes each side contends for — typically expressed as possible divisions of the assets under section 25 of the Matrimonial Causes Act 1973.
The disclosure still outstanding — which documents remain to be produced, by whom, and by when.
The experts required — whether valuation or pension expert reports are needed, by whom, and at what cost.
The questions for the judge the parties want determined at the final hearing.

Where it fits in the process

Financial remedy cases follow the standard track under Part 9 of the Family Procedure Rules 2010: disclosure, first appointment, Financial Dispute Resolution (FDR) appointment, then final hearing.
The PODE is typically prepared between the first appointment and the FDR — often by agreement of counsel or solicitors — and is designed to focus the FDR judge on the true battlegrounds so negotiation is meaningful.
Many courts have adopted PODE (or equivalent issue-narrowing documents) through local practice directions and standard directions; the precise format varies by court.

Why it matters for litigants

It forces precision. Vague "I want what's fair" positions are stripped down into concrete outcome models with figures attached — which is often where settlement pressure first bites.
It exposes gaps. If your disclosure is incomplete, or you have no expert evidence on a pension or business valuation, the PODE makes that visible to the judge early.
It saves cost. Time at the FDR and final hearing is limited; a good PODE means the expensive court time is spent on the genuinely disputed questions, not the rest.
If you represent yourself, ask the court or the other side's solicitor what form the court expects the PODE to take — some courts publish templates.

Practical tips

Prepare your outcome models before the PODE meeting, not during it.
Be realistic about the section 25 factors — a PODE is not the place for maximalist positions you cannot support with evidence.
Check that every expert you claim to need is justified; the court controls the number and cost of experts under Part 25 of the Family Procedure Rules 2010.

Official sources

Not legal advice

YourFamilyCase.co.uk is an independent information site, not a law firm. We take no referral fees and nothing here is legal advice. Court practices around PODE documents vary — confirm the local expectation with the court or a solicitor.

Content verified against the official HMCTS court directory, gov.uk forms and fees pages, and the professional body registers (SRA, FMC, Bar Council). Last reviewed September 2026.