CP21/4: Funeral Plans: Proposed Approach to Regulation

The BSA's response to the FCA consultation

The BSA supports the FCA's regulation of the funeral plan market.

We entirely agree with the FCA's stated objective to improve outcomes for customers, with better value products, better sales practices and better controls in place.  There is clear evidence of harm to consumers, which needs to be addressed, and certain market participants have adopted practices leading to poor outcomes for some consumers.

Read the full response here.


On 5 July 2021, the FCA published PS21/8: Regulation of funeral plans - Feedback to CP21/4 and final rules. PS21/8 sets out the final rules funeral plan providers will need to follow when they come under FCA regulation from 29 July 2022.

The rules mean:

  • funeral instalment plan products will always deliver a funeral (after a moratorium period) as the FCA will be banning those that don’t guarantee this
  • cold calling will be banned and new standards on advertising will be implemented to ensure plans are sold fairly 
  • commission payments to intermediaries will be banned to ensure products represent fair value
  • those selling funeral plans are subject to full checks on their fitness to operate to improve governance standards and oversight

The BSA was broadly supportive of the proposals in CP21/4, but we expressed concern regarding the proposal to ban commission payments to intermediaries. While the FCA acknowledges the potential impact on competition in the market, we note it has decided to go ahead with the proposed ban. Intermediaries are still permitted to charge a fee to the customer direct.