Funeral Plans

Dignity publishes White Paper calling for stronger regulation of the funeral plan sector

Dignity has set out its plan for a stronger form of regulation in the funeral plan sector with a document which explains how regulation can be improved to better protect consumers.

Dignity’s White Paper – ‘Strengthening regulation in the funeral plan sector’ – sets out a detailed vision for what stronger but proportionate regulation in the funeral planning market should look like. The paper has been developed with regulatory experts and follows the report Dignity conducted with Fairer Finance in July 2017, which highlighted misleading advertising and aggressive telesales methods.

Research, conducted for Dignity, by Matter Communications in March, shows that whilst improvements have been made since Dignity first raised awareness of the problems in the funeral plan sector last year, significant issues remain.

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The research found that new providers entering the market, as well as some of the providers identified last year work with websites purporting to be “comparison sites” and sell plans via telesales agents who use high pressure sales calls to generate their sales.

None of these providers are registered with the Funeral Planning Authority (FPA).

However, the research suggested a reduction in the volume of call centre activity, and some improvement in conduct. During this period the FPA have been pro-actively engaging with FPA and non-FPA firms to raise their game, campaigning for funeral directors and customers not to use non–FPA registered firms, and actively reviewing its rule-book and code of conduct.

Dignity’s White Paper will feed into the FPA’s review of its rules and considers, amongst other factors, why stronger regulation is necessary, what regulation currently exists in the funeral plan sector, what the expected outcomes of enhanced regulation of the funeral plan sector might be and what the conduct and prudential rules should cover.

One of the proposals set out in the White Paper is a model of stronger regulation that would see the existing Funeral Planning Authority (FPA) placed on a statutory footing with all firms compelled to register with the regulator in order to trade.

Dignity’s proposed approach to regulation set out in the White Paper is based on many of the principles that underpin the Financial Conduct Authority (FCA), Prudential Regulation Authority’s (PRA) and the Pension Regulator’s existing approach to regulation, and includes:

  • Compulsion of all plan providers to be covered by the regulator, together with adequate powers for the regulator to ensure appropriate enforcement including license to trade.
  • Applying new minimum standards to both plan providers and distributors of funeral plan products, both in terms of construction, promotion and management, as well as suitability and capability of individuals responsible for performing appropriate tasks.
  • Ensuring that any proposals are proportionate and recognise the differing nature, size and complexity of the business models of various participants in the funeral plan sector whilst respecting the principle that there needs to be an agreed set of minimum standards.
  • Recognition that any new set of regulations will require an appropriate period of transition to allow individuals and firms to migrate existing business practices to the new rules.
  • Setting out twelve key principles that conduct regulation should follow covering areas including product oversight, dealing with vulnerable customers, the role of management, and oversight and governance of distribution channels.
  • Setting out clearer prudential rules, including establishing rules for a minimum solvency margin and putting in place ongoing monitoring of the solvency of funeral plans.

Simon Cox, Dignity’s head of insight and external communications, said: “Following the research we conducted last year and the report with Fairer Finance, it was important to maintain momentum. We have seen growing support amongst policy makers and consumer groups for action and have therefore drafted a White Paper detailing a stronger form of regulation which will better protect the consumer.”


Dignity has co-sponsored a follow-up report by Fairer Finance along with a number of other FPA-registered providers. The report looks at what it would take for stronger regulation to be placed onto a statutory footing and will be published later this month.

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