Regulation of the funeral plan market
On 5 July 2021, the Financial Conduct Authority (FCA) launched a consultation (CP21/20) on its proposals for regulating the pre-paid funeral plan sector. This is part of...
Read the guideSPECIALIST SERVICES
FCA Regulated Since July 2022Funeral Plans Regulation & Compliance
Permissions, customer protection and operating controls for funeral plan firms.
Since July 2022, the FCA regulates firms providing pre-paid funeral plans. We have supported 100+ businesses through FCA authorisation since 2019, and we're here to help funeral plan providers navigate regulatory requirements with confidence.
SERVICE OVERVIEW
Funeral Plan Authorisation and Compliance
Help funeral-plan providers and intermediaries understand permissions, customer protection and operating controls.
Funeral-plan providers, intermediaries and firms reviewing their regulatory model. A practical route through permissions, governance, customer protection and ongoing compliance.
Evidence we help you build
- Permissions and operating model
- Customer protection and communications framework
- Governance and resource evidence
- Monitoring and regulatory reporting
Typical timeframe
Ready to submit within 6 weeks, often sooner
Under FSMA the FCA must decide within 6 months of receiving a complete application, or within 12 months of receiving an incomplete one.
Ideal for
- Funeral-plan providers
- Intermediaries
- Firms reviewing their regulatory model
Your Path to FCA Compliance
- Direct FCA Authorisation
- Appointed Representative
- Orderly Cessation
How MEMA helps you
- Pre-Authorisation Services
- Application Support
- Post-Authorisation Support
Your Path to FCA Compliance
Three options available for funeral plan providers
Direct FCA Authorisation
Full regulatory authorisation
Apply to the FCA for direct authorisation as a funeral plan provider
Benefits
- Complete control over operations
- Full FCA-authorised status
- Ability to appoint representatives
- Direct relationship with FCA
Requirements
- Full FCA application process
- SM&CR compliance obligations
- Consumer protection standards
- Suitability and solvency requirements
- Ongoing regulatory reporting
Appointed Representative
Operate under a Principal Firm
Operate as an Appointed Representative under an FCA-authorised Principal Firm
Benefits
- Lower regulatory burden
- Principal handles FCA relationship
- Faster route to market
- Reduced compliance costs
Requirements
- Find suitable Principal Firm
- AR agreement requirements
- Compliance with Principal's policies
- Note: Introducer ARs have fewer requirements
- Ongoing activity reporting
Orderly Cessation
Exit the market compliantly
For firms unable or unwilling to pursue authorisation
Benefits
- Compliant exit from market
- Customer protection maintained
- Orderly wind-down process
- Regulatory obligations met
Requirements
- Not entering into new plans after 29 July 2022 unless authorised
- Customer plan fulfilment arranged
- Proper customer communications
- Transfer or refund processes
- FCA notification requirements
How MEMA Supports Funeral Plan Providers
Comprehensive support from pre-authorisation through ongoing compliance
Pre-Authorisation Services
Preparation for FCA application
- Dedicated regulatory adviser assignment
- Comprehensive fact-finding
- Compliance risk identification
- Regulatory business plan preparation
- Compliance monitoring document creation
Application Support
Managing your FCA application
- Complete FCA application forms
- Supporting documentation preparation
- Application submission
- FCA query management
- Liaison with FCA throughout process
Post-Authorisation Support
Ongoing compliance guidance
- Tailored compliance documentation
- Ongoing compliance monitoring
- Regulatory advisory services
- Staff training programmes
- FCA correspondence support
Understanding Funeral Plan Regulation
Pre-paid funeral plans allow customers to pay upfront or in instalments for funeral services, helping protect against rising costs and easing financial burden on families
Regulatory Timeline
Key dates in funeral plan regulation
- The FCA began regulating pre-paid funeral plans on 29 July 2022
- Providers that were not authorised by then had to stop entering into new plans
- Ongoing: Full compliance required for all providers
Consumer Protection
Why the FCA now regulates funeral plans
- Protection against rising funeral costs
- Safeguarding customer payments
- Ensuring plan providers are solvent
- Clear disclosure requirements
- Suitability standards for vulnerable customers
FCA Compliance Requirements
Core regulatory obligations for funeral plan providers
SM&CR Obligations
Senior Managers & Certification Regime requirements
- SMF appointments
- Certification regime
- Conduct rules
- Prescribed responsibilities
Consumer Protection
Safeguarding customer interests
- Clear plan disclosures
- Fair value standards
- Vulnerable customer support
- Complaints handling
Suitability Standards
Ensuring plans meet customer needs
- Customer needs assessment
- Product suitability checks
- Affordability considerations
- Clear recommendations
Solvency Requirements
Financial stability and security
- Capital adequacy
- Trust fund management
- Insurance arrangements
- Financial monitoring
Regulatory Reporting
Ongoing FCA reporting obligations
- Financial returns
- Data reporting
- Material changes notification
- Annual compliance attestations
Documentation Standards
Required policies and procedures
- Terms and conditions
- Customer agreements
- Compliance policies
- Record retention
Key Funeral Plan FCA Compliance Requirements
What the FCA expects, and the evidence behind it.
Permissions
Map provider, intermediary and regulated activity roles.
Customer protection
Review fair treatment, communications and vulnerability.
Resources
Assess governance, financial and operational capability.
Oversight
Maintain monitoring, reporting and issue management.
What you will need to produce
- Permissions and operating model
- Customer protection and communications framework
- Governance and resource evidence
- Monitoring and regulatory reporting
Clarify the specialist operating model
Provider and intermediary roles should be clear before controls are assessed.
- Permissions and roles
- Map the provider, intermediary, introducer and regulated-activity responsibilities.
- Customer journey
- Review sales, disclosures, vulnerability, support, cancellation, transfer and refund processes.
- Dependencies
- Identify administrators, plan providers, client-money or operational dependencies and oversight.
Evidence customer protection and resilience
Specialist-sector confidence comes from practical controls and visible oversight.
- Governance
- Set senior accountability, monitoring, reporting and issue escalation.
- Resources
- Assess financial, operational and people resources against the firm's model.
- Regulatory reporting
- Maintain evidence of reviews, notifications, customer outcomes and remedial action.
Experienced Funeral Plan Regulatory Support
Supporting 100+ firms through FCA authorisation since 2019
- 100+ firms authorised
- Ex-FCA regulators on team
- Big 4 consulting experience
- Funeral plan sector expertise
- Tailored compliance solutions
- Ongoing regulatory support
The Funeral Plan FCA Compliance journey
The route from scoping your permissions to a decision. The FCA's part of it is fixed; the preparation before it is where applications are won or lost.
- 1Establish your role in the planProviding a funeral plan and selling one are different activities, and how the customer's money is held changes what the application has to evidence.
- Confirm whether you provide, arrange or distribute plans
- Establish how customer money is held and protected
- Identify the permissions the model actually needs
- 2Evidence customer protectionThe regime exists because customers pay years in advance, so the application is assessed on what happens to their money and their plan in the meantime.
- Evidence customer protection and money arrangements
- Prepare communications and vulnerability arrangements
- Show the governance to run the plan long term
- 3Submit to FCASubmitted through the FCA's Connect portal with the application fee of £2,820 – £11,260.
- Complete submission through Connect
- Application fee paid at submission
- Case officer assigned by the FCA
- 4FCA reviewThe statutory determination period is 6–12 months — six months for a complete application, twelve if it is incomplete when submitted.
- Case officer raises questions on the submission
- Further information requests answered and evidenced
- Weak responses, not complexity, are the common cause of delay
- 5Permission grantedPermission is granted and the firm can carry on the regulated activity, subject to any requirements attached to it.
- Permission recorded on the Financial Services Register
- Any limitations or requirements confirmed
- Reporting and supervision obligations begin
Related FCA Guidance
Deeper reading on the regulatory framework behind funeral plan regulation.
Explore our other services
End-to-end support across the full regulatory lifecycle.
Frequently asked questions
Which funeral-plan roles need to be distinguished?
Provider, intermediary, introducer and other distribution roles can create different permissions, responsibilities and customer-protection questions. The operating model should make those hand-offs clear.
What customer-protection issues should be reviewed?
The review can cover communications, fair treatment, vulnerability, demands and needs and, where a personal recommendation is made, suitability. It can also cover complaints, cancellation or transfer processes and the evidence supporting customer outcomes.
What resources and governance evidence matter?
The firm should be able to explain senior accountability, financial and operational resources, oversight of providers, monitoring, reporting and how issues are escalated and resolved.
Can existing funeral-plan arrangements be reviewed?
Yes. We can assess the current permissions, customer journey, documentation and control framework, then identify practical improvements or a change route.
Need Funeral Plan Regulatory Support?
Whether you need FCA authorisation or ongoing compliance support, we're here to help
Phone: 0330 133 0811
Email: contact@memaconsultants.com