CMA Review of Funerals Market Outcomes

On 9th February 2024 the Competition & Markets Authority (CMA) published its annual ‘Funerals Market – Review of Market Outcomes’. Here we highlight some of the main findings and points of interest from this report.

The CMA’s Funerals Market – Review of Market Outcomes assesses the extent to which the concerns and recommendations raised in its Funeral Investigation Final Report (published in December 2020), and subsequent legally binding Funeral Markets Investigation Order 2021, have been implemented and followed by the funerals sector. The Review also considers the impact of these recommendations.

Here we summarise what we feel are points of particular interest for our readers. However, we recommend viewing the full report here to get a complete overview of the CMA’s findings.

Concerns Highlighted Following the Initial Investigation

The original investigation was wide-ranging and was designed to identify problems in the funerals sector, particularly concerning transparency around pricing, products and services. Some of the key concerns that the Funeral Investigation Final Report highlighted arose from:

  • Low levels of customer engagement caused by the intrinsically challenging circumstances surrounding the purchase of a funeral;
  • the lack of easily accessible and clearly comparable information on the products and services provided by funeral directors, including their prices and levels of quality;
  • the lack of visibility to customers of the level of quality of care given to the decease by funeral directors;
  • high barriers to entry in the supply of crematoria services;
  • high levels of concentration in the supply of crematoria services.

‘Sunlight remedies’ Proposed and Implemented Following the Investigation

The Inquiry Group implemented a number of what they called ‘sunlight remedies’ to try to improve transparency and information sharing, including:

  • A requirement on all funeral directors and crematorium operators to disclose certain price information to customers.
  • A requirement on crematorium operators to disclose certain price information to funeral directors in the local area and other funeral directors upon request.
  • A requirement on all funeral directors to disclose particular business, financial and commercial information to customers.
  • Prohibitions on the way funeral directors solicit business from third parties, which may have resulted in preferential treatment or the inhibition of free market competition.

Ongoing Monitoring and Assessment

To enable the CMA to monitor the sector, larger funeral directors and all crematorium operators were required to supply the CMA with specific information on the goods and services they supply. 84% of funeral directors and crematorium operators required to do so provided these submissions.

In terms following the regulations, the CMA noted that whilst the overwhelming majority of firms are complying with transparency requirements set out in the Order (for example displaying Standardised Price Lists both on their website and in premises), based on complaints submitted to the CMA, around 10% of firms appear not to be doing so. The CMA say that they will be targeting these businesses to ensure compliance.

In addition to this, the CMA will continue to assess the impact and consequences of the COVID-19 pandemic on the funerals sector. Restrictions during the pandemic changed the way in which funerals could be conducted and this enforced simplification may still be affecting people’s choices (for example, with smaller, simpler funerals).

Findings of the Latest CMA Review

Findings in Relation to Revenue Per Funeral and Per Cremation

The average revenue per funeral for the period from 1st September 2022 to 31st August 2023 compared to this period the previous year showed an increase of 4% for funeral directors with 5+ branches, and 3% for funeral directors with 10+ branches. The average increase in revenue over the same period per cremation was 2%.

The report concluded that these increases are ‘consistent with a declining average revenue per funeral in real terms, given the rate of inflation including the rise in energy costs during the period of the review’. The CMA noted that during the period leading up to the investigation there had been ‘repeated cost increases above inflation for more than a decade’.

However, the Report noted that for some types of funeral, in particular unattended funerals, there were greater increases in average costs (with revenues reported by funeral directors up 12% in 2023). The majority of funerals during the period were attended, but the CMA’s data indicates ‘a gradually rising trend in the purchase of unattended funeral services’. The majority of revenue over the period for both funeral directors and crematorium operators was generated by attended funerals.


The CMA suggests that ‘its Funerals Market Investigation Order 2021 is continuing to have a beneficial impact on the costs paid by bereaved relatives when arranging a funeral’. Following more than a decade where prices had been rising above the rate of inflation, this appears to no longer be the case in most instances.

However, the CMA acknowledges that it is too early to know to what extent the new transparency measures and ongoing monitoring is keeping prices in check. This may be a temporary trend, and may also be due to restrictions around funerals during the COVID-19 pandemic, and the ongoing changes in behaviour associated with this.

The good news is that for anyone organising a funeral, greater transparency around pricing and the requirement for funeral directors and crematioria to provide customers with more detailed, clearly visible information is enabling families to make better, more informed choices.

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