Time to speak up

Fran Hall 7 Comments
Fran Hall

Dear Reader

Are you connected to funerals in any way?

Are you somebody who has an interest in what goes on in funeralworld?

Have you had to arrange a funeral, or had to think about funeral arrangements for someone close to you?

Or do you work in the funeral sector?

Have you seen or heard things that you know are just wrong?

Are you concerned about aspects of your work, prices that you can’t justify to clients, procedures that you have to follow that you find uncomfortable, things that have gone on behind the scenes that worry you?

Have you been a bit busy recently and not got round to responding to the consultation launched by the Competition and Markets Authority at the end of November?


(We wrote about the CMA’s Interim Report on the blog here and here if you want to refresh your memory)

Comments are invited on the CMA’s provisional decision to make a market investigation reference (MIR) in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services in the UK.

Such comments should be provided no later than 5pm on 4 January 2019 to:

Funeral market study team

Competition and Markets Authority

Victoria House

Southampton Row



E-mail: funerals@cma.gov.uk

This is hugely important. 

It could completely change the landscape of the funeral sector for the benefit of people who need to arrange funerals. And that, effectively, will be all of us.

Please, make sure that the CMA hears from people from all walks of life who have an interest in how the funeral sector is currently operating.

If you have relevant experience or thoughts on the proposed investigation into the funeral sector, then make your voice heard. 

If you don’t take the time to write and tell the CMA what you think, the responses received will be dominated by replies from corporate funeral operators and trade associations.

Your experience matters. 

Your opinion matters. 

You are the people the CMA need to hear from. 

It’s time to speak up.

The full interim report and details of the consultation can be downloaded here, along with the findings of the research commissioned by the CMA to understand the behaviour, experiences and decision making of people who had recently engaged the services of a funeral director.

The report is a lengthy document but well worth reading – if you haven’t got time to do so, then here is a precis of what the CMA is inviting comments on:

The CMA considers that this interim report identifies significant concerns about the effectiveness of competition in relation to the supply of funeral services at the point of need and the supply of crematoria services in the UK.’

‘The CMA welcomes representations from interested parties on the provisional decision set out in this document. The CMA wishes to stress the importance of the consultation process in assisting the CMA’s decision making and urges interested parties to engage with the consultation. Respondents may wish to reply in relation to the supply of services by funeral directors at the point of need, in relation to the supply of crematoria services, or both. In doing so, respondents may wish to consider the following questions:

Do you consider that the CMA’s analysis is correct with respect to the suspected features of concern in the supply of:

  • services by funeral directors

‘8.31    Based on the evidence and our analysis set out in section 4, our provisional view is that there are reasonable grounds for suspecting that one or more of the following features or combination of features prevents, restricts or distorts competition in the supply of services by funeral directors at the point of need in local areas:

  1. Customers’ vulnerability and difficulty in engaging at the point of need.
  2. Customers’ unresponsiveness to measures of price and quality; they largely choose a funeral director on the basis of recommendation or personal experience.
  3. Customers’ inability to assess certain aspects of quality and the value for money of all options offered given funerals are an infrequent purchase and customers are often inexperienced.
  4. Lack of transparency: reluctance of firms to publish / disclose clear prices (including online) or to provide comprehensive information on quality and range.
  5. Point of sale advantage: ability of suppliers to largely control the decision-making process leading to the sale and its outcome.
  6. Ineffective self-regulation in respect of information transparency – no mandatory publication of online prices, absence of publication of inspection reports.’
  • crematoria services 

8.33    Based on the evidence and our analysis set out in section 5, our provisional view is that there are reasonable grounds for suspecting that one or more of the following features or combination of features prevents, restricts or distorts competition in the supply of crematoria services in local areas:

  1. Customers’ vulnerability and difficulty in engaging at the point of need.
  2. Customers’ unresponsiveness to measures of price and quality; they largely choose a crematorium on the basis of location or personal experience.
  3. Low numbers of crematoria providers in local areas.
  4. High barriers to entry arising from the planning regime and high fixed costs, which limit the number of crematoria in each local area.’

Do you consider that the CMA’s analysis is correct with respect to the reference test being met in relation to the supply of:

  • services by funeral directors at the point of need (see paragraphs  8.12 to 8.37) and
  • crematoria services (see paragraphs 8.12 to 8.37)?

Do you agree with the CMA’s proposal to exercise its discretion to make a reference in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services (see paragraphs 8.38 to 8.96)?

Do you consider that the proposed scope of the reference as set out in the draft terms of the reference in Appendix F, would be sufficient to enable any adverse effect on competition (or any resulting or likely detrimental effects on consumers) caused by the features referred to in paragraphs 8.31 and 8.33 to be effectively and comprehensively remedied?

Do you consider that the features which the CMA has identified that may prevent, restrict or distort competition are capable effectively and comprehensively remedied by UILs (undertakings in lieu of a MIR)?

Do you have any view on our current thinking on the types of remedies that an MIR should consider (see paragraphs 8.66 to 8.86)? Are there other measures we should consider? 

Funeral director services:

  • Transparency remedies
  • Changes to the regulatory framework
  • Establishment of a regulatory body
  • CMA-led price regulation


  • Establishment of sectoral regulator or price regulation
  • Guidance to local authorities
  • Changes to the planning system

Other possible remedies

The CMA would particularly welcome any specific evidence from respondents in support of their views.

In addition to the above, the CMA would also welcome evidence and views on the following matters:

  1. Quality of care of the deceased: we have received anecdotal evidence that there may be varying standards of care being applied by funeral directors and would like to understand how widespread such issues may be. We would therefore like to hear from people who have witnesses standards of care which they considered to be unacceptably low.
  2. Issues specific to religious groups that are not covered in this report: we have focused our work on the transactional aspects of funerals involving funeral directors and crematoria. We believe that the issues we have identified in relation to those specific aspects would essentially be similar across all faiths (to the extent that the way they organise funerals involves transactions with funeral directors or crematoria. We are keen to find out whether we may have overlooked any issue of relevance and will seek to engage actively with the representatives of the major faiths.

Our intention is to publish on the CMA’s website an aggregated and anonymised summary of submissions from individuals, although if you prefer, you can indicate that you would prefer for your response to be published in full.

We intend to publish all responses from business and other organisations on the CMA’s website, except those responses marked as confidential. Respondents may request that their response be kept confidential. If you would like your response to remain confidential, clearly mark it to that effect and include the reasons for confidentiality. Please restrict any confidential material to the appendices to your response.

We will redact, summarise or aggregate information in published reports where this is appropriate to ensure transparency whilst protecting legitimate consumer or business interests.’

We have a chance to make a change. Right now.

Do you want to improve things for bereaved people? Do you want to be a responsible citizen who stands up for what they know is right?

Then find ten minutes to tell the CMA what you think.

Thank you.


  1. Fran Hall

    Thank you for this timely summary Fran and for opening up comments.

    I want to reply to the consultation as a member of the public but it’s hard to do so in an informed way – in the same way it is hard for a member of the public to make fully informed decisions during the process of arranging a funeral. I’m hoping you can help me understand a bit more before I respond to the consultation. In Fran’s precis of the report, there is a reference to the crematoria sector. The emerging idea seems to be that more crematoria would figure as part of the solution. This seems to me to be counter to cost saving and also to have a negative environmental impact. Crematoria running efficiently at capacity without taking up further land would make more sense to me in the longer term – and more duties for local authorities in respect of body disposal and ensuring that people who need an affordable funeral can have one would seem a more logical way forward to me.

    These are the things I would like to understand better:

    – when someone dies at home and is not required to be taken away for a post-mortem, what happens then?

    – for someone who has died in hospital, how long will a hospital mortuary keep a body?

    – is there anywhere at the moment, other than at an undertakers or at home, that a body can be kept while the relatives plan for the funeral?

    – do any undertaking companies offer a body storage only service?

    – is there any research around the percentage of people who would be happy to have a funeral service in a venue of their choice with the body present in the coffin at the service and for the coffin then to be taken away to a crematorium, not necessarily local, which the relatives do not necessarily visit themselves but which can cremate at an affordable price (most likely a local authority crematorium?)

    – how easily could that be done without undertakers e.g. who would put the body into the coffin from cold storage on the day of the funeral, how easy would it be for relatives to transport the coffin from a vehicle in and out of the building and vehicle for the funeral service, can a body legally be transported to a crematorium by someone other than by relatives or undertakers?

    – why are some former local authority crematoria now in the hands of private sector funeral industry?

    – can a CMA study result in recommendations for the public sector or is the funeral industry being treated as though it is 100% private sector enterprise?

    1. Fran Hall

      Very thoughtful comments here. I see the deadline is looming so will offer some brief thoughts if they might help:

      – When someone dies at home they can stay there until the funeral but the Dr(s) will still need to complete the necessary papers for cremation/burial.

      – Hospital mortuaries can keep the body for long times but do not all have the space to be a widespread interim solution for many.

      – There are few (very few in my understanding) coroner’s mortuaries that exist separately from hospital ones. Post-mortem examinations happen there and they may have their own collection systems and fridge space. I have also seen fridge space at a crematoria.

      – Some undertakers will be flexible to just collect and store – this may not come cheap or as easy as it could!

      – I understand there is on-going research into the growing trend of direct or simple creations (separating the practical and ceremonial). I hope there to also be comprehensive studies into the importance of ritual for grieving people.

      – Tomorrow morning I am offering exactly the type of service you talk of here – I will put someone into a coffin and use my car as the hearse.

      (There is currently no legal authority that a funeral director/family member has to transport a body)

      Interesting points at the end too – I’d love to work with local authorities to provide flexible, professional funeral support to enable people to have highly personal, cost-effective, meaningful funerals.

      In short, I was interested to read your comments and can only say that in my area I’m working to encourage just this type of questioning and providing the services that people need to fill in the gaps.

      1. Fran Hall

        Thank you Tora. That is really helpful. Hope I can get a reply in on time. I am one of the fortunate ones for whom expense has not been an issue when organising a funeral. But I was thinking along the lines of the last funeral I helped organise and whether or not the more expensive elements – which were not the most meaningful bits to us anyhow – could have been cut out. It was interesting, because the way that we wanted it did not seem in the least novel to me but clearly the fixer at the undertakers (which I realise afterwards was Dignity) found it challenging and we spent ages in the undertakers when really we needed to be off doing other arrangements. We organised to have the ceremony at the local church. The body was taken to the church by the undertakers in a hearse and then afterwards to a crematorium that was able to offer an appointment that same day. We did not wish to attend the crematorium at all. It was finding a crematorium with a free slot that day which seemed to tax the “fixer”. I’m not quite sure why as we wer e not being price conscious, there was a long gap until the day of the cremation (3 weeks I think), we live in the south -east (several crematoria within an hour or so), and we would have been happy to discuss “holdover” of the body if she had raised it, I am sure. She just kept on saying that there had to be a free service slot at the crematorium at the right time for her to be able to make a booking for us – which seemed odd when we didn’t want the crematorium service slot. she would have preferred us to pick a different day for the funeral but for various reasons this was impossible for us. It all worked out in the end but I didn’t understand the obstacles she was up against. One of the significant parts of the cost was the undertaker’s role and whenever I read about low cost funerals I think that, really, we wouldn’t have missed the “visible” bits of that role too much but would still have wanted someone else to keep the body, place it in the coffin, and transport the coffin to and from the church and crematorium. Being involved with placing the flowers on the coffin and in / out of vehicles would have been fine. i think there are probably many like us, with or without money concerns, who don’t want much to do with the dead body but are happy to take a more active role in the rest and who do want a service with the body present. The idea of a body being taken away at the “beginning”, cremated, and then for the service to take place has a bit of an empty feel for me but seems, at the moment, to be one of the few options for people stuck for cash. I would love to hear from others too about why local authorities seem to be fading out of the picture with more and more private crematoria. Local authorities are particularly cash-strapped at the moment and to get more income from carrying out more cremations would seem to be a positive step forward for both them and the public. We used a local authority crematorium for another relative in the past. I seem to remember that they weren’t particularly well prepared for members of the public contacting them – they dealt with it well when I did (wanted to go and practise the organ there before the service) but I just have in my mind that this was not the norm. A lot of these issues, both in the private and public sector, are simply how customer service can be, unfortunately. But where a funeral is concerned, the customer is under so many different pressures – in terms of time, money and emotions – customer service skills, so to speak, need to be of the very best. I do think the public sector could provide better info too. The info on gov.uk on what to do when someone dies does not address sufficiently how to find out how to do a good funeral at low cost – there is a fleeting reference to direct cremation I think, but that’s about it. For me, what I’ve read about the current notion of “direct cremation” does not really meet the desired type of funeral requirements that most people wish for.

        1. Fran Hall

          I admire your decision to take on much of the work yourselves – I understand some of the far-reaching positive benefits that can come from families having more autonomy throughout the process.

          I can see the importance for some of the body being central to the ceremony.

          Also very much agree that any gate-keepers and funeral professionals should be highly skilled in the people stuff bit – emotional intelligence is key.

          Each situation is different and it’s good to have a professional network there to offer flexible support from experience, but this doesn’t mean that we must have corporate templates thrust upon us.

          I hope you get something in before the deadline!

          1. Fran Hall

            Thank you – yes I did. Sadly, I think they are seeing more private crematoria as the way forward whereas I’m thinking that will make life harder for both independent funeral directors and members of the public looking for a low cost option.

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