Five years on: what the CMA Funerals Order has and hasn't done for UK funeral pricing

Made comparison possible at all. Pre-Order, UK funeral directors typically did not list prices on their websites. A bereaved family looking to compare two providers had to ring round and ask, and the question was socially uncomfortable. Today, around 67% of indexed UK funeral directors publish a usable SPL the public can read without picking up the phone.

Surfaced the variation. Among the 2,844 UK funeral directors with a captured direct cremation price, the spread runs from £1 to £135,000 — a difference of over £134,999 for what is ostensibly the same product. The median is £1,545 and the middle 50% of providers cluster between £1,240 and £1,745. Pre-Order, none of this was visible.

Standardised the format. The Order’s biggest single design choice was requiring a fixed price-list format rather than just disclosure. Every SPL has the same line items in the same order, which is what makes aggregation possible. The Solicitors Regulation Authority’s Transparency Rules and the new CMA Vet Services Order both follow the same pattern — and both are direct policy descendants of the funeral SPL.

Enabled regulatory follow-through. The CMA’s 2024 review of the Order’s effectiveness drew on the same kind of independent evidence base that Funeral Cost Index quarterly snapshots now publish on a recurring basis. Without the SPL, a regulator wanting to audit price transparency would have had to commission its own survey.

Driven price compression. The Order’s logic was that mandatory disclosure plus standardised format would let consumers shop on price, putting downward pressure on the spread. Five years in, the spread is still wide — direct cremation prices in the same UK town routinely vary by £505+ between providers — and the median has continued to rise broadly with general consumer-price inflation. Mandatory disclosure is necessary for downward pressure but isn’t sufficient on its own.

Closed the chain premium. The CMA’s 2018–2020 investigation found that consolidated corporate ownership groups (Co-op Funeralcare, Dignity, Funeral Partners) priced above local independents on routine services. Our captured data shows that pattern persists. The Order’s ownership-side remedies were lighter than its disclosure-side remedies; the price gap remains visible in the data.

Closed compliance. 1,636 UK funeral directors that we’ve indexed do not currently publish a usable SPL on their website — either no SPL at all, an SPL with material missing fields, or a price list in a non-mandated format we couldn’t reliably extract. That’s roughly 33% of regulated UK funeral directors, five years after the Order took effect. Compliance is monitored by the CMA but enforcement has been light.

Solved the disbursements problem. The headline SPL figures are funeral director’s charges only. Adding the cremation fee (£900–£1,200, set by individual crematoria), doctors’ fees, and clergy or celebrant takes the total bill for a fully attended cremation funeral to roughly £3,500–£4,500 — and this third-party-fee layer is exactly the part of UK funeral pricing the CMA Order doesn’t reach.

A national compliance register. The CMA could publish a quarterly register of every regulated UK funeral director and their SPL compliance status, the way the SRA publishes its Find a Solicitor register. Funeral Cost Index already maintains the equivalent independent dataset; transferring it to a regulator-published statutory register would close the compliance gap quickly.

Disbursement transparency. The cremation fees set by UK crematoria are substantially less transparent than the funeral director side. A consumer comparing two attended cremations needs to know both, but only the funeral-director side is on the SPL. Extending the disclosure mandate to crematorium fees would be a natural next step.

Time-series accountability. An SPL captured today and an SPL captured a year ago compared side-by-side tells you which providers are raising prices and by how much. Funeral Cost Index publishes quarterly snapshots at /data so the year-on-year movement is now trackable. Regulators and policymakers can hold the chain groups specifically to account on this.

The CMA Vet Services parallel. The CMA’s 2025 Vet Services Order applies the same transparency playbook to a much larger and more consolidated UK consumer-services market. The lessons of the funeral five-year period — that mandatory disclosure works, that standardisation matters more than disclosure alone, that ownership disclosure needs the same enforcement weight as price disclosure — are now informing the early shape of the vet remedies.