The Funerals Market Investigation Order 2021 is not a best-practice guide. It’s not a recommendation from your trade association. It’s a legally binding order made under the Enterprise Act 2002, and it applies to every funeral director in the United Kingdom — whether you run one branch or fifty, whether you’re an NAFD member or not, whether you’ve read the document or never heard of it.

Yet more than four years after the Order took effect, the CMA’s own monitoring has found that a significant number of funeral homes still aren’t fully compliant. In January 2023, the CMA identified over 100 funeral directors who appeared to be falling short — roughly 5% of providers — and began sending enforcement letters. By late 2024, public breach letters were landing on the desks of firms like James Henry Funeral Services and Springhead Funeral Services Limited, with their names published on GOV.UK for anyone to see.

This post is a plain-English walkthrough of what the Order actually requires on your website. Not what you think it requires. Not what your web designer told you it requires. What the Order says.

100+
directors flagged by CMA in Jan 2023
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max penalty under DMCC Act 2024 (of turnover)
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max distance from homepage to SPL

Why the CMA Intervened — and Why It Matters Now

The CMA launched its funerals market investigation in 2019 after finding that bereaved families couldn’t effectively compare prices between funeral directors. Pricing varied widely for similar services, information was presented inconsistently, and families — grieving, under time pressure, and often arranging a funeral for the first time — had no reliable way to shop around.

The investigation’s final report, published in December 2020, concluded that pricing transparency across the sector was inadequate. The remedy was the Funerals Market Investigation Order 2021, which came into full force on 16 September 2021. Every UK funeral director was required to comply from that date.

The regulatory direction since then has been toward greater scrutiny, not less. The CMA published updated compliance guidance in January 2023, began active enforcement the same month, and has continued publishing public breach letters through 2024. Meanwhile, the Digital Markets, Competition and Consumers Act 2024 — which came into force in April 2025 — gave the CMA significantly expanded enforcement powers across all sectors, including the ability to impose financial penalties of up to 10% of worldwide annual turnover. Directors in Scotland should also note that the funeral sector register went live in April 2025, bringing additional oversight and a code of practice with its own compliance requirements.

The short version: the enforcement landscape is tightening. Getting compliant now is significantly less expensive than being caught non-compliant later.

Key takeaway

The enforcement landscape is tightening. Getting compliant now is significantly less expensive than being caught non-compliant later.

The Standardised Price List: What Must Be on Your Website

The core requirement is the Standardised Price List (SPL). The Order specifies the exact terms, structure, and format you must use — you cannot redesign it, reword it, or fold its contents into your own pricing page and call it done.

Here’s what the SPL must contain, broken down by element.

The CMA Attended Funeral

This is a funeral where family and friends have a ceremony, event, or service for the deceased person at the same time as they attend their burial or cremation. Your SPL must show both a total price for this funeral and individual prices for each of the six component items. The sum of the individual items must equal the total.

The six components are:

  1. Taking care of all necessary legal and administrative arrangements
  2. Collecting and transporting the deceased person from the place of death (normally within 15 miles of the funeral director’s premises) into the funeral director’s care
  3. Care of the deceased person before the funeral in appropriate facilities
  4. Providing a suitable coffin — the Order requires you to describe the coffin specification (e.g., “made from oak veneer,” “made from plain MDF”). Vague descriptions aren’t acceptable
  5. Viewing of the deceased person for family and friends, by appointment
  6. A hearse or other appropriate vehicle to take the deceased person to the agreed cemetery or crematorium (normally within 20 miles of the funeral director’s premises), at a date and time agreed with the family

Every one of these items must show a monetary value greater than £0, except viewing, which may be listed at £0 if you don’t charge for it separately.

Common mistakes

Listing a single bundled price without the six-item breakdown. Using vague coffin descriptions like “a standard coffin” without specifying the material. Omitting the mileage qualification on collection and hearse transport.

If you don’t offer attended funerals, you must write “Not offered” in place of the total price and use a dash for each component — but you still need to include this section on the SPL.

The CMA Unattended Funeral

This is a funeral where family and friends may choose to have a separate ceremony or event, but they do not attend the burial or cremation itself. You must display a total price for the unattended funeral.

The Order requires you to list the unattended funeral for both burial and cremation (if you offer both). The pricing must be for the funeral director’s charges only — disbursements are shown separately.

Common mistake

Offering only a direct cremation price and omitting unattended burial. If you offer any form of unattended funeral, you must present the CMA Unattended Funeral on the SPL.

Disbursement Estimates: The Fees Families Must Pay

Separate from your own charges, the SPL must include estimates for third-party fees that families will need to pay. These must be clearly labelled as fees the family must pay (not your charges) and include:

These must be presented as estimates or typical local costs. The Order does not require you to guarantee third-party prices — but you do need to give families a realistic picture of what these disbursements will cost in your area.

Common mistake

Omitting disbursement estimates entirely, or burying them in a separate document rather than including them on the SPL itself. Another frequent error is failing to update crematorium fees when they change — the Order requires the information to be current.

Local Crematorium Pricing

In addition to the disbursement estimates on the SPL, you must display the price information provided to you by local crematorium operators. The Order requires crematorium operators to supply you with their pricing, and you must make it accessible to families.

This means showing prices for crematoria within a 30-minute cortege drive of your premises, covering standard fee attended services, reduced fee attended services (off-peak), and crematorium unattended services (direct cremation at the crematorium).

Additional Options Price List

Alongside the SPL, you must also display an Additional Options Price List. This covers products and services beyond the standard attended and unattended funerals — things like limousines, embalming, additional mileage, floral tributes, collection and delivery of ashes, and any other items you offer.

The Order doesn’t prescribe the exact format of this list with the same rigidity as the SPL, but it must be present, accessible, and priced clearly.

Terms of Business

Your terms of business must also be displayed. This includes deposit requirements, payment timelines, accepted payment methods, and any late payment charges. If you require a deposit, the amount or percentage must be stated. If you charge interest or fees on late payments, that must be disclosed.

Declaration of Interests

You must disclose any material financial interests in other businesses in the funeral supply chain — for example, if you own or have a financial interest in a crematorium, a price comparison website, or another funeral-related business. You must also disclose any material charitable donations or contributions to hospices, hospitals, care homes, or similar institutions (the threshold is £250 or more in any 12-month period).

Where It Must Appear: The Prominence Requirement

Getting the content right is only half the job. Where and how you display it matters just as much.

The Order is specific: when you display the SPL on your website, it must be in a PDF titled “Standardised Price List”. That PDF must be accessible from a page no more than one click away from your homepage, with the link prominently labelled so that visitors can tell what it leads to.

In practical terms, this means a clearly visible link — labelled something like “Standardised Price List” or “Our Prices” — on your homepage or in your main navigation. Not buried in a footer. Not hidden behind a “Resources” dropdown. Not sitting on a page that requires three clicks to reach. For a deeper look at how pricing page structure affects both compliance and conversion, see The Most Common Pricing Page Mistakes Funeral Homes Make.

If you don’t have a website but market your services online — through Facebook, Google Business Profile, or any other platform — you must display the SPL prominently on those channels too. A PDF shared via a file-hosting link is one approach SAIF has recommended for social media platforms.

The same prominence requirement applies to your Additional Options Price List, local crematorium pricing, terms of business, and declaration of interests. All of it needs to be accessible, not just technically present somewhere on your site.

Common mistakes

Uploading the SPL as a PDF but not linking to it from the homepage. Labelling the link vaguely (“Click here for more information”). Placing the link only in the footer or only in mobile navigation where it collapses. Using a pricing page that embeds some information in HTML but doesn’t include the actual SPL PDF in the required format.

What Happens If You Don’t Comply

The CMA has the power to issue legally binding directions compelling you to comply. It can — and does — publish the names of non-compliant businesses, along with details of the breach and the enforcement action taken. The public letters issued in October 2024 to firms like James Henry Funeral Services and Springhead Funeral Services are now permanently visible on GOV.UK.

To date, the CMA’s approach to the funerals sector has been graduated: monitoring, guidance, private enforcement letters, then public letters. Fines under the original Order framework have not been widely reported. But the enforcement posture is clearly escalating, and the broader regulatory environment has shifted. The DMCC Act 2024 gave the CMA direct enforcement powers and the ability to impose penalties of up to 10% of annual turnover for consumer law breaches — a tool that, while currently being deployed in other sectors, signals where the direction of travel is heading.

NAFD members should also note that non-compliance with the CMA Order is a breach of the NAFD’s Funeral Director Code. SAIF’s position is similar. Trade association membership and CMA compliance are now explicitly linked.

This isn’t a scare piece. The reality is straightforward: the requirements are clear, the CMA is actively monitoring, and the cost of non-compliance — reputational and regulatory — is rising. Getting it right is not difficult. Getting it wrong is increasingly visible.

Your Compliance Audit Checklist

Open your website in one tab and work through this list. Every item should be checkable right now.

Standardised Price List (SPL)

  • SPL exists as a PDF titled “Standardised Price List”
  • SPL is accessible within one click from your homepage
  • The link to the SPL on your homepage is prominently labelled and clearly describes what it leads to
  • SPL uses the exact terms and structure prescribed by the CMA template — no reformatting, no rewording
  • Attended funeral total price is displayed
  • All six individual component prices for the attended funeral are listed separately
  • The six individual prices sum to the total attended funeral price
  • Every item shows a monetary value greater than £0 (except viewing, which may be £0)
  • Coffin specification is described (material, not just “a suitable coffin”)
  • Mileage limits are stated for collection (15 miles) and hearse transport (20 miles)
  • Unattended funeral prices are displayed (burial and/or cremation, as applicable)
  • If you only offer attended funerals, “Not offered” appears for the unattended section (and vice versa)
  • Disbursement estimates are included: burial fee, cremation fee, and doctors’ fees (England/Wales/NI)
  • Disbursements are clearly labelled as fees families must pay, not your charges

Additional Requirements

  • Additional Options Price List is displayed and accessible
  • Local crematorium pricing is displayed (crematoria within 30-minute cortege distance)
  • Crematorium pricing covers standard attended, reduced fee attended, and unattended services
  • Terms of business are displayed: deposit amount, payment terms, late payment charges
  • Declaration of interests is included (financial interests in other funeral-related businesses, material donations to institutions)
  • If you market on social media or other online platforms but have no website, the SPL is accessible there

Format and Accessibility

  • SPL is in PDF format (not only HTML embedded in a webpage)
  • All pricing documents are current and reflect your actual charges
  • Crematorium fees have been updated since the last price change
  • Links work on both desktop and mobile
  • Nothing is hidden behind a login, contact form, or email request

If any box is unchecked, fix it. The CMA’s compliance guidance and SPL template are both available at GOV.UK. The NAFD and SAIF both offer member support for working through the requirements.

A Note for Irish Directors

Ireland has no equivalent to the CMA Funerals Market Investigation Order. There is no statutory pricing transparency requirement for Irish funeral directors, and no regulator with the power to compel price disclosure.

The IAFD’s Quality Standard — aligned with the European Standard for Funeral Services — requires members to have a complete price list available and to offer written confirmation of costs at the time of making arrangements. But this is a membership obligation, not a legal one, and it doesn’t prescribe the same level of public-facing detail as the CMA’s SPL.

That said, the direction of regulatory travel across Europe is toward greater transparency. Irish directors who adopt the CMA’s SPL framework voluntarily — publishing clear, itemised pricing on their websites even without a legal obligation to do so — position themselves ahead of any future regulation. More immediately, transparent pricing builds trust with families who are increasingly researching options online before picking up the phone.

The CMA template is free, publicly available, and provides a ready-made structure that’s already been tested across thousands of UK funeral homes. Using it — or something closely modelled on it — costs nothing and signals professionalism. For a plain-English explanation of one of the key items on the SPL, see Direct Cremation Explained Without the Jargon.

The Bottom Line

The CMA Order is four years old. The requirements haven’t changed. The template is publicly available. The guidance is published. The enforcement is real and escalating. None of this is ambiguous.

If your website is compliant, you can confirm it in fifteen minutes with the checklist above. If it isn’t, the fix is rarely more than a few hours of focused work.

The families you serve deserve clear pricing. The regulator expects it. And the cost of doing nothing is no longer nothing.

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