CMA funeral price rules: a checklist for your website

A practical, sourced checklist of what the CMA Funerals Order requires funeral directors to show online, and how to present it well.

Since 16 September 2021, every funeral director in the UK has had to follow the Funerals Market Investigation Order 2021, made by the Competition and Markets Authority (CMA). Much of it is about what you display to families, both in your branches and online.

I started in the funeral industry at 16, and I remember the work that went into getting price lists ready when the Order came in. In my experience, the website is where things can slip: a price list buried three pages deep, an out of date PDF, or terms of business that never made it online.

This checklist covers what the Order requires on your website, based on the CMA's own published guidance. It is a practical summary, not legal advice. The CMA itself says its compliance checklist for funeral directors is not a full list, and that you should check your position against the full text of the Order and its Explanatory Note.

What the CMA funeral price rules require you to display

According to the CMA's guidance for funeral directors with 4 or fewer branches, funeral directors must display, and keep up to date:

• the Standardised Price List
• an Additional Options Price List
• local crematorium operators' prices
• certain terms of business, such as deposits and late payment charges
• a disclosure of interests, including information about certain donations and payments

All of this must be shown within your branches and online, on your website (and the website of each branch), or on any other online platform where you advertise if you do not have a website.

Checklist 1: your Standardised Price List online

The Standardised Price List is a fixed format, itemised list that lets families compare funeral directors like for like. Check the following.

• It is on your website. The CMA checklist asks whether it is "accessible no more than one click away from your homepage".
• It is a separate PDF. The guidance says the Standardised Price List "must be displayed in a PDF separate to all other information, accessible in one link from the home page."
• It uses the CMA template. You must complete the Standardised Price List in full using the CMA template, available on the Order's gov.uk page. No changes to the format are allowed except those permitted in Part B of Schedule 1. You may use your own branding, colours and font.
• The attended funeral is fully priced. If you offer attended funerals, you must show the total price and a separate price for each of the six listed items, and those items must add up to the total.
• Prices are above £0. Items must be shown as monetary values greater than £0, unless the Order specifies otherwise.
• "Not offered" is used correctly. If you only offer unattended funerals, enter "Not offered" for the attended funeral total, and the other way round. The full list must still be displayed.
• Unattended funerals are priced. If you offer them, give a total price for the types you offer, for example unattended burial, unattended cremation, or both.
• Third party fees are shown. If you offer burial, show the range of local burial fees. If you offer attended cremation, show the range of local cremation fees for residents. Otherwise mark them "Not offered".
• Additional services are priced. If you offer additional mileage, additional transfers of the deceased, collection and delivery of ashes, or embalming, each needs a non zero price. Services outside normal office hours and a funeral officiant are marked "price on request".

Checklist 2: your Additional Options Price List

This is an itemised list of the products and services you offer that are not on the Standardised Price List. The CMA says it includes items that may traditionally have been treated as disbursements, such as flowers, coffins, transport and funeral jewellery.

• It covers everything you advertise on your website and in branch, even services you do not provide directly.
• Prices can be fixed, "from" or a range. The guidance allows any of these.
• Bespoke items are handled properly. Items you do not normally offer on your website or in branch do not need to be listed, but you must disclose the price of any bespoke service before the customer agrees to buy it.
• It is online as an appropriately named PDF.

Checklist 3: local crematorium prices

Local crematorium operators must provide you with their prices, and you must display them in the format the Order prescribes. Where offered, that means:

• Crematorium Standard Fee Attended Service
• Crematorium Reduced Fee Attended Service
• Crematorium Unattended Service

Check that the figures on your website match the latest prices you have received. This is an easy one to let go out of date when crematoria change their fees.

Checklist 4: terms of business

If you require a deposit or charge for late payment, the CMA guidance says you must display:

• the amount of any deposit
• when any deposit and the final balance must be paid
• the payment options available, including whether interest is payable
• any late payment charges

The CMA also notes that customers may find it helpful if you say when you do not require a deposit or charge late payment fees. If that is your approach, it is worth saying so plainly. It reassures families.

Checklist 5: disclosure of interests

Your website must also show:

• The ultimate owner of the business. For a sole trader this may be the trading name; for a company owned by individuals, the registered company; for a group, the parent company as well as the registered company.
• Any business or material financial interest in a comparison website that compares funeral director or crematoria services or prices. Changes must be declared within three weeks.
• A register of payments, covering the previous 12 months, of charitable donations, contributions or other payments totalling £250 or more that do not relate to a cost incurred or service provided by a third party on your behalf. It should include the name of the third party, the amounts and when they were made.

Checklist 6: clear and prominent display

The Order does not only ask that information exists online. It must be clear and prominent. The CMA guidance says it must be:

• legible and written in plain English
• easy to find
• prominent within its particular location
• actively brought to the customer's attention

Paragraphs 94 to 101 of the Explanatory Note give more detail. In practice, on a website, I would check:

• Is there a clearly labelled link such as "Our prices" in the main menu or on the home page?
• Do the PDF file names make sense, for example "Standardised Price List" rather than "doc_final_v3"?
• Do the PDFs open properly on a mobile phone?
• Are the dates on the PDFs current?

If you market on Facebook or another platform without a website, the same information needs to be displayed there.

Beyond compliance: presenting prices well

The PDFs are a legal requirement. They are not always the friendliest way for a grieving family to understand what you charge. Many funeral directors add a simple prices page in plain words alongside the PDFs, explaining what is included in each type of funeral, what third party fees are, and inviting families to call with questions.

This is not required, and it must not contradict your Standardised Price List. But in my experience families appreciate it, and a clear prices page is often one of the most visited pages on a funeral director website. It also gives search engines readable text about your services, which a PDF on its own does not do as well.

Things the Order prohibits that touch your marketing

The Order also bans certain practices, and some of them overlap with how you promote yourself. According to the CMA guidance, you must not:

• make arrangements with hospitals, hospices, care homes, palliative care providers or similar institutions that could reasonably be understood to encourage them to refer customers to you
• make payments or gifts to a care home that could reasonably be understood to incentivise referrals
• agree to exclusively or prominently advertise on a hospital's written materials, such as leaflets or online pages, in a way that may undermine customer choice
• market your services while providing services to a coroner or the police, including when collecting the deceased

Worth remembering when a local care home or hospital offers you advertising space.

If you find a problem

The CMA says that if you find you are in breach of the Order, you must report it to the CMA within 14 days of becoming aware of it, by emailing RemediesMonitoringTeam@cma.gov.uk. Fix the website issue promptly and keep a note of what you changed and when.

Firms with five or more branches have additional reporting duties to the CMA. The compliance checklist sets these out.

Official sources

• Funerals Market Investigation Order 2021 (gov.uk)
• Compliance checklist for funeral directors (gov.uk)
• Funeral directors with 4 or fewer branches (gov.uk)
• Funeral directors and crematorium operators guidance (gov.uk)
• Things to know when arranging a funeral (gov.uk)

Frequently asked questions

Does the CMA Order apply to small independent funeral directors?

Yes. The Order applies to all funeral directors. Firms with fewer than five branches do not have to submit financial information or compliance statements unless the CMA asks, but they must comply with everything else.

Can I put my price list on a web page instead of a PDF?

The CMA guidance says the information must be displayed in appropriately named PDF documents, with the Standardised Price List in its own PDF one link from the home page. You can add a plain web page as well, but it should be in addition to the PDFs, not instead of them.

Can I brand my Standardised Price List?

Yes. The guidance allows your own branding, colour and font, but not changes to the format beyond what Part B of Schedule 1 permits.

If you would like a second pair of eyes on how your prices appear on your website, I am happy to have a chat.