Funeral Casework
The Standardised Price List is a fixed-format list of prices that a funeral director displays in each branch, in the branch window where practicable, and on its website in a PDF titled "Standardised Price List" that sits no more than one click from the homepage. Those obligations sit in article 3 of the Funerals Market Investigation Order 2021(opens in a new tab), made by the Competition and Markets Authority in June 2021 under the market investigation provisions of the Enterprise Act 2002, with the price-display parts commencing three months later on 16 September 2021.
Unlike the death certification and cremation rules, the Order is not an England and Wales instrument. It applies across the United Kingdom, so a Scottish funeral director complies with the Order and with the Scottish statutory Funeral Director Code of Practice, and a Northern Ireland firm complies with the Order in a jurisdiction that has no funeral-specific regulator of its own.
The rules have not moved since 2021, and the CMA has stopped reporting on whether they worked
Nothing in the Order has changed. What changed is the monitoring around it.
On 7 August 2025 the CMA published its annual review of market outcomes in the funerals sector(opens in a new tab), described on the publication page as the third and final one. The report itself states that "moving forward, we will not publish any further annual reviews of market outcomes in the funerals sector, but we will continue to monitor the information we receive under the Order", and that the CMA Board has decided not to consult on a further market investigation reference. On the question of going further, it says the CMA does "not believe that introducing further transparency measures would be appropriate", because such measures would not improve the competitive process in a market where the buyer is bereaved.
Monitoring therefore continues through the price and volume information firms already supply. What has stopped is the published commentary on whether the Order is working.
The reviews are also easy to miss. The CMA's funerals market case page(opens in a new tab) carries the investigation documents and the Order but links none of the annual reviews, and its most recent listed update is from July 2021, so a firm following the case rather than the publication feed will not see them appear at all.
The practical position is that the compliance requirements are current and the commentary around them is finished. A page describing the Order as being under active review is describing 2023.
The same information appears in the window, in the branch and on the website
The CMA's guidance for funeral directors and crematorium operators(opens in a new tab), last updated 21 January 2025, is more specific than the Order about physical format.
In the window, the Standardised Price List at A4 minimum. Inside the premises, in areas customers frequent, the Standardised Price List, the Additional Options Price List, crematorium prices, terms of business and the disclosure of interests, mostly as A2 or A3 posters. On the website, everything displayed in branch, as appropriately named PDF documents, with the Standardised Price List reachable in one link from the home page and crematorium pricing likewise.
The Standardised Price List itself covers attended funerals, unattended funerals and the individual items making up the funeral, with the headline total and the line items shown together and reconciling to each other. The CMA publishes the template in both English and Welsh alongside the Order, in ODT, so the layout is not a design decision.
The Additional Options Price List absorbs what firms used to call disbursements
The Additional Options Price List is defined in the Order as an itemised list of every product and service the funeral director offers that is not on the Standardised Price List. The CMA's guidance is explicit that this includes "services which may have traditionally been treated as disbursements, such as flower arrangement, coffin, transportation".
That is the line most likely to bite a firm that has carried a category over from its pre-2021 paperwork. A charge described internally as a disbursement, but which is in fact the firm's own product or service, belongs on a published list rather than in an unlisted pass-through.
The guidance does allow the list to reflect regional and cultural preferences, and excludes genuinely bespoke items that are not regularly offered.
Two branch thresholds do two different jobs
The Order uses branch count twice, at different numbers.
Five or more branches makes a firm a large funeral director for reporting purposes. Footnote 3 of the 2025 annual review records that the Order requires large funeral directors, meaning those operating five or more branches, and all crematorium operators, to provide the CMA with specific price and volume information. The display obligations carry no threshold at all, which is why they land on a firm opening its first branch from the first day it trades.
Ten or more branches triggers the compliance statement. The CMA's guidance says funeral directors operating ten or more branches, and all crematorium operators, must submit a compliance statement by the end of April each year, confirming compliance during the preceding 1 April to 31 March.
A firm crossing five branches acquires a reporting obligation; a firm crossing ten acquires an annual attestation on top of it. The display obligations themselves apply from the first branch, with no threshold at all.
Keeping a price list current when a crematorium raises its fee
The operational cost of the Order is not writing the list once. It is that a third party can invalidate it.
The CMA heard this directly. At paragraph 119 of the 2025 review, The Individual Funeral Company told the CMA that every time a crematorium changed its prices, it had to get new Standardised Price Lists printed out and update its website. Philip Blatchly & Son Funeral Directors submitted that the time of costing, production and putting up the posters had driven up costs, which had to be passed on to the families it served.
Both descriptions are of the same shape of work. A single external number moves; the firm then has to reprint the window poster, the in-branch posters, the version in the arranger's folder, the estimate template that quotes it, and the PDF on the website, and the last of those is the one that gets forgotten because nobody walks past it.
The fee also has to be right on the estimate for cases already in progress. A crematorium fee rise with a commencement date splits a firm's live cases into ones booked before and after it, and the itemised estimate for each has to carry the figure that will actually be invoiced.
For context on the scale of the numbers involved, the 2025 review recorded the weighted average cost of a simple attended funeral rising 8.4 per cent from £3,953 in 2022 to £4,285 in 2024.
The disclosure obligations sit alongside the price lists, not inside them
Article 5 of the Order requires a funeral director to display any business or material financial interest it has in a price comparison website that compares funeral director or crematoria services and their prices, where material influence means the ability materially to influence that website's management, strategic direction or commercial objectives.
The CMA's guidance sets out the wider disclosure set as the ultimate owner of the business, material financial interests in comparison websites, and a register of charitable donations or contributions totalling £250 or more over the preceding twelve months.
These are displayed in branch and on the website like the price lists, and they change on a different clock: an ownership change or a donation crossing the threshold, rather than a supplier's fee.
How Funeral Casework will keep the list and the estimate in step
Funeral Casework is being built as case management software for UK funeral directors, and the price list is one record rather than several. The firm's prices will be entered once, in the structure the Competition and Markets Authority requires, and the same entries will produce the itemised estimate and then the invoice, with disbursements recorded separately from the firm's own charges. Changing a crematorium fee will be one edit rather than a reprint and a re-upload done from memory.