Insurance
Funeral plans are the most heavily constrained vertical we work in, and that is a good thing. The rules that arrived in July 2022 removed a great deal of bad practice from this market. They also made most of the acquisition tactics the sector previously relied on illegal. We build inbound, consented acquisition for FCA-authorised funeral plan providers who need volume without inheriting the problems the last decade created.
The FCA took over regulation of pre-paid funeral plans on 29 July 2022, following a period in which the market caused real harm to real families. Two of the changes matter enormously for anyone generating enquiries.
Cold calling is banned. Unless a consumer has been in contact with the firm before and would reasonably expect the call as part of that relationship, the firm cannot call them. That single rule eliminates outbound telemarketing, purchased calling lists, and the aged-data reselling that dominated funeral plan acquisition previously.
Commission payments to intermediaries are banned. The FCA prohibited them specifically to ensure plans represent fair value, after a market in which commission structures drove sales that were not in the customer's interest.
Together these mean funeral plan acquisition has to be genuinely inbound, genuinely consented, and commercially structured with care. Anyone offering you funeral plan leads on a model that looks like the pre-2022 market is offering you a compliance problem with a price tag attached.
We do not advise on how your arrangements should be structured. That is a conversation for your compliance function and your legal advisers, and any supplier telling you otherwise is overstepping. What we can say is that we build campaigns that generate inbound, consented enquiries, and that we will not work around the cold calling rules.
Reference: FCA, regulation of the funeral plans market
Beyond the regulatory constraint, three things account for most of the waste.
Product confusion. A significant proportion of enquiries come from people who want something adjacent but different. Over-50s life cover, which pays out a sum rather than delivering a funeral. Immediate at-need funeral arrangements, because someone has died this week. Probate and will-writing services. Each of those is a legitimate need and none of them is a pre-paid funeral plan.
Age and affordability. Plans have issue age ranges and most are paid by instalment, so affordability over the payment term matters more than the headline price. Enquiries outside those parameters cannot proceed regardless of intent.
Emotional timing. People enquire about funeral plans for two very different reasons. Some are planning calmly, often in their sixties, having decided to spare their family the cost. Others have just been bereaved and are acting in distress. The second group frequently should not be sold anything at all that week, and treating them as a conversion opportunity is both wrong and commercially short-sighted, because those sales cancel.
Inbound calls, and only inbound.
The product needs a conversation. What is and is not included, what happens if the plan holder moves or dies abroad, what the moratorium period means, how instalments work if the holder dies partway through. These are exactly the details that get misunderstood, and misunderstanding here surfaces at the worst possible moment for a family.
Inbound only, without exception. The caller initiates. There is no outbound dialling, no callback from purchased data, no hot-key transfer from an unrelated campaign. If a supplier cannot evidence that the consumer initiated contact, the enquiry is not usable.
IVR qualification, handled gently. Confirming the caller wants a pre-paid funeral plan rather than life cover or an immediate funeral, and that they are within the plan's age range. Brief, plainly worded, and not an interrogation.
Forms work for the planners. People researching calmly, often comparing two or three providers, frequently prefer to read before speaking to anyone. Data capture with genuinely useful follow-up serves them well, and it self-selects for the group in the better frame of mind to make the decision.
Paid search. The core channel, because it is inherently inbound. "Pre-paid funeral plans", "funeral plan cost", "funeral plans over 60". The searcher has initiated, which is precisely what the rules require. Negative keyword work matters more than usual here, filtering out at-need funeral directors, probate, wills and over-50s life cover.
Owned comparison properties. We operate comparison and review properties, so funeral plan demand can be met on our own estate with consent language and call routing we control end to end. In the most consent-sensitive vertical in the portfolio, controlling the source is worth considerably more than the traffic itself.
Content and organic. Genuinely valuable, and underused. What a plan does and does not cover, how it differs from over-50s cover, what happens to the money, what the FCA rules changed and why. People research this carefully because they are trying to protect their family, and honest content earns trust in a category that has spent it.
Paid social. Usable for reaching the demographic, and requiring the strictest creative governance of anything we run. No fear framing, no guilt, no imagery implying a family left in difficulty. The temptation in this category is obvious and it should be resisted.
Email and consented data. Only against genuinely consented, recent, first-party data. This is not a category for list purchase.
What we do not use: outbound telemarketing, purchased calling data, aged leads, or any hot-key arrangement that puts a call in front of someone who did not ask for it.
The at-need row is the one that matters most. Someone whose parent died three days ago needs a funeral director, not a pre-paid plan, and the kindest and most compliant response is to say so and point them somewhere useful. It costs a lead. It is unambiguously the right call.
This category sells to people thinking about their own death, frequently in their seventies or eighties, and sometimes shortly after losing someone. The FCA's vulnerable customer expectations apply constantly rather than occasionally, and Consumer Duty requires firms to avoid foreseeable harm across the product lifecycle.
Our position:
Inbound only. No cold calling, no exceptions, no creative interpretations of what counts as an existing relationship
No fear or guilt framing. Nothing implying a family will suffer or be burdened
No urgency or scarcity. There is no reason a funeral plan decision needs to be made today
Clear product distinction, so nobody thinks they are buying life cover
Vulnerability indicators passed to the provider as context rather than removed to tidy a record
Consent evidenced to source, every time
The commercial case is straightforward. There are 26 FCA-authorised providers holding the large majority of plans in this market, they are all operating under a regulator that arrived because of past failures, and every one of them audits their acquisition supply chain. A supplier who cannot evidence consent provenance is not a cheaper option, they are a liability.
Enquiry volume is a poor guide, because a meaningful share of enquiries in this category should not convert.
We report on:
Cost per contacted enquiry
Cost per qualified conversation. In age range, wants a pre-paid plan, planning rather than at-need, affordability workable
Product-match rate by source. How many enquiries actually wanted a funeral plan rather than life cover or at-need help. This is the fastest way to spot a channel with sloppy targeting
Cost per plan taken out
Persistency through the instalment term. A plan that lapses in month five has helped nobody
Complaint rate by source. Tracked deliberately. In this vertical it is the leading indicator of a channel that will not survive
Where an enquiry is declined because the person was recently bereaved or outside the age range, that is recorded as a correct outcome rather than a failure.
No. The FCA banned cold calling for funeral plans when it took over regulation of the market on 29 July 2022. A firm can only call someone who has been in contact previously and would reasonably expect the call. All acquisition has to be genuinely inbound or consented.
Regulation began 29 July 2022. Cold calling was banned, commission payments to intermediaries were prohibited, providers became subject to authorisation and fitness checks, and customers gained access to the Financial Ombudsman Service.
Through inbound channels where the consumer initiates: paid search, owned comparison properties, and content. Consent is evidenced to source. No purchased calling data, no aged leads, no outbound dialling.
A pre-paid funeral plan arranges and pays for a specified funeral. Over-50s life cover pays a cash sum which may or may not cover funeral costs. They are frequently confused at enquiry stage, and routing the wrong one to a provider wastes everyone's time.
Those enquiries are identified and separated rather than pushed toward a plan. Someone arranging a funeral this week needs a funeral director. Selling them a pre-paid plan would be inappropriate and would not stand.
Vulnerability indicators reach the provider as context rather than being stripped out. Creative avoids fear, guilt and urgency. Where someone appears to need time or family involvement, that is the right outcome rather than a lost sale.
Issue ages vary by provider, and most plans are paid by instalment over a defined term, so affordability across that term matters as much as age. Capturing both at enquiry prevents applications that cannot complete.
Tracked to origin, with the source, timestamp and wording retained. Given the cold calling ban, a supplier who cannot show where consent came from is creating regulatory exposure for the provider rather than for themselves.
Yes. Selling pre-paid funeral plans in the UK requires FCA authorisation, and we would not run acquisition for a firm operating outside that.
Consumer Genius operates across 11 markets. The UK pre-paid funeral plan market is distinctly regulated and the rules described here are UK-specific, so campaigns are built per market rather than translated.
Written by
Luke RobertsHead of Growth, Consumer Genius. 20 years in lead generation, pay per call operations and customer acquisition across 11 markets, with a focus on call quality, consent provenance and regulatory compliance.
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