Draft guidance on funeral costs consultation: analysis of responses

Independent analysis of responses to our public consultation about draft guidance on funeral costs.



The Scottish Government published its Funeral Costs Plan, in August 2017, which set out a range of measures aimed at addressing funeral poverty in Scotland. These included delivering Funeral Expense Assistance to replace the current DWP Funeral Payment in Scotland, and producing guidance on funeral costs. The latter of these provided the focus for a public consultation which ran from 16 August to 8 November 2018, the results of which are presented here.

The development and publication of guidance on funeral costs is designed to help improve the availability and transparency of funeral charges information to help consumers understand, compare and choose the services that are right for them at the time of planning a funeral. The draft guidance sets out steps that burial authorities (cemeteries), cremation authorities (crematoriums) and funeral directors can take to improve transparency and availability of funeral pricing information. Recognising that the funeral market is complex, with both private and local authority providers offering a range of different services, a section of the draft guidance was included specifically for local authorities to cover charge setting and tackling funeral poverty.

In developing the draft guidance, the Scottish Government worked with the Convention of Scottish Local Authorities (COSLA), as well as local authorities, private crematoriums, and funeral directors to try to identify areas of consensus; but also to explore areas where transparency and consumer choice might be improved through guidance. Alongside the consultation, the Scottish Government invited interested stakeholders to engage directly via a series of meetings, to discuss the draft guidance and explore ways of ensuring that organisations and individuals would embrace and implement the finalised guidance effectively.

Learning from these meetings, alongside the consultation responses analysed and presented here, will be used by the Scottish Government to prepare a final copy of the guidance on funeral costs, which will be published under Section 98 of the Burial and Cremation (Scotland) Act 2016.

The Consultation Exercise

The consultation document included a copy of the draft guidance structured under four headings - one each for burial authorities, for cremation authorities, for funeral directors and local authorities, in turn.

A total of 22 questions were asked in relation to the draft guidance focussing on a number of cross-cutting themes, these being:

  • use of language and terminology;
  • display of pricing information;
  • transparency of cremation charges;
  • definition of a simple funeral;
  • transparency of pricing at point of sale;
  • burial or cremation without using the services of a funeral director;
  • understanding local authority charges; and
  • local authority measures to reduce funeral poverty.

The consultation also sought views on the potential business impacts of the draft guidance on the public, private and/or third sector as well as potential impacts on people with protected characteristics under the Equality Act 2010.

Contributions were encouraged from local authorities, private burial or cremation authorities, funeral directors and any other groups or individuals with a working knowledge of, or interest in, burial and cremation or the funeral industry. Views were also invited from individuals and organisations with experience of tackling poverty or providing consumer advice.


A total of 49 substantive responses were received, most via the Scottish Government's online portal Citizen Space, but some by email. Some respondents submitted views using both the online consultation portal but also forwarded additional context/clarification documents to accompany their response. Of the 49 responses, 18 were submitted by individuals and 31 came from organisations.

A total of 10 closed and 12 open questions were included and all questions were answered by at least one respondent. All responses were read and logged into a database, and all were screened to ensure that they were appropriate/valid. None were removed for analysis purposes. Although some responses to individual questions were not appropriate/did not directly address the questions being asked, all feedback was analysed and is presented under the appropriate sections below.

Closed question responses were quantified and the number of respondents who agreed/disagreed with each proposal is reported below. Comments given at each open question were examined and, where questions elicited a positive or negative response, they were categorised as such. For most of the questions, respondents were also asked to state the reasons for their views, or to explain their answers. The main reasons presented by respondents both for and against the content included in the various sections of the draft guidance were reviewed, alongside specific examples or explanations, alternative suggestions, caveats to support and other related comments. Verbatim quotes were extracted in some cases to highlight the main themes that emerged. Only extracts where the respondent indicated that they were content for their response to be published were used - five respondents asked that their response not be published and 20 approved publication without reference to their name/affiliation. The remaining 24 were content for their response and identity to be published, although a decision was made to anonymise all responses as part of the reporting process.

Report Presentation and Research Caveats

Findings are presented as they relate to each question contained under the core sections of the consultation document (described above). Where people provided no response, this is noted separately from cases where respondents indicated that they had no further comments or were unsure.

The tables below show the difference in views expressed by the respondent group as a whole. Given the relatively small number of responses received overall, it was decided that disaggregated analysis by respondent typology would be unreliable, however, in any cases where individual respondents offered views that differed significantly from those submitted by organisations, this is picked up narratively in the report. As a guide, where reference is made in the report to 'few' respondents, this relates to three or less respondents. The term 'several' refers to more than three, but typically less than ten.

Finally, especially given the small number of responses received overall, it is worth stressing that the views presented here should not be taken as representative of the wide range of stakeholders invited to respond to this consultation, nor should they be generalised too broadly. They simply reflect the views of those individuals and organisations who contributed.


Email: funeralpoverty@gov.scot

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