Funeral Poverty and Funeral Support Payment Reference Group minutes: November 2023

Minutes from the meeting of the group on 28 November 2023

Attendees and apologies


  • Ellie Wagstaff, Marie Curie
  • John Cunningham, COSLA
  • John Halliday, Caledonia Funeral Aid
  • Lindesay Mace, Down to Earth, Quaker Social Action
  • Natalie McQuade, Association of British Credit Unions
  • Susan McNaught, Cruise Bereavement Care Scotland


  • Elaine Thornton-Nicol, Scottish Older Peoples Assembly
  • Fiona Arnott-Barron, Bereavement Care Scotland
  • Stephanie Millar, Citizens Advice Scotland
  • Jane Matheson, Scottish Working Group on Funeral Poverty
  • Julie Dunk, Institute of Cemetery and Crematorium Management 

Scottish Government Attendees

  • Jasmine Darroch, Scottish Government Policy (Chair)
  • Michelle Rumgay, Scottish Government Policy
  • Mikaela Bain, Scottish Government Policy
  • Barry Pattison, Scottish Government Policy

Items and actions

Welcome and introductions

The chair welcomed attendees, asked for introductions and outlined the purpose of the meeting: To discuss proposed changes to Funeral Support Payment regulations and carry out impact assessment related activities in relation to the changes.

Funeral support payment – Overview of proposed improvements and impact assessments

Funeral Support Payment (FSP) Policy provided an overview of proposed improvements to current regulations and received the following feedback from stakeholders in relation to the following changes;

Allow full application of a reasonability test when a person has been buried or cremated outwith the area in which they resided. 

Stakeholders were broadly supportive of the proposal, with an acknowledgement that this could improve equity of access to the benefit. There was also an acknowledgement that the proposed change would have a positive impact for island communities as crematoriums tend to be on the mainland and this proposed change gives greater choice for island communities. The impact on businesses was also acknowledged with positives identified around more of the costs the client incurs being covered through the FSP award. A concern was also raised around smaller businesses, such as privately owned burial plots on the islands losing out to mainland businesses but with the caveat that the change will have a bigger positive impact on the client overall.   

Concerns were also raised around underclaiming of benefits in remote and rural areas due to lack of awareness or increased stigma in relation to claiming benefits in these areas. FSP policy advised that they will work with Communications and National Stakeholder Engagement colleagues to increase awareness of FSP in Island communities.

Extend provision to allow Funeral support payment to be awarded in exceptional circumstances if a funeral is held outwith the UK and an award is not allowable under current regulations. 

In general, the proposal is deemed to have positive impacts from an equalities perspective. It was noted that island communities have local hubs that support people in local communities. These microbusinesses will need to be updated on the changes in order to support their communities. FSP Policy will reach out for further information on this aspect.

The impact on businesses was discussed with concerns raised around funeral directors being unable to ascertain whether an application for FSP has been made and whether they will receive a payment from the client. This could be a bigger issue due to complexity of overseas funerals and higher travel costs. FSP Policy advised that they have data protection and client rights aspects to consider when an application has been made. Very few FSP awards are in relation to funerals that take place abroad.

Bring Irish citizens within the scope of Funeral support payment regulations to ensure Irish citizens with acquired rights are not disadvantaged by the withdrawal of the UK from the EU.  

The consensus was that this was a positive change with no negative impacts identified. A specific point was raised on the positive impact this may have for those in island communities who may wish to have a funeral in Ireland.

Introduce a change to explicitly deduct any available and accessible assets of the deceased that can be used for funeral costs from the award of Funeral support payment in all cases.  

The consensus was that this was a positive change with no negative impacts identified, although the importance of awareness raising and signposting the proposed change was highlighted.

Explore amending the definition of funeral to include provision for means of disposal of human remains by alkaline hydrolysis.

Although the potential to increase client choice was welcomed, there was a concern raised around availability of alkaline hydrolysis for those in island communities.

FSP policy were also asked if they were considering awarding FSP in cases where there is no body or remains in line with the provision that DWP may be able to provide. FSP policy advised that they had considered this aspect when reviewing FSP provision, but this is not something that is being introduced at this time.

Further points raised

Although the proposed changes to FSP regulations are welcomed, there was a point raised that these changes do not go far enough for those who are facing abject poverty and that those in the lower socioeconomic groups could have better targeted support such as an increase to the flat rate payment. FSP policy outlined that they uprate the flat rate payment of FSP in line with inflation and that they are working within the scope of fixed budgets and limited devolved powers.

The term “disposal of body” was mentioned, and it was noted that the Law Commission in England and Wales are replacing this term with ‘funerary methods’ in advance of their public consultation. This change in terminology is to try and ensure that the language used is as sensitive as possible for bereaved people. This may require a legislative change to address this further and change this wording. FSP policy advised that they will continue to engage with their legal department on what language is appropriate to use in this context.

Action points

FSP policy to follow up on how to reach out find out how best to engage with microbusinesses in island communities. FSP policy will also send out the forecast on budgetary implication on the proposed regulation changes to the reference group members when this has been published.

The meeting ended with the chair thanking attendees for their time and advising that FSP policy will follow up on the action points raised and will provide a minute of the meeting for review.

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