Pre-paid funeral plans firms: apply for authorisation

If you’re a pre-paid funeral plan provider or intermediary, find out what you need to do to have appropriate authorisation before our regulation starts on 29 July 2022.

If you’re a funeral plan provider and want to continue offering pre-paid funeral plans after 29 July 2022, you must apply for our direct authorisation.

If you’re an intermediary, you can either apply for direct authorisation or become an appointed representative.

Find out whether you're a provider or intermediary firm.

Remember, our assessment of applications for authorisation and variation of permissions takes time, as we review, examine and discuss your information with you. 

If you plan to become directly authorised, then you must prepare and submit your application now. If you're a provider of funeral plans and don't intend to apply for authorisation, please contact us now to let us know.

Before you apply

Review our forms and guidance notes so you know what information and documents you will need to provide. 

Applications for direct authorisation

Applications need to be made on our Connect system.

You will need a Connect account to submit your application. Think carefully about selecting the person whose name the account will be created in, as this can’t be changed. Find out more about registering for Connect

You must make sure that you fully answer every question on the application form and provide all the information requested. Any omission will result in information requests to your firm, causing delays to your application.  

Poor quality applications with missing information or documents will be returned. 

Apply for authorisation

Preparing your application 

At the time you apply, you should be able to evidence that:

  • that your firm is ready, willing and organised to be authorised  
  • that you have products, processes, systems and people (or robust plans in place) that meet our regulatory standards for the pre-paid funeral plans sector
  • how, at the point of authorisation, your firm will satisfy and continue to satisfy our Threshold Conditions
  • how your firm’s management meets the FIT test
  • that you meet our Principles for Business 

Make sure you review your firm’s products, systems and controls, processes, ways of working and financials against the requirements set out in our Policy Statement, to ensure they meet the requirements to be authorised.

Your plans must set out a timetable for implementation and you will need to show that your firm has the resources available to deliver the plans.  

You should be able to set out what you still have left to implement and how you plan to be ready in time for regulation, including key dependencies and risks to delivery.  If your plans are not being delivered to the set timetable, this may delay or undermine your application for authorisation. 

If substantive changes to your business are being made after your application has been submitted, which could indicate that you are not ready, willing and organised to be authorised, we may ask you to consider withdrawing the application and re-applying when you are ready. While this will give you an opportunity to address the issues raised, it may mean you won’t be authorised by 29 July 2022. 

For more information on what being ready, willing and organised means, see Authorisation: what’s involved, which has general information on the authorisations process.

Other factors to consider when applying 

  • Consider which permissions you need. You will need to explain how the permissions you apply for match with your business model and services you offer. Don’t apply for permissions which you don’t need or intend to use, as this may prolong the application assessment process. You can find more information and explanations in our Perimeter Guidance Manual.   
  • We will assess the honesty, integrity and reputation of key members of staff in your firm’s management, as well as their competence, capability and financial soundness. Your application must clearly explain how and why individuals in key roles were selected, based on their relevant experience, as well as the scope of their regulatory responsibilities. You will need to demonstrate how you have applied our rules under the Senior Managers & Certification Regime (SM&CR) to your business. You can find related information in Chapter 7 of our Policy Statement, and further detail in Chapter 8 of CP21/4
  • You will need to create a regulatory business plan. This sets out your firm's business model, the key regulatory risks, how your firm will manage and mitigate these risks, and how you will comply with regulatory obligations on an ongoing basis.  
  • You need to explain how your business operates, so that we can assess if you meet our minimum standards. If you use an external adviser to help prepare your application, make sure that you set out your understanding of the business model (rather than your adviser’s). Do not submit generic business plans.
  • We will want to see agreements with your key service providers and understand how you are building resiliency into your business model. You should also be aware of the training and competence requirements to which you and the team will be subject.
  • Your application must clearly explain what compliance arrangements you have in place to meet your regulatory obligations. You must tell us about any conflicts of interest and explain how you intend to manage or mitigate them.
  • If you are applying to be a principal, you must be able to demonstrate that you have appropriate systems and controls in place to effectively onboard, oversee and monitor your network of appointed representatives (ARs). It’s the principal’s responsibility to make sure their ARs are compliant with our rules. 
  • Any technology or systems you will be using must also be ready to carry out the regulated activities you’ve applied for. You will need to be able to provide evidence of how these will operate to support your business. 
  • If you are a funeral plan provider, you must provide an Asset Adequacy Report (AAR) (see Appendix 2 of the Funeral Planning Authority’s rules dated Jan 2020) with your application. This is separate to the Solvency Assessment Report (SAR), which is a standalone report for all trust-backed funeral plan providers that secure their funeral plans by way of trusts. The SAR is focused on the assets and liabilities of the trust (see FPCOB 3.2) and must be produced by an actuary. Both must be submitted with your application as separate documents, where required (see application guidance notes).  
  • Before you submit your application make sure it is complete and has no missing forms or information. The system will not allow you to submit your application until you have attached the necessary documents. Don’t attach blank or incomplete documents as your application will be returned. Where necessary, make sure that your documents are signed and that you have provided us with the passwords for any password-protected files. 

You must refer to our full rules and application guidance notes when preparing and submitting your application.  

Once you’ve submitted your application

Once we’ve received your application, we will start the assessment to determine whether your firm meets our standards for authorisation. We will assess applications on a case-by-case basis.  

If we need to, we will ask you for more information or documents to help us determine if your firm meets our standards for authorisation. We expect you to be open and co-operative with us and respond to requests for information within the timeframes we specify. 

If you aren’t authorised by 29 July 2022, you will have to stop selling and administering funeral plans until your application for authorisation is approved. 

Throughout our assessment of your application, we will consider whether you’re ready, willing and organised to comply, on a continuing basis, with the requirements and standards under the regulatory system

More information

We will communicate with your firm throughout the authorisation process, but if you have any questions about preparing or submitting your application, please contact us.

You can also sign-up to receive email updates

Page updates

01/09/2021: Information added applications open for authorisation
04/08/2021: Information added Applications for authorisation
23/07/2021: Information added Registering for Connect.
13/07/2021: Editorial amendment Clarification of regulation date.
05/07/2021: Information changed Information on PS21/8
16/06/2021: Information added To help firms determine if they're providers or intermediaries.