The FCA describes this time as “a point when customers may have a higher chance of demonstrating characteristics of vulnerability.”1
A process designed around internal structures rather than the claimant’s circumstances can quickly cause avoidable harm.
The importance of this issue extends beyond regulatory scrutiny. The UK has an ageing population: the Office for National Statistics estimates that 625,000 people were aged 90 or over in 2024, an increaseof 53.7% since 2004, while the number of centenarians doubled over the same period.2 Its latest population projections also indicate that deaths will exceed births over the decade to mid-2034.3 For financial services firms, this means bereavement is a foreseeable and growing part of customer service that needs to be designed, resourced, and governed accordingly.
Regulatory attention has moved well beyond isolated examples of poor administration. The FCA has examined bereavement journeys in banking and life insurance and is now reviewing consumer investment firms. Its work raises a common supervisory question for all regulated firms: can the firm demonstrate that its end-to-end process delivers timely, consistent, and appropriate outcomes, even when another company performs part of the service?
The warning from enforcement
The most prominent enforcement action is the FCA’s 2018 Final Notice issued to Santander UK plc.4 The FCA imposed a penalty of £32.8 million after finding serious failings in the bank’s probate and bereavement process. More than £183 million of funds were not transferred when they should have been, and 40,428 customers were directly affected. The failings included an inability to identify all funds forming part of a deceased customer’s estate, ineffective follow-up with representatives and inadequate monitoring of open cases. Some cases stalled for years. The FCA also found that the firm had not disclosed relevant information promptly to the regulator in accordance with Principle 11.
The significance of the case goes beyond the size of the fine. It shows how fragmented systems, weak case ownership, and poor management information can combine to deprive beneficiaries of money to which they are entitled. It also demonstrates that the bereavement process can engage fundamental obligations regarding management and control, customers’ interests, and openness with the regulator. A customer’s death does not end the firm’s obligations.
The risk is not confined to failing to act when a customer has died. In 2018, TSB apologised after a systems issue affecting a small number of customers who had switched or closed accounts resulted in third parties being told that they were deceased.5 Direct debits were cancelled and some customers received condolence communications from service providers. The case illustrates the wider consequences of inaccurate death-status data: an error in one process can ripple through payments, utility services, and other essential arrangements, causing distress and practical harm to living customers.
What the FCA found in life insurance
In November 2024, the FCA published findings from its multi-firm review of life insurers’ bereavement claim processes.6 The review covered 15 insurers representing more than 75% of the life protection market. It considered term insurance, group life cover, guaranteed over 50 plans, and whole of life insurance.
The FCA recognised examples of effective support, but found that firms needed to settle claims more quickly and improve how they measured claimant experience. Average end-to-end times differed substantially by product. Term Insurance claims took between 53 and 122 days, while the reported averages were 36 days for Group Life cover, 20 days for Over-50 plans, and 53 days for Whole of Life cover. Few firms consistently captured the data, making comparison and effective challenge difficult.
The review identified several recurring issues. Service standards are often measured in isolated operational steps rather than the complete customer journey. Firms did not always analyse the reasons for delay or distinguish between time within their control and time spent waiting for evidence. Customer feedback was limited, and management information did not always reveal whether claimants with characteristics of vulnerability experienced worse outcomes. The FCA also highlighted practical improvements, including electronic verification of death, early identification of support needs, clear explanations of evidence requirements, named contacts, and proactive updates.
Banking findings reinforced the same message
In April 2025, the FCA published its review of retail banks’ and building societies’ treatment of customers in vulnerable circumstances, focusing on bereavement and powers of attorney.7 It found good practice, including clear procedures and the use of data to identify and support customer needs. It also found uncertainty among staff about what action to take and how quickly to act. In some cases, customers or their representatives were unable to access the funds needed to pay essential bills.
The banking review underlined the importance of adaptable journeys. A rigid demand for standard documents, repeated requests for information already provided, or a requirement to use a particular channel may be convenient for the firm but inappropriate for the person dealing with a death. Staff need sufficient knowledge and authority to recognise the circumstances, explain available options, and depart from the standard route where a reasonable adjustment is required.
The regulator is widening its focus
In May 2026, the FCA announced a review of how consumer investment firms support bereaved customers. Its announcement noted that fewer than half of bereaved customers (47%) felt they had received the support they needed from financial firms. The FCA said, “We want firms to design bereavement processes with people, not paperwork, at their centre. These processes are a real test of a firm’s culture and key to consumer trust.” 8
The work covers firms that advise on, manage, or administer investments, including platforms, advisers, and wealth managers. It will examine the journey from notification through to settlement or transfer, including communications, support for vulnerable customers, service standards and the treatment of fees on bereaved accounts. The FCA plans to publish its findings later in 2026.
The sequence of work across insurance, banking and now investments indicates that the FCA views bereavement support as a cross-sector Consumer Duty concern. Every regulated firm serving retail customers should consider whether the findings are relevant to its own products, operating model and customer base rather than waiting to be selected for a review
What effective bereavement support looks like
A solid framework begins with a clear view of the complete end-to-end journey. The process should start when any part of the firm receives notice of a death and end only when every relevant account, policy, investment, payment and communication has been resolved. Mapping that journey often exposes handoffs, duplicate evidence requests, conflicting service standards, and cases that can fall between teams or systems.
A reliable single customer view is essential. Firms should be able to identify all relationships connected to the deceased across products, brands, legal entities and legacy systems, and apply a verified death notification consistently. Without this, assets may be missed, instructions may be applied incorrectly, and representatives may be left to identify relationships that the firm itself cannot see.
Firms should be able to demonstrate the following:
- Complete identification. The firm can identify every relationship, balance, policy and investment connected to the deceased, including holdings on legacy systems, joint products and linked
- Clear ownership. Each case has an accountable owner, defined next action and effective escalation route. Cases do not disappear into work queues simply because the claimant has not
- Proportionate evidence. Requirements are legally and operationally justified, explained clearly and not repeated unnecessarily. Digital verification and alternative forms of evidence are considered where appropriate.
- Appropriate support. Staff recognise vulnerability and respond sensitively without making assumptions. Evidence collection is people centred rather than a checklist exercise, with requirements tailored to the circumstances and unnecessary or repeated document requests avoided. Communication preferences and support needs are recorded and acted upon throughout the journey.
- Timely resolution. Service standards cover the end-to-end journey as well as individual stages. Delay is analysed by cause, ownership and customer impact.
- Meaningful outcomes The firm tests actual files and customer experiences, not only policy compliance. Results are segmented to identify differences by product, channel, customer need, supplier, and case complexity.
- Effective governance. Senior management receives management information that shows volumes, ageing, stalled cases, repeat contacts, complaints, compensation, fees, exceptions, and root causes, together with clear remedial action.
Outsourcing does not outsource accountability
Bereavement journeys frequently involve administrators, claims handlers, technology providers, tracing services or other third parties. Outsourcing can bring expertise and capacity, but it can also fragment responsibility. A contractual service level may report that a supplier completed its task on time while the claimant experienced weeks of inactivity between the firm and the supplier.
Case study: finding the gaps between the firm and its outsourced provider
HKA experts have assessed the effectiveness of end-to-end bereavement processes at a large UK retail financial institution, including activities performed by it outsourced provider. This experience involved examining governance, procedures, system handoffs, case progression, customer communications, and management information, supported by testing of the evidence used to demonstrate customer outcomes.
Viewed separately, many of the controls appeared reasonable. Viewed through the claimant’s experience, significant gaps emerged. The provider produced management information for each stage it performed, but no one brought the data together to show the complete journey from notification of death to final resolution. This meant the institution could not readily identify overall delays, repeated contacts, or cases that had stalled between teams.
The review also found confusion over ownership and accountability. Cases were closed and left without active follow-up when claimants did not provide the prescribed documents. A process that appeared complete at each individual stage therefore failed to operate as a coherent, people centred service.
The case demonstrated why firms cannot rely solely on contractual service levels or stage based reporting. Effective oversight requires one accountable view of the full journey, clear responsibility for progressing every case and management information that reveals where customers are waiting, why cases have stalled and whether evidence requirements are proportionate.
Effective oversight therefore requires more than supplier meetings and headline performance reports. Firms need access to sufficiently detailed data, agreed outcome measures, file testing rights, clear escalation thresholds and evidence that recurring issues are corrected. Contracts should support the firm’s regulatory obligations, but governance must test what customers actually experience.
Questions boards and senior management should ask
- Can we identify all products and assets belonging to a deceased customer across every system and legal entity?
- What is the true end to end time from notification to final resolution, and how does it vary by product, customer need and service provider?
- How many cases have not been resolved (whether the system shows it as open or closed)?
- Do our communications explain clearly what will happen, what is needed, how long it may take and who can help?
- Can staff make reasonable adjustments and resolve urgent needs without navigating excessive approvals?
- How do we identify and prevent continuing fees, tax treatment or other consequences that may be inappropriate after death?
- What do file reviews, complaints, call listening and customer feedback tell us about actual outcomes and how is this feedback used to drive improvements in the customer experience?
- Where a supplier is involved, can we see and challenge the whole journey rather than only the supplier’s contracted tasks? Do we have audit rights and have they be exercised?
Act before the findings arrive
The FCA’s work gives firms a clear basis for action now. A focused review should combine journey mapping, document and control assessment, data analysis, case testing, staff interviews, communication review, and supplier oversight. The objective is not to produce another policy. It is to establish whether the process works in practice and whether the firm can evidence that it delivers good outcomes.
How HKA can help
HKA supports firms to assess bereavement frameworks, test customer outcomes and design practical remediation. Our work brings together regulatory interpretation, operational process review, data and management information, customer journey testing and third party oversight. For firms exposed to the current thematic work, or seeking assurance before regulatory scrutiny turns to them, an independent end-to-end assessment can identify weaknesses while there is still time to address them.
About the author
Priya Giuliani is a Chartered Accountant with 30 years of experience in investigations, regulatory compliance, governance, and risk management. She has provided expert witness evidence in civil and criminal proceedings, including matters before the UK High Court and HMRC tribunals. Her work has included complex investigations involving fraud, misconduct, regulatory breaches, asset tracing, confiscation proceedings, and financial analysis, as well as advising organisations on regulatory expectations, controls, and compliance frameworks.
Priya specialises in helping organisations respond to regulatory, operational, and integrity related risks through investigations, independent reviews, compliance assessments, and dispute resolution support. She has extensive experience working with regulated firms, corporates, legal advisers, regulators, and law enforcement agencies in the UK and internationally.
1 Findings of our multi-firm review of life insurers’ bereavement claim process | FCA
2 Estimates of the very old, including centenarians, UK – Office for National Statistics
3 National population projections – Office for National Statistics: “natural change (births minus deaths) is projected to be negative 450,000 (6.40 million births and 6.85 million deaths)”
4 Final Notice 2018: Santander UK plc
5 TSB sorry after claims ex-customers who switched had died | STV News Archive
6 Findings of our multi-firm review of life insurers’ bereavement claim process | FCA
8 FCA reviews whether investment firms are doing enough to support bereaved customers | FCA
Disclaimer
The views and opinions expressed in this guest blog are those of the author and do not necessarily reflect the official policy or position of PIMFA. The author and their firm are clearly identified and responsible for the content provided.