Bereavement support under scrutiny for investment firms

What happened?

The FCA has announced a review into whether consumer investment firms are doing enough to support bereaved customers, after finding that fewer than half of bereaved customers (47%) felt they received the support they needed. The review will assess the customer experience from the point a bereavement is notified through to the settlement or transfer of investments, including communication, support for vulnerable customers, service standards and how fees are applied on bereaved accounts.

It follows earlier 2024 multi-firm reviews into life insurers’ bereavement claims processes and the treatment of vulnerable customers in retail banking, in which the FCA said it wanted to see a “step change” improvement and that “no firm can afford to be complacent in this area”.

Why does it matter?

As Consumer Duty supervision matures, the FCA’s focus is moving beyond whether firms have made an effort towards whether they can prove their approach actually works. Bereavement is a real test of a firm’s culture: poorly designed journeys, with unclear letters, repeated requests for information and avoidable delays, compound distress at an already difficult time.

The FCA has been explicit that this review sits within a wider, outcomes-focused supervisory direction for 2026/27, in which vulnerable customers, fair value and customer understanding are core supervisory points rather than secondary considerations.

Who is affected?

Consumer investment and advice firms handling bereaved customers’ accounts and transfers, and the boards and executive teams accountable for how those journeys are designed, monitored and improved.

Key risks

• Bereavement journeys that rely on unclear communications, repeated information requests or avoidable delays, compounding customer distress.
• Policies that describe good intentions on paper without evidence that outcomes are actually being delivered.
• Governance gaps where boards cannot show how bereavement outcomes are measured or where weaknesses exist.

Actions to take

1. Map the end-to-end bereavement journey and identify where communication, delay or repeated requests cause friction.
2. Introduce a single point of contact and streamlined information requests to reduce repetition for bereaved customers.
3. Record how quickly cases are resolved, where delays arise, and what feedback customers give.
4. Brief the board on outcomes evidence and the changes made where those outcomes fall short.

Wider implications

The bereavement review is best understood as a marker of where Consumer Duty supervision is heading: the FCA is increasingly testing firms against real customer experiences rather than abstract frameworks, and bereavement is unlikely to be the last customer journey to face this level of scrutiny.

Recommendations

Firms should independently review and test their bereavement and other vulnerable-customer journeys end-to-end, covering governance, process, data and outcomes, so they can evidence effectiveness rather than simply describing policy intent.

Boards should satisfy themselves that they understand how these journeys work, how outcomes are measured, and what action has been taken in response to earlier FCA findings.

We’re supporting firms that are taking a closer look at how effectively their Consumer Duty frameworks operate in practice, particularly for vulnerable customer journeys such as bereavement. TCC independently reviews and tests these journeys end‑to‑end, helping firms assess whether governance, processes, data and outcomes stand up to regulatory scrutiny. From board level challenge and outcomes assurance through to targeted reviews of customer support models and evidence of effectiveness, we help firms move beyond policy intent to demonstrable, regulator ready outcomes. Get in touch to discover how we can help your firm.