In 2023, FTC staff members posing as consumers called 278 randomly selected funeral homes across the United States and asked for pricing information. The Funeral Rule requires providers to give price information over the phone to anyone who asks.
The results were not encouraging.
While over 70% of providers eventually gave pricing information, it sometimes took multiple calls to get it. Thirty-seven providers quoted different prices for the same services on different calls. And 39 providers, roughly 14%, failed to provide pricing information at all. Those 39 received warning letters from the FTC in January 2024.
This was the first telephone pricing sweep in the Funeral Rule's history. Forty years of a telephone disclosure requirement, and 2023 was the first time the FTC systematically tested whether providers were complying with it.
The results tell two stories at once. The first story is that most providers do comply when asked. The second story is that a meaningful minority don't, that the FTC had never checked before, and that the enforcement mechanism for the most basic consumer protection in the Rule had gone essentially untested for four decades.
The State of Funeral Pricing in 2026
To understand where price transparency stands today, you need to understand three layers: what the Rule requires, what the industry does, and what consumers experience.
The Rule requires funeral providers to give you a printed GPL during in-person meetings and price information over the phone when you call. That's the floor. It has been the floor since 1984.
What the Rule does not require is any form of electronic or online disclosure. A funeral home can have a beautifully designed website with photos of its facilities, testimonials from families, and a detailed description of every service it offers, and include no prices whatsoever. This is perfectly legal under federal law.
Some providers post their prices online voluntarily. Studies by the Consumer Federation of America have examined how many funeral homes make pricing information available on their websites. The findings have consistently shown that a majority of providers do not post their GPL or any itemized pricing online. The families who want to comparison-shop before picking up the phone or walking through the door are, in most cases, unable to do so.
This is the central tension of the price transparency debate: the Rule gives families the right to ask for prices, but it does not give them the ability to see prices without asking. In every other major consumer market, from healthcare to home repair to car insurance, the trend over the past two decades has been toward proactive, digital price disclosure. The funeral industry remains an exception.
The Online Pricing Debate
Every FTC review cycle since 2019 has centered on the same question: should funeral providers be required to post their General Price List on their website?
The arguments in favor are straightforward. Families should be able to see prices before they're sitting in an arrangement room. Comparison shopping is impossible when pricing requires a phone call or an in-person visit. The emotional dynamics of at-need funeral purchasing make it especially important that families can review costs in advance, outside the pressure of the arrangement conference. Online disclosure brings the Rule into alignment with how consumers actually shop in 2026.
The arguments against are more varied. Industry groups have raised several concerns. Pricing is complex and may be misunderstood without context. Small, family-owned funeral homes may face compliance burdens that larger providers can absorb more easily. Families may make decisions based on price alone without understanding the value of the services being offered. And some providers argue that the existing telephone disclosure requirement is sufficient.
The FTC's 2022 ANPR dedicated 15 of its 40 questions to electronic price disclosure. The agency held a public workshop on the topic in September 2023. Consumer advocacy groups submitted comments overwhelmingly in favor of mandatory online posting. Industry associations, including the largest trade groups in funeral service, submitted comments opposing it or proposing alternatives that would stop short of mandatory price posting.
One proposal that received significant attention was the idea of requiring funeral homes to provide a mechanism on their website for consumers to request pricing information, rather than requiring them to post the prices directly. Under this approach, a consumer visiting a funeral home's website would find a button or form to request the GPL, rather than the GPL itself.
The distinction is meaningful. A posted GPL allows instant comparison across multiple providers. A request mechanism requires the consumer to initiate contact with each provider individually, wait for a response, and then compile the information themselves. The former is a transparency tool. The latter is a disclosure process that adds friction at every step.
As of this writing, no online posting requirement has been adopted. The 2022 ANPR produced comments, a workshop, and then silence. No proposed rule has followed.
What Other Industries Have Done
The funeral industry's resistance to online pricing is not unique in the history of consumer markets, but it is increasingly exceptional.
Healthcare underwent a similar transformation. The Hospital Price Transparency Rule, which took effect in January 2021, requires hospitals to post their standard charges online in a machine-readable format. The rule was met with significant industry resistance. Compliance has been uneven. But the principle was established: consumers have a right to see prices before they commit to care.
Real estate, automotive sales, legal services, and financial services have all moved toward greater price transparency over the past two decades, driven by a combination of regulation, consumer demand, and competitive pressure from digital-first entrants.
In each of these industries, incumbents initially argued that their services were too complex to price transparently, that consumers would misunderstand the information, and that disclosure would undermine the value of professional expertise. In each case, the market moved toward transparency anyway, and the providers who adapted thrived.
The funeral industry is not immune to these forces. It is simply behind.
What Families Can Do Right Now
The absence of an online posting requirement does not mean families are powerless. Here's what works today.
Call and ask. The Funeral Rule requires providers to give you pricing information over the phone. Call two or three funeral homes, ask for the price of the specific services you're considering (direct cremation, immediate burial, a traditional service with viewing), and write down what they tell you. You are exercising a legal right when you do this.
Ask for the GPL by email. The Rule requires in-person delivery and phone disclosure, but many providers will email or fax their GPL if you ask. There is no prohibition on electronic delivery, only an absence of a mandate. A polite request often works.
Look for providers who post voluntarily. A growing number of funeral homes, particularly independent and digitally-savvy operators, post their pricing online as a competitive differentiator. If a provider posts their prices, that tells you something about how they approach transparency in general.
Check third-party resources. Organizations like the Funeral Consumers Alliance maintain directories and pricing information in some markets. State-level consumer protection agencies sometimes publish funeral pricing guides.
If You're a Funeral Professional
The providers who post their prices online are not doing so because a regulation requires it. They're doing it because they've calculated, correctly, that transparency builds trust and trust drives business.
Families in 2026 expect to see prices before they buy. They expect it from their doctor, their mechanic, their attorney, and their contractor. The funeral homes that meet this expectation are positioned as consumer-friendly. The ones that don't are increasingly perceived as having something to hide, whether or not that perception is fair.
The regulatory question of whether online posting should be mandatory is distinct from the business question of whether it's smart. The regulatory question remains unresolved. The business question has been answered by every other service industry that has undergone this transition.
The funeral homes that will lead the next decade are the ones that got ahead of the mandate.
What Comes Next
In Part 8, we'll look at where the Funeral Rule ends and state law begins. The federal Rule is a floor, not a ceiling, and the patchwork of state regulations that layers on top of it creates a landscape that varies dramatically depending on where you live.