Ad description
Two TV ads for Dignity Funerals t/a Simplicity Cremations seen in January 2026:
a. The first ad featured an individual speaking to the audience. They said, “More people have been opting for what’s been called ‘the way to go’. A funeral plan from Simplicity Cremations offers one of the UK’s best value funeral plans saving thousands of pounds compared to the cost of a traditional funeral.” A second individual then said, “Simplicity has put my mind at rest that everything will be dealt with so all my friends and family can have a day out on me.” The ad then displayed on-screen text “Low cost funeral plan only £1699”. The first individual then spoke again “In a world of worry […] ever increasing prices, when your time comes to go, Simplicity Cremations is the way to go” followed by further on-screen text that stated, “funeral plans made simple”.
b. The second ad featured two individuals who played musical instruments and sang on the stage in a theatre. They sang individually and together and stated, “Simplicity cremations way to go way to go who needs the complications […] you’ll find help and consolation with those who really know. Simplicity cremations […] they could save you quite a packet […] save your precious money it only goes to show.” On-screen text during the ad stated, “Funeral Plans made simple…”.
Issue
The complainant, who understood the “funeral plan” was for a non-attended cremation only, challenged whether the ads were misleading.
Response
Dignity Funerals Ltd t/a Simplicity Cremations said the ads made clear they were a large funeral provider offering a direct cremation service. They said the difference between the advertised price and the cost of a full attended funeral meant consumers were unlikely to understand the product as an attended funeral, and that the service inclusions were clearly set out online. They also said “funeral plan” was the Financial Conduct Authority’s (FCA) regulatory term for prepaid funeral products, including direct cremation plans, and that terms such as direct, simple and pure cremation were widely used across the funeral sector. They believed they were generally understood by consumers to mean a low-cost, non-attended cremation. They said they used the Simplicity Cremations brand to clearly distinguish their offering from other funeral plans.
They said both ads made clear through the branding and wording that they related to direct or simple cremations. They also said ad (a) [AM1.1]referred to the lower cost of a Simplicity Cremation compared with a “traditional funeral”, directed viewers to a verification page setting out what the service provided, and was intended to build awareness of the brand and product in line with the FCA framework. They further highlighted that the significant difference between the advertised price and the average cost of a traditional funeral made it unlikely that consumers would understand the plans advertised included a full attended funeral. They also said the testimonials referred to separate memorial gatherings organised by family members, and that reinforced that the plan covered only the cremation itself rather than an attended funeral service.
They said the ad (b) was a brand ad focused on savings and did not state a price. They therefore did not believe it was misleading as to what was included as it did not depict or imply attendance at a crematorium service. They nevertheless accepted that additional clarity would be helpful and said they would add on-screen text to make the nature of the service clearer.
Clearcast said they were satisfied the ads did not suggest that Simplicity Cremations offered a fully attended funeral service. They said “funeral plan” was the FCA’s regulatory term and “direct funeral” was a recognised industry term for a cremation-only plan. They believed there was nothing in the visuals, voice-over or audio likely to mislead viewers. They also said the superimposed text identifying Simplicity as a trading name of Dignity Funerals Ltd made clear it was a streamlined offering from a larger funeral provider. They added that references to a non-traditional plan, repeated mentions of cremation and signposting to further information made sufficiently clear the nature and extent of the service and did not exaggerate what was included. They also highlighted that ad (b) was a brand ad that was intended to encourage consumers to seek further information, and that the associated landing page clearly explained what was included in the plan.
Assessment
Upheld
The ASA understood that Simplicity Cremations offered a cremation plan which did not include an attended, commemorative service at the crematorium.
We considered that, in the absence of any attended service or ceremony, the advertised plan was materially different from what many viewers were likely to understand a funeral to involve. Pre-paid funeral plans were subject to regulation by the FCA, and we understood that the FCA considered the term ‘funeral plan’, as used to describe a regulated pre-paid funeral product, was not, of itself, misleading simply because a plan was limited to a non-attended cremation. However, we understood the FCA expected advertising to be clear about the nature and scope of the service provided, particularly where it differed from what a consumer might commonly associate with a funeral.
Because the plan on offer was not one that many viewers were likely to regard as a typical funeral, we considered it was important that the ads clearly conveyed the nature of the service covered by the plan. We also considered that funeral arrangements were likely to be of particular importance and sensitivity to consumers, because they related to their own end-of-life planning or that of a loved one. In that context, details of what was and what was not included in the advertised plan were material information and therefore needed to be presented clearly.
Ad (a) stated, “A funeral plan from Simplicity Cremations offers one of the UK’s best value funeral plans saving thousands of pounds compared to the cost of a traditional funeral”. The ad also included the on-screen claims “Low cost funeral plan only £1699” and “funeral plans made simple”. We considered that viewers were likely to understand the repeated, unqualified use of the term “funeral plan”, together with the comparison with a “traditional funeral” and the emphasis on saving “thousands of pounds”, to mean that the product was a lower-cost version of a funeral of the type they would usually expect.
We acknowledged that the advertised price was lower than the quoted average cost of a traditional funeral and considered that viewers were likely to understand that the plan offered a less expensive service. However, we did not consider that the price comparison alone made sufficiently clear that the plan excluded attendance at the cremation and any commemorative service altogether.
Ad (b) featured two individuals performing a musical jingle on a theatre stage, repeatedly singing “Simplicity Cremations, way to go, way to go”, alongside claims including “who needs the complications”, “they could save you quite a packet” and “save your precious money”, in conjunction with the on-screen text “Funeral Plans made simple”. Taken together, and in the absence of any clarifying information, we considered viewers were likely to understand those claims as meaning the advertiser was offering a lower-cost funeral plan of the kind viewers would usually expect, rather than a materially different service. We accepted the ad focused mainly on the advertiser’s branding rather than on the details of a particular plan, and that it did not state a price. We also acknowledged the advertiser’s view that it was intended as a brand awareness ad. However, in the context of the savings claims and the on-screen text “Funeral Plans made simple”, and without any further information, we considered viewers were likely to understand that the advertiser was offering a cheaper funeral of the kind they would usually expect, rather than a plan limited to a non-attended cremation.
We acknowledged the ads directed viewers to a verification page containing further information about the plan. However, we considered that information regarding the plan not including an attended service was material information. We therefore considered the fact that no attended service was included in the plan should have been made sufficiently and prominently clear in the ad itself.
We welcomed Simplicity Cremations’ willingness to amend their advertising to make clear that the funeral plan was for a direct cremation only and that attendance and ceremony were not included.
Because the ads omitted material information making clear that the funeral plans were limited to non-attended cremations, we concluded the ads were misleading.
The ads breached BCAP Code rules 3.1 and 3.2 (Misleading advertising).
Action
The ads must not appear again in the form complained of. We told Dignity Funerals Ltd t/a Simplicity Cremations to ensure that their ads made clear, with sufficient prominence, that the funeral plans advertised were for non-attended cremations only.
