The Financial Conduct Authority's Consumer Duty rules took effect in July 2023 for new and existing products, and were extended to closed products in July 2024. The Duty requires regulated firms to deliver 'good outcomes' for retail customers across four headline outcomes — products and services, price and value, consumer understanding, and consumer support. Bereavement was not explicitly named in the Policy Statement. It has, nonetheless, become one of the practical battlegrounds on which the Duty has been enforced.
What changed in practice
Before the Consumer Duty, bank bereavement teams varied considerably in their handling of executors and surviving family members. Some banks ran specialist bereavement units with dedicated phone lines and reasonable turnaround times. Others routed bereavement enquiries through their general customer service queues, with predictable results — long waits, repeated explanation of the circumstances, inconsistent documentation requirements between calls. The Financial Ombudsman Service received a measurable upturn in bereavement complaints in 2019 and 2020.
The Consumer Duty has, broadly, forced standardisation upward. The major UK banks now operate dedicated bereavement teams with defined service-level agreements, single points of contact, and standardised documentation lists communicated in writing at the first contact. Where they do not, the Ombudsman has begun to find against them under the Duty's consumer support outcome. The case law is young but consistent.
The fair-value question
The Duty's price and value outcome has had a less visible but arguably more important effect on bank account closure timing. Before the Duty, banks were not under explicit pressure to close deceased accounts promptly; balances continued to attract whatever interest rate (typically negligible) the account paid, and the bank retained the funds during whatever period it took to complete the closure. The Duty makes that pattern questionable. A regulated firm holding an executor's funds for longer than necessary, on terms unfavourable to the estate, is not delivering fair value.
The practical effect, observable across the industry, has been a tightening of the time between document submission and account closure. Where it was routine in 2022 to wait six to eight weeks after submitting probate, the median in 2025 is closer to three. The slowest-moving banks have, in some cases, been the subject of public ombudsman decisions.
What an executor should expect
Three things, at first contact with a UK retail bank. A named bereavement specialist as a single point of contact. A written list of the documentation the bank requires — typically the death certificate, the grant of probate or letters of administration where applicable, and a current photo identification for the executor. A stated timeline for account closure once the documentation is complete.
Where any of those three is not forthcoming, the executor has a legitimate basis to escalate within the bank and, if necessary, to the Financial Ombudsman Service. The Ombudsman is not a slow process; bereavement complaints are typically resolved in three to six months, against a low burden of proof. The existence of the route has, by all available evidence, improved the average bereavement experience even for executors who never need to use it.