Culture Counts Response to findings of the Independent Review of Creative Scotland
On Wed 3 December, Culture Counts held an online gathering for Core Members to explore the findings and recommendations of the independent review of Creative Scotland.
We invited four prepared contributions from those working across the sector, followed by wider discussion. This note captures those discussions with our core members - key themes that arose in reaction to the review, and reflections on how Creative Scotland might move towards meaningful and long-term change.
The below note can also be downloaded as a PDF here
Summary
The Creative Scotland review arrives at a significant moment for cultural policy in Scotland. It identifies issues that affect funding, planning, workforce sustainability and the condition of local cultural infrastructure. It also recognises the need for clearer direction in how the national development body supports and engages with the wider ecosystem. The review captures some, but not all, of the complexity within the sector. This is partly a result of the review’s scope, which focused on Creative Scotland rather than the wider operating environment, and partly a result of who was most visible within the process. The report reflects experiences that are already close to Creative Scotland’s programmes and structures, which means that organisations and practitioners outside that space see less of their reality represented. This creates an uneven picture of current conditions and possible routes forward.
A central question emerging from the review is how to turn this moment into lasting improvement. Incremental adjustments or isolated actions will not address long term challenges. The next phase needs to be shaped by an ambition to secure the long-term health of the cultural ecosystem as a whole. On its own, the review provides only a partial platform for this. Its value will depend on how the recommendations are interpreted, prioritised and aligned with wider national commitments.
Some recommendations are practical and relate to internal processes. Others are broad in scope and require further definition before they can be delivered. There is considerable work ahead to turn these ambitions into actions that are fair, accessible and grounded in the experiences of those currently underrepresented or excluded.
Culture Counts continues to advocate for a Culture Act for Scotland as a route to provide this wider framework. A statutory approach would support long term planning, embed culture across public policy and ensure that Creative Scotland operates within clear national duties that reinforce both independence and accountability. Aligning the implementation of the review with the development of this legislation would create coherence, reduce the risk of fragmented reform and deliver greater impact for the sector and for communities across Scotland.
Our discussions with those across the arts, heritage and creative industries identified the following key opportunities, concerns and areas of interest emerging from the report and recommendations:
Equalities
Discussion highlighted the limited attention given to equalities. The review's analysis is brief and does not set out a clear picture of how structural barriers shape participation, representation or progression within the sector. The review notes challenges around diversity but does not explore the underlying conditions that maintain these patterns or the interventions required to change them.
There is also little evidence of meaningful engagement with those most affected by inequality. The experiences of marginalised groups are underrepresented and equalities led organisations were not prominently reflected in the review process. This creates gaps in understanding and risks leaving equalities framed as broad intentions rather than essential conditions for credible change. A more substantial approach will be needed in the implementation phase, with clear routes for input from those currently excluded or constrained by existing systems.
Risk
The review highlights the need for Creative Scotland to develop a clearer and more confident approach to risk. This was broadly welcomed by those in attendence, although there was caution about how far this can progress without wider system change. Discussions drew a distinction between financial risk, operational risk and risk within funding decisions, noting that each requires different conditions and support.
There was strong concern about risk created by external factors, particularly uncertainty in government budgets and short-term allocations. Creative Scotland should not be expected to absorb instability that sits outside its control. A shift in risk appetite will only be credible if government provides the stability, time and financial clarity needed for strategic planning. Without this, expectations of increased risk taking may place more strain on the national body and on those applying for funding.
There was also interest in how Creative Scotland could use the flexibility already present in its remit. A more assured leadership role, supported by clear national policy, would make it easier to take proportionate risks in support of artistic practice. This requires adequate staffing and resources, along with a policy environment that recognises that innovation, experimentation and cultural growth involve uncertainty.
Any move toward increased risk must protect the arm's length principle. It should not shift risk on to organisations or individuals with limited capacity. A stronger framework for cultural policy, as proposed through developing a Culture Act, could help align expectations, clarify responsibilities and give Creative Scotland the confidence to make decisions that balance innovation with accountability.
Advocacy
The review proposes a stronger advocacy role for Creative Scotland. There was broad agreement on the value of a national body that can articulate cultural impact, contribute to policy development and draw on intelligence across the sector. This can support clearer national direction and help strengthen the profile of culture across government.
Creative Scotland cannot, however, replace independent advocacy from sector organisations, nor can it speak for parts of the ecosystem beyond its direct reach. A stronger advocacy role would require wider engagement and partnership working, so that Creative Scotland’s understanding is informed by people with different expertise, rather than by its own structures alone. Any expansion of this role must protect the arm’s length principle and avoid diverting resources away from front line delivery.
Governance, leadership and transparency
The review’s call for stronger governance, clearer performance oversight and a more durable long-term strategy was widely supported. There is a clear need for a Board with a broader mix of skills and lived experience, including voices that reflect the diversity of Scotland and the full breadth of the cultural ecosystem. Concerns were also raised about the very limited representation of minority ethnic communities and the review’s light treatment of equalities more generally.
Trust in Creative Scotland has eroded in recent years and rebuilding it will rely on greater openness in decision making, consistent communication and more meaningful engagement across the sector. This also depends on ensuring that staff have the time and resources to build relationships across different parts of the sector. Better knowledge of local contexts and lived experience will support stronger governance and leadership and will shape the credibility of any wider change that follows the review.
Regional and place-based work
Regional perspectives need to sit at the centre of any future change. The review acknowledges the importance of local insight but gives it limited depth. Access to cultural opportunity varies widely across Scotland, with sustained underinvestment in areas including (but not limited to) Ayrshire and Inverclyde, and higher living and delivery costs in many island communities. Digital infrastructure is uneven, which affects organisations’ ability to modernise at the same pace. Local authority capacity also differs significantly, further enabling or limiting what happens at a regional or local level.
Contributions to the discussion highlighted that the review continues to reflect conversations largely concentrated in Edinburgh and Glasgow. Smaller towns, rural areas and Islands are not well represented, and community-based work is largely absent. There is a risk that redesign, if approached narrowly, could repeat the centralising tendencies that have contributed to current pressures. Regional insight is not peripheral, as it affects the fairness of funding decisions, the sharing of risk, and whether the system is able to support equitable outcomes rather than uniform inputs. Strengthening understanding of place would support better decision making and enable stronger partnership with local authorities and other organisations that understand local delivery conditions.
Lasting improvement in regional equity will require more than changes within Creative Scotland. A Culture Act could provide the statutory footing needed to link national ambition with local delivery, ensuring that regional insight becomes a core part of how decisions are made across the whole system.
Relationships and staffing
Revisiting relationship-based roles has value, but only if Creative Scotland has the capacity to deliver them well. Staff are already operating under significant pressure. Adding responsibility for wider engagement without addressing resourcing risks deepening existing gaps between organisations with strong networks and those without comparable social or financial capital.
Trust will rely on sustained visibility, clearer communication and a commitment to understanding place-based needs. Any changes to staffing structures need to support this, rather than create new layers of expectation. A credible shift in how Creative Scotland relates to the sector will depend on investment in staff, realistic workloads and consistent engagement across the full breadth of cultural activity.
Funding, processes and proportionality
The review recognises the need for clearer financial planning, a capital strategy and more streamlined funding processes. This reflects long standing concerns about bureaucracy, delays and uncertainty. Proportionality also requires more than shorter forms. It needs processes that reflect the capacity of organisations, reduce unnecessary burden and give applicants confidence that decisions are transparent and consistent.
There is strong support for improved digital systems and for making more data publicly available. Clearer use of existing flexibilities would help Creative Scotland respond to need with greater precision, although this must be backed by stable budget conditions. Better designed funding processes would support a more confident sector and help rebuild trust in how decisions are made.
Arm's length principle
The review raises important questions about the balance between government and Creative Scotland. Recent years have seen growing concern about “short arms” practice, where government influence has become more visible in how decisions are made or communicated. This has affected confidence across parts of the sector. The report notes the need for clearer delegation and more flexibility in grant conditions. This is positive only if it results in stronger independent decision making, not weaker. The protection of independent artistic judgement is a basic condition for a credible national body.
Discussion also pointed to wider factors that shape how the arm’s length principle works in practice. Funding uncertainty has limited Creative Scotland’s ability to operate with the stability expected of an independent body and has sharpened risk aversion across the system. Expectations from government have at times risen faster than the resources or structural footing available to meet them. Any reform that flows from the review should reinforce Creative Scotland’s independence in its funding decisions and place responsibility on government to create the conditions that allow the organisation to act with clarity and authority. A future Culture Act could provide this stability by setting out clear duties, roles and protections that support both accountability and independence.
Broader sector concerns
Several important issues sit largely outside the review’s scope, despite being central to how cultural work happens across Scotland. Community arts received little attention, even though it provides vital routes into participation and supports many of the outcomes that national policy seeks to advance. The review also does not reflect the scale of precarity across the workforce or the gap between training pipelines and the availability of paid work. Digital access remains uneven, particularly in island communities, and expectations around delivery will need to account for these constraints.
Discussion also raised concerns about the absence of commitments on safe reporting spaces, workforce representation in governance, or clearer pathways for people who do not have established networks. These gaps matter, as they shape who can participate in the system and who remains excluded.
Taken together, the review offers a useful start but does not fully capture the diversity, complexity or ambition of Scotland’s cultural ecosystem. Its value will depend on how the next phase is designed and delivered. A coherent national approach is needed to drive long term progress, bring clarity to roles and responsibilities, and ensure that change reaches every part of the country. Aligning the implementation of the review with the development of a Culture Act would provide a framework capable of supporting that direction.