Evidence to the Creative Scotland Review and Future Policy Priorities 

Blog from Joseph Peach, Culture Counts’ Director - Policy and Public Affairs

It's now been just over six weeks since the beginning of Kathryn Welch and I's tenure as co-directors of Culture Counts. It’s not been a case of starting completely from scratch for either of us - I first joined the Culture Counts as project coordinator in 2021 and have subsequently held various permanent and interim roles.  

Since starting, there’s been a lot to jump into in relation to my area of focus within our co-directorship, policy and public affairs. Kathryn posted a blog last month which outlined some recent thinking, looking with fresh eyes at Culture Counts role, remit, reach and impact from a network, projects and partnerships perspective. There are similar considerations for me in terms of the ongoing development of our approach to policy and public affairs. 

This blog explores that a wee bit – in terms of Culture Counts’ future policy and public affairs activity, as well as our recent submission of written evidence to the Independent Review of Creative Scotland. 

Future plans: 

I’m finding it helpful to think about there being two sides to this work, the reactive and proactive. Where we need to react - providing evidence, analysis and opinion on behalf our network and the wider ecosystem they support. This is largely in response to external events, processes of policy development, parliamentary scrutiny and decision making. Recent years have been characterised by a need to work almost entirely reactively, particularly in relation to Scotland’s public funding for culture.   

But looking towards the Scottish Parliament election next year and beyond, there are increasing (and fast approaching) opportunities for Culture Counts to be proactive, towards our ultimate aim to: 

  • promote the public benefit of the arts, heritage and creative industries, and  

  • protect the eco-system of the arts, heritage and creative industries for our common future; through administration and policy change. 

  • demystify the operations of Government and Parliament; allowing more people from the arts, heritage and creative industries to influence policies that impact on them’. 

In the weeks and months ahead there will be more from us on this front, moving towards shaping a shared vision for policy change through to the election and beyond. We’ve already been having lots of good conversations about this, but if there is something you’re interested to discuss or share information on - if your organisation is also developing manifesto asks or have any other thoughts on the above, please do drop me a line.  

As well as this, there is a busy time coming up in terms of reacting - ensuring input into existing processes. On the near horizon are the next round of Scottish Parliament’s Constitution, External Affairs and Culture Committee’s Pre-Budget Scrutiny for 2026/27, and Scottish Government’s Consultation on the draft Scottish Environment Strategy. And of course there’s the ongoing Independent Review of Creative Scotland, covered below in more detail.  

Independent Review of Creative Scotland: 

This week, we submitted written evidence to the Independent Review of Creative Scotland - our submission can be read in full here. Given the breadth of the remit, and the volume of views and evidence being received by the review team, our eventual submission sought to be quite targeted, focusing on the on areas of maximum potential impact and widest relevance across our network and the wider sector, while avoiding duplication.  

Recommendation 1 is about who the review is reaching:  

Culture Counts would highlight that it is equally important that Independent Review of Creative Scotland also considers whether methods of engaging and gathering views to inform this process are creating any unintended barriers, or if there are areas requiring specific support in order to ensure that a diverse range of experiences, perspectives and expertise are reflected in the evidence. 

The primary way in which the review has engaged with people has been through roundtable discussions and a call for written evidence. Both involve individuals or organisation members of staff self-selecting to engage with the process.  

We’ve heard from members of our steering group and wider network that while this openness to written evidence, and roundtables being held in a variety of locations is positive, that the approach may also hold some barriers to engagement, particularly when it comes to marginalised groups.  

Creative Scotland research highlights pay gaps within the sector, including in relation to race, disability, gender and socioeconomic background. These are symptoms of much wider structural issues within the sector, which the review has the opportunity to play a part in addressing.  

But this will only be possible if input from marginalised people is duly considered. The expertise of those with lived experience, and those working in this area tell us that when it comes to processes such as the Independent Review of Creative Scotland, a more considered, tailored and proactive approach to engagement with marginalised groups is required. 

Recommendation 2 is about the deployment of Government Grant Aided Expenditure (GAE) and National Lottery Distribution Fund (NLDF) proceeds across Creative Scotland’s funding streams:  

Culture Counts recommends that the independent review of Creative Scotland should consider the need for a clear, transparent and publicly available strategy or decision-making rationale in terms of the respective roles of Grant Aided Expenditure and National Lottery funds in supporting each funding stream delivered by Creative Scotland. 

Whether funds distributed by different Creative Scotland funding streams originate from Scottish Government Grant Aided Expenditure (GAE) or the National Lottery Distribution Fund (NLDF) is a seemingly technical distinction. But through close involvement in discussions, campaigning and the development of evidence around funding for culture over recent years, we know that this technical matter underpins couple of wider strategic issues, which the review has an opportunity to address.  

  1. The varied mix of GAE and NLDF across different CS funding streams (i.e. Multi Year Funding being primarily enabled by GAE, and Open Funds for Individuals and Organisations being primarily enabled by NLDF), and lack of a decision-making framework in this regard, points to a lack of clarity over how funding priorities are set, and by whom - whether allocation decisions reflect SG policy, CS strategy, or a combination of both.  

  2. Government and Lottery allocations to CS are subject to very different decision-making conditions, timescales and planning horizons. The lack of a clear framework for how these sources are deployed across CS programmes limits long-term planning ability and sustainable delivery by both CS and the wider ecosystem the organisation supports. 

Appendix i of our submission provides further briefing on current conditions and recent history of Scottish Govt and National Lottery inputs to Creative Scotland, as well as setting out the benefits that could be realised by developing and adopting a decision-making framework on this matter: 

  • Providing clarity and confidence to Scotland’s cultural sector by setting out SG and CS’s responsibilities in setting the GAE/NLDF mix within each funding stream; 

  • Creating a clearer link between strategic ambitions for culture, and the role of these investment streams in delivering that ambition; 

  • Enabling a greater ability to meet demand and resilience to external economic factors in the delivery of funding streams by CS; 

  • Supporting long-term planning across both CS in terms of delivering these funding streams, and the culture sector in terms of delivering activity. 

Of course, as well as Multi-Year and Open funding, CS delivers a range of targeted funding streams, each of which are underpinned by their own mix of GAE and NLDF. These considerations, in terms of a more structured approach to the GAE/NLDF mix will also be relevant to these funding streams. 

Recommendation 3 is about the review’s process of analysis, prioritisation and recommendation:  

Culture Counts recommends that this latter phase of the review include time for draft recommendations or findings to be offered for consultation with sector representatives ahead of finalisation. 

The review has had a huge amount of input from across the sector. The review’s stated aim of reporting by November 2025 means there is a huge amount for the team to consider in a relatively short amount of time.  

Given the enormous potential influence of the review’s outcome, it is clear to us that further consultation with the sector is of critical importance. We believe strongly that the sector needs to have an opportunity to understand the direction of travel and provide additional input before any findings and recommendations are finalised and enacted. 

What next? 

There’s plenty coming up from a policy and public affairs perspective, as we work to develop our vision for change through the next election and beyond, as well as responding to ongoing workstreams. Our thinking on how we approach this work was also highlighted in Kathryn’s recent blog:  

We’re confident that the greatest opportunity here comes from our work with high-level policy and decision makers who influence the future of the arts, heritage and creative industries (that includes funders, Government, senior civil servants and so on). We think that what we can do best is (on the one hand) to gather, understand and interrogate the complexity and nuance of experiences across the breadth of the sector, and (on the other) to build trusted, informed relationships with those in decision-making roles. Then, the opportunity for us is to present an accessible, compelling and robust case for the arts, focussing on the areas where there’s a potential for change (over the long or short term), and distilling the core messages without over-simplifying. That understanding helps clarify and focus our work - to prompt wide-ranging conversation across the sector (and with other sectors, too), and to create compelling, timely and robust cases for support. 

Our greatest strength is our network, so we’re keen for folk to stay in touch and to be involved. There are a number of ways to do so: 

Culture Counts