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Andrew Evans
Andrew Evans • 18 Dec 2025
Partner, Director, Counterculture Wales

Counterculture Response to the Hodge Review

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Baroness Margaret Hodge’s independent review of Arts Council England (ACE) was published on 16th December 2025. Our team gives an initial response to some of its headline recommendations.

The Hodge review (https://www.gov.uk/government/publications/arts-council-england-an-independent-review-by-baroness-margaret-hodge/arts-council-england-an-independent-review-by-baroness-margaret-hodge ) makes twenty-one main recommendations; largely thoughtful, sensible steps that could result in modest but meaningful improvements in access to high-quality arts for people across England.

After some slightly feverish speculation, it is good to see a clear recommendation that Arts Council England should remain and that the arm’s length principle should be rigorously upheld – however it is unclear how achievable this will be in the light of the report’s recommendation that swathes of decision making related to funding should be devolved to bodies including representatives from local government; there is surely a high risk that this approach will lead to funding decisions in different areas of the country being swayed by our increasingly polarised electoral maps.

It was reassuring to see a clear statement that arts has been underfunded for the last decade, though with the predictable caveat that “fiscal constraints limit the government’s ability to increase Grant in Aid funding for culture and the arts.” This is both untrue (the government is entirely free to decide to spend money on the arts rather than elsewhere) and a clear signal that we can expect no significant increase to ACE’s available funds.

Instead the Hodge Review proposes a smorgasbord of possible funding mechanisms to get extra money into the sector. Some of these seem likely to be effective, such as extensions to theatre and orchestra tax relief and the removal of legacy capital charges. Others are highly unlikely to survive Treasury scrutiny – particularly “doubling the level of Gift Aid from £0.25 to £0.50 for shows, events and organisations that reach audiences outside London and the South East to encourage philanthropy outside the Capital”; a policy that would not only rightly elicit howls of protest from the rest of the charity sector, but would also mean that you’d get twice as much tax relief for a show in the richest parts of Cheshire as you would in Barking or Newham.

Other recommendations on funding – such as that “ACE should work with the sector to develop a better capability in philanthropic giving” – largely repeat things that have been said many times before. In fact ACE has done significant work in this area and the fact that the UK arts scene has not become like the US one in terms of philanthropy says far more about wider UK attitudes to philanthropy than about any supposed failures in the sector. We are also unconvinced that ACE needs a trading arm – and certainly if it is to enter into more esoteric funding models than grant-making and the occasional loan this would need to be properly resourced with expert skills. The proposal for ACE to take what are effectively equity stakes in commercially successful tours sounds unnecessarily complex and we believe there are better ways to incentivise organisations that make profits to invest in the grassroots of the sector.

We suspect few arts organisations will mourn the recommended shelving of Let’s Create and are likely to welcome a shift away from an approach which has felt painfully difficult to apply to and report against. Of course (and particularly in the current political and economic climate) the risk is that the good ground that has been gained through Let’s Create (wider access to the arts) will be lost – although the recommendations do make clear that diverse groups should be represented not just in funded organisations but in the Arts Council itself.

Reforms to the National Portfolio Organisation (NPO) programme are long overdue, and a simpler system with a longer cycle and the opportunity for organisations to apply on a rolling basis are all welcome. The opportunity for NPOs to determine their own KPIs in negotiation with ACE is a sensible approach; but publication of these KPIs, organisational performance against them, and clear results of failure to meet KPIs will be essential if the current suspicion, amongst a wide range of stakeholders, that NPOs are not treated consistently in response to their performance is to be dispelled.

The recommendation that “National ACE” and a National Board of experts should determine the funding of all the organisations across the country that are “nationally significant” is an interesting one, and we hope that this can lead to an ongoing healthy debate (and not a factional feud) about what constitutes “significant”, and who gets to determine that.

Our experience in working with local authorities in developing culture strategies is that where these are deeply owned at a senior level within the organisation they can be a powerful tool for putting arts and culture at the heart of placemaking and policy. The effectiveness of Government mandating the creation of strategies on councils is, however, not a happy one. While we would love to see every local authority having a regularly updated culture strategy we aren’t convinced that making everyone do it will lead to the kind of enthusiastic embrace that is required for transformative effect.

Whilst we love the British Library (BL) (!) the proposal that the development role for libraries would be better undertaken there than by ACE fails to understand how vastly different the role of the BL is to the local authority and volunteer-run lending libraries they would be responsible for developing.

Finally, we hope that the recommended “comprehensive overhaul” of ACE’s systems will hasten the demise of the much-loathed Grantium!

Article written by Counterculture Partners Andrew Evans and Susanna Eastburn.

Photo credit: Arindam Mahanta

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