Strengthening the English Devolution & Community Empowerment Bill

by Trevor MacFarlane FRSA

Director & CEO of Culture Commons

“We’re delighted to announce that the UK Government have agreed to adopt our recommendation for ‘culture’ to be explicitly included as an eight area of competence in their flagship devolution legislation!”

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Introduction

 

The English Devolution and Community Empowerment Bill represents a significant shift towards a more coherent, place-based model of governance in England. By transferring powers to Strategic Authorities and strengthening the frameworks for collaboration, planning and accountability, it begins to address the deep-rooted over-centralisation that has constrained local leadership, civic capacity and long-term growth.

However, while the Bill meaningfully strengthens the architecture for economic decision-making, it stops short of embedding the creative, cultural and heritage ecosystem within that architecture. As drafted, it provides no clear statutory route through which MHCLG, DCMS and DSIT – or the arm’s-length bodies they sponsor – can work in a joined-up way with Strategic Authorities. This leaves the previous White Paper’s ambition for cultural partnership structurally underpowered and culture, creativity and heritage outside the formal machinery of devolution.

This omission matters. High-quality devolution is not only about where powers sit, but about the capabilities that enable places to use those powers well. Culture, creativity and heritage are core to those capabilities. They are the systems through which people experience place, shape identity, build trust and participate in civic life. They drive regeneration, support innovation and generate economic, social and cultural values simultaneously, with well-evidenced spillovers across health, education, skills, tourism and enterprise.

Crucially, these sectors make devolution real. People do not encounter devolution through institutional diagrams or governance frameworks; they encounter it through the cultural life of their places – the spaces, stories and institutions that anchor belonging and pride. It is through these experiences that strategy becomes shared ownership, governance becomes lived experience, and growth becomes something communities can see, feel and help to shape. When culture is absent from the statutory framework, devolution risks remaining abstract, technocratic and disconnected from everyday experience.

Our proposed amendments close this gap. They translate the intent of the English Devolution White Paper – which recognised culture, heritage and the creative industries as drivers of growth, wellbeing and civic renewal – into clear, workable legislative provisions. They establish the cultural ecosystem not as a discretionary add-on, but as strategic infrastructure: a foundational component of place-based leadership and inclusive growth.

Importantly, these proposals work entirely within the Bill’s existing architecture. They draw on the powers to convene and collaborate, the planning and reporting duties, the conferral and pilot mechanisms, and the neighbourhood and community-rights framework already before Parliament. They are grounded in extensive research led by Culture Commons, developed with 30 core partners and more than 250 stakeholders from across the creative, cultural and heritage sectors through The Future of Cultural Devolution in the UK programme.

We do not pretend to have all the answers on implementation. Devolution is, by its nature, an iterative process, and the precise mechanisms through which culture and heritage are embedded will rightly vary and be determined by the needs of different places. But what is clear is that this is a critical moment: if culture and heritage are not included within the devolution framework now, they risk being structurally sidelined for a generation.

This is also not a case for new layers of bureaucracy or significant new fiscal commitments – though we hope the UK Government will increase investment in our sectors more generally. It is about ensuring that Parliament’s proposed devolution settlement is coherent, future-facing and capable of delivering on its own ambitions. Embedding culture and heritage alongside transport, housing, skills and infrastructure strengthens local strategy, improves accountability and enables more meaningful public participation, deepening civic trust and ensuring that devolution is measured not only in powers transferred, but in fairness, inclusion and a genuine sense of pride in place.

Cultural devolution connects policy to people. It turns strategy into shared ownership, governance into lived experience, and growth into something communities can see, feel and help to shape. By doing so, it deepens civic trust and ensures that devolution is measured not only in outputs and powers transferred, but in fairness, inclusion and a genuine sense of pride in place.

Taken together, our amendments offer a practical and proportionate route to make this vision real – ensuring cultural devolution becomes a living expression of empowered local leadership, resilient places and long-term national renewal.

Summary

  • Amendments A1–A2 designate culture, creativity and heritage as a formal area of competence for Strategic Authorities, alongside transport, housing, skills and health. This closes a structural gap in the Bill and recognises the proven contribution of our sectors to inclusive growth, innovation and wellbeing.

    Building on that competence, B1–B2 require each Tier 3 Strategic Authority to prepare a Cultural Ecosystem Plan – a multi-year statutory plan, aligned with Clause 38 (Local Growth Plans), that maps assets, workforce and participation, sets measurable outcomes, and integrates culture across spatial, skills and regeneration strategies.

  • C1–C2 establish Culture Forums under Clauses 21–22 to embed cross-sector partnership and workforce participation at the heart of devolved decision-making. These bodies will act as focal points for local communities and key policymakers alike.

    D1–D2 empower mayors to appoint a Culture Commissioner – a senior regional leadership role akin to the Deputy Mayor for Culture in London that will sit alongside other Commissioners for other policy areas – to coordinate policy, represent the ecosystem across constituent councils, and ensure accountability in delivery.

  • E1–E2 introduce a discretionary Overnight Accommodation Levy power, enabling mayors to capture a modest proportion of visitor spend and reinvest it in creative, cultural and heritage renewal – mirroring existing levy powers for transport and proven local models such as Greater Manchester’s City Visitor Charge and Edinburgh’s Visitor Levy.

    K1–K2 add a Cultural Infrastructure Duty to the Community Infrastructure Levy provisions (Schedule 19), requiring authorities to “have regard to” cultural infrastructure when setting and spending CIL priorities, thus placing theatres, studios, museums and heritage facilities on equal statutory footing with transport and housing.

    I1–I2 strengthen community ownership by explicitly naming cultural infrastructure within the Community Right to Buy (Clause 60 et seq.), empowering communities to protect, acquire and steward cultural assets central to local identity.

  • F1–F2 extend the Bill’s accountability framework so that cultural participation, transparency and neighbourhood input are embedded in devolved governance – linking the Annual Devolution Report (Clause 19) and Neighbourhood Committees (Clause 58) to local cultural planning, participatory budgeting and public reporting.

    J1–J2 place cultural data, evidence and evaluation on a statutory footing by expanding Clauses 37–38 to require that Strategic Authorities collect, publish and use consistent cultural data alongside economic and spatial evidence. This ensures that future decisions associated with our sectors are informed by shared standards and measurable outcomes, supported by an independent National Cultural Data Observatory.

Amendments in detail…

Allow culture, creativity & heritage to benefit from the Bill

Current Gap

As drafted, the Bill standardises devolved competences in seven policy domains, including transport, infrastructure, regeneration, housing and skills, yet makes no reference to culture, creativity or heritage.

Their absence from the Bill as a defined policy area fails to reflect the way that these sectors’ function – intersecting with, and improving outcomes associated with the existing seven policy competencies but also requiring their own suite of policies to truly flourish. It also implies that culture, creativity and heritage sit outside the everyday business of devolution; an assumption at odds with both the evidence we have amassed and practice on the ground.

To continue to omit our sectors from statute as this new tier of sub-regional governance takes shape would be to render invisible one of the most distinctive and proven levers for successful devolution. Without explicit recognition, these sectors risk being relegated to merely discretionary or symbolic – confined to the status quo of ad-hoc projects and short-term grants – rather than embedded within the strategic machinery of devolution that will drive prosperity, wellbeing and belonging.

Policy Objective

To ensure that our sectors are recognised as core strategic domains within the English devolution framework – embedded alongside transport, infrastructure, skills and planning – so that they can benefit from the Bill’s new powers and accountability mechanisms.

Our research has unearthed the myriad ways that our sectors can contribute to, and benefit from, ‘cultural devolution’. Recognising them formally within the Bill will align legislation with the reality of how mayors and Strategic Authorities are already leading – championing culture as a driver of regional and local identities, regeneration and pride – and encourage future Strategic Authorities to do so.

  • Amend Schedules 6 and 19 (eligible functions of Strategic Authorities) to include “Culture, Creativity and Heritage” within the list of default policy domains. This amendment will enable Strategic Authorities to exercise the new powers conferred elsewhere in the Bill in support of these sectors when they are ready to do so, rather than relying on ad-hoc conferrals or secondary instruments on a “deal by deal” basis.

    Cross-reference Clauses 20 to 22 (General Power, Power to Convene, and Duty to Collaborate) to ensure these provisions expressly extend to our sectors, with appropriate recognition of the roles of devolved decision-making bodies and the arm’s-length principle - an important ingredient that is celebrated at the national level and must now move down to the sub-regional. This will make clear that cultural and creative governance falls squarely within the collaborative, multi-agency architecture the Bill already envisages for other policy areas.

  • Amend Clause 49 (Requests for new mayoral functions) to create a clear, criteria-based route for Strategic Authorities to request devolved cultural functions and associated budgets, building on the new competence established under A1.

    This should require the Secretary of State to respond to requests within a defined timeframe against published tests including:

    • local institutional capacity and inclusive governance arrangements, such as a Culture Forum (C1);

    • alignment with the area’s Local Growth Plan (Clause 38) and an agreed Cultural Ecosystem Plan (B1); and

    • arrangements for transparent, independent and arm’s-length decision-making.

    This will ensure that once culture, creativity and heritage are recognised in statute (A1), there is a clear, lawful mechanism for Strategic Authorities to activate those powers in practice and integrate them into multi-year devolved settlements as readiness allows.

Intended Outcomes

Formally recognising culture, creativity and heritage within the Bill (A1) and providing a clear route to activating these powers (A2) will:

  • Institutionalises culture, creativity and heritage as a core area of devolved competence – placing them on an equal statutory footing with transport, housing, infrastructure and skills.

  • Eliminates ambiguity and ad-hocism by giving Strategic Authorities a clear, lawful pathway to take on cultural functions and budgets when they are ready to do so.

  • Enables multi-year, accountable planning for culture and creativity within the same devolved systems that drive growth, wellbeing and regeneration.

  • Aligns national intent with local practice, recognising how mayors and Strategic Authorities are already championing cultural investment and innovation across their regions.

  • Strengthens collaboration and transparency by embedding culture, creativity and heritage within the Bill’s wider framework for partnership, data and accountability.

  • Elevates cultural leadership as a defining feature of English devolution – ensuring that the power to shape local economies is matched by the power to shape the stories, identities and shared spaces that give them meaning.

Require Strategic Authorities to produce a Cultural Ecosystem Plan

Current Gap

Clause 38 requires Strategic Authorities to prepare Local Growth Plans addressing economic conditions, infrastructure, skills and regeneration, but it contains no requirement to plan for the creative, cultural and heritage life of the region that underpins many of these outcomes. Of course, the “creative industries” will feature in some Local Growth Plans already – particularly in those sub-regions with burgeoning creative clusters – but this will not necessarily meet the needs of the wider ecosystem they are part of.

Our research suggests that the absence of a statutory duty means that cultural planning remains inconsistent within sub-regions across England – often reliant on local champions, discretionary projects or short-term funding. This absence in the Bill overlooks one of the most powerful and proven levers for civic renewal and regional productivity: culture’s ability to regenerate high streets, animate public spaces, strengthen wellbeing, and sustain skilled employment.

Policy Objective

To ensure that every Establish Mayoral Strategic Authority develops a statutory Cultural Ecosystem Plan to compliment the Local Growth Plan required under Clause 38, placing a clear duty on authorities not only to include culture, creativity and heritage within their economic and spatial strategies, but to take active responsibility for these as core elements of local infrastructure.

The Cultural Ecosystem Plan will build on the new competence for culture we’re calling for (A1), the explicit “Right to Request” cultural powers (A2), as well as ensure they are matched by responsibilities for Strategic Authorities to plan and invest in the ecosystem. The new plans will interact with the Bill’s broader architecture – particularly the powers to convene and collaborate (Clauses 20–22) and the data and reporting duties (Clauses 37–38 and 19) – giving Strategic a structured, evidence-led framework for long-term, locally led cultural development and investment.

  • Amend Clause 38 and Schedule 19 to require that any Strategic Authority seeking to progress to Tier 3 of the Devolution Framework must prepare and publish a multi-year Local Cultural Ecosystem Plan, developed in partnership with its constituent local authorities.

    The plan should focus on the strategic tier – adding value to, and aligning with, local cultural and creative strategies that are already in place – so that regional priorities complement, rather than duplicate or override, existing local plans and activity.

    The Local Cultural Ecosystem Plan should:

    • map tangible and intangible cultural infrastructure (venues, studios, archives, heritage assets, digital networks and public-realm assets);

    • analyse workforce and participation flows, including freelancers, SMEs and supply-chain dependencies;

    • detail governance and participation arrangements drawing on the collaborative powers set out in Clauses 20–22 – including how a Culture Forum (C1) might be implemented.

    • compliment Local Growth Plans (Clause 38), local spatial and skills strategies, and relevant health-improvement plans (Clause 43);

    • set clear indicators for inclusion, wellbeing, civic identity, productivity and growth (which could be aligned across Strategic Authorities to allow for meaningful within and between sub-regional areas); and

    • include a transparent funding profile (capital and revenue) and evaluation framework informed by our proposedNational Cultural Data Observatory (J1).

  • Amend Clause 38 to require the Secretaries of State for MHCLG and DCMS to issue joint statutory guidance setting minimum national standards for the preparation and review of Local Cultural Ecosystem Plans.

    The guidance should promote consistency of approach while enabling local flexibility and innovation, and should cover:

    • data definitions, reporting formats and shared indicators (cross-referencing Clauses 37–38);

    • public engagement and participation protocols, ensuring representation from freelancers, micro-businesses, civil society organisations and the wider public; and

    • evaluation methodologies and outcome indicators aligned with the Annual Devolution Report (Clause 19).

    The Bill should further specify that Strategic Authorities must “have regard” to this joint guidance, to published advice from relevant arm’s-length bodies (such as Arts Council England, Historic England and The National Archives), and to the recommendations of the Culture Forum (C1) in developing and delivering their Plans.

Intended Outcomes

  • Institutionalises culture, creativity and heritage as core components of local and regional infrastructure – making them a statutory element of inclusive growth, wellbeing and civic renewal.

  • Operationalises the new cultural competence and Right to Request powers (A1–A2) through a clear, evidence-led planning mechanism that turns ambition into delivery.

  • Creates a consistent national framework for cultural planning, underpinned by joint statutory guidance, while preserving local flexibility and innovation.

  • Generates multi-year, evidence-based investment pipelines, linking cultural development directly to the data, planning and reporting duties set out in Clauses 19, 37 and 38.

  • Reduces reliance on short-term project funding by embedding culture within strategic planning cycles and capital investment programmes.

  • Strengthens accountability and alignment across government tiers by connecting the Local Cultural Ecosystem Plan (B1) with the Culture Forum (C1), Culture Commissioner (D1) and National Cultural Data Observatory (J1).

  • Integrates culture across economic, social, health and civic domains, ensuring that devolved authorities treat creativity and heritage as drivers of prosperity, wellbeing and pride in place.

  • Fulfils the Bill’s wider mission of empowerment, giving communities and regions not only the means to grow economically but the tools to shape their stories, identities and shared futures.

Mandate Strategic Authorities to set up a Culture Forum

Current Gap

The Bill introduces welcome mechanisms, including Power to Convene (Clause 21) and Duty to Collaborate (Clause 22), but provides no clarity on how collaboration should operate in specific policy domains. In the cultural sphere, this leaves open the risk of closed-door decision-making by existing institutional leaders, excluding freelancers, small creative businesses and community representatives who are integral to the health of the ecosystem.

Without a clear participatory structure, devolved powers could consolidate rather than democratise cultural governance – undermining public legitimacy and the principle of community empowerment that underpins the Bill.

Policy Objective

To embed legitimate, transparent and inclusive local cultural decision-making within Strategic Authorities. A Culture Forum will ensure that culture, creativity and heritage are co-produced through genuine partnership across the sub-region, rather than top-down imposition, giving effect to the principles and collaborative powers introduced under Clauses 20–22.

A Culture Forum will give local stakeholders a way to activate the proposed new competence for culture, creativity and heritage (A1) and participate in the new planning duty established under (B1), ensuring that decisions taken through those frameworks are informed by the full range of local voices – from freelancers and SMEs to heritage, civil-society and public representatives.

Where collaboration structures already exist, such as Cultural Compacts operating at the sub-regional scale, they are often under-resourced and inconsistent. Upgrading them to a Culture Forum that is included in statute could stabilise these developing partnerships and ensure that every sub-region can benefit from inclusive, enduring governance.

  • Use MHCLG guidance under Clauses 21–22 to require each Strategic Authority to establish or designate a Culture Forum as the statutory consultative body for the cultural domain at the sub-regional level.

    Each Culture Forum should take a whole-place approach, bringing together representatives from across the regional ecosystem alongside other sectors such as health and social care, education, skills, housing, transport and regeneration.

    A Culture Forum should:

    • act as the strategic nexus for regional cultural policy, linking local government, business, civil society and national arm’s-length bodies;

    • co-design and oversee the Local Cultural Ecosystem Plan (B1) and advise on investment priorities, evaluation and funding criteria;

    • recommend policy on business models, skills, innovation and cultural infrastructure;

    • include civil-society groups and members of the public, selected through open or representative processes, to ensure decisions reflect regional diversity; and

    • over time, participate directly in allocating devolved and regional cultural funds.

    Each Culture Forum should be co-chaired by the mayor (or equivalent) and a prominent industry figure, providing both democratic and sectoral accountability.

    Membership should reflect the partner categories in C1 and align with:

    • the Local Cultural Ecosystem Plan (B1),

    • the Cultural Infrastructure Duty (K1), and

    • the National Cultural Data Observatory (J1), contributing shared data and evaluation evidence.

    Embedding this structure ensures regional cultural governance becomes institutionalised within the new devolution settlement, creating a durable mechanism for public participation, sector alignment and shared stewardship of local creative futures.

  • Amend or supplement Clauses 21–22 to specify that, in exercising powers for creative, cultural and heritage matters, mayors and Strategic Authorities must convene and collaborate with the following categories of partners:

    • national arm’s-length bodies (e.g. Arts Council England, Historic England, The National Archives);

    • constituent local authorities;

    • NHS / Integrated Care Systems where culture contributes to health and wellbeing outcomes;

    • representatives of the cultural and creative workforce, including freelancers and trade unions;

    • SME and micro-business representatives;

    • civil-society and grassroots cultural organisations; and

    • members of the public selected through open or representative processes (e.g. sortition or public call-out).

    These categories should be set out in statutory or policy guidance issued under Clauses 21–22, and cross-referenced in the guidance proposed under B2 (Local Cultural Ecosystem Plans).

Intended Outcomes

  • Institutionalises transparent and inclusive governance for the creative, cultural and heritage sectors within devolved structures, ensuring decisions are legitimate, accountable and representative.

  • Operationalises Clauses 20–22 by turning procedural collaboration powers into active, statutory mechanisms for partnership and participation.

  • Provides the formal architecture through which Local Cultural Ecosystem Plans (B1) are co-produced, monitored and reviewed – anchoring culture in the everyday business of devolved policymaking.

  • Strengthens alignment across tiers of government by connecting Culture Forums (C2) with the Culture Commissioner (D1), Cultural Infrastructure Duty (K1) and National Cultural Data Observatory (J1), creating a coherent regional governance ecosystem.

  • Builds public trust, accountability and civic pride by embedding workforce, civil-society and public voices directly into policy formation, investment and evaluation.

  • Demonstrates that cultural powers are exercised with communities, not merely for them, realising the Bill’s principle of empowerment through partnership and shared leadership.

  • Secures long-term legitimacy and continuity by institutionalising participation as a defining feature of English devolution – ensuring that cultural governance endures beyond political cycles and individual champions.

Enable Mayors to Appoint a Culture Commissioner

Current Gap

The Bill already enables mayors and Strategic Authorities to appoint commissioners in other policy domains – such as transport, health, skills and infrastructure – under the general powers (Clause 20) and the duties to convene and collaborate (Clauses 21–22). However, because culture, creativity and heritage are not currently defined as an area of competence within the Bill (A1), there is no equivalent provision for formal cultural leadership.

Some places, like the Greater London Authority, have shown how roles such as the Deputy Mayor for Culture and the Creative Industries can transform coordination and visibility, while other sub-regional governance structures rely on particularly talented officers, informal champions or have dispersed responsibilities. The absence of a point person appointed by elected people limits accountability, weakens strategic coherence, and diminishes the profile of culture within broader devolved policymaking.

Policy Objective

To strengthen leadership and coordination for the creative, cultural and heritage sectors within devolved governance by establishing a statutory power for mayors and Strategic Authorities to appoint a Culture Commissioner – a dedicated champion responsible for driving strategy, ensuring accountability, and linking cultural priorities to wider social and economic outcomes.

  • Amend Clause 20 (General Power of Strategic Authorities) to allow each mayor or Strategic Authority to appoint a Culture Commissioner with defined functions to:

    • oversee and develop the sub-regional Cultural Ecosystem Plan (B1);

    • chair or co-chair the Culture Forum (C2);

    • advise on integration of culture, creativity and heritage across local growth, health, skills and regeneration strategies;

    • ensure relevant data is fed into the National Cultural Data Observatory (J1); and

    • represent the Strategic Authority in internal and external regional, national and international cultural partnerships.

    Appointments should follow transparent, merit-based processes consistent with public appointments principles. Commissioners should be appropriately remunerated and may hold non-executive status within the Authority to ensure independence of voice.

  • MHCLG should issue guidance under Clauses 20–22 specifying:

    • indicative responsibilities and reporting expectations;

    • coordination approaches with national arm’s-length bodies and DCMS agencies; and

    • minimum standards for engagement withCulture Forums, local authorities and the creative workforce.

Intended Outcomes

  • Brings the new cultural competence (A1–A2) to life by creating a clear and empowered leadership mechanism to champion culture, creativity and heritage across the devolved landscape.

  • Provides visible, accountable and trusted leadership within each devolved area - ensuring that culture has a clear voice alongside other statutory portfolios such as transport, health, and skills.

  • Transforms coordination and coherence by establishing a consistent statutory focal point linking local, regional and national partners – from DCMS and arm’s-length bodies to local authorities, business, education and civil society.

  • Embeds cultural expertise at the heart of strategic decision-making, ensuring that creativity, heritage and participation are fully integrated into growth, regeneration, health and skills agendas.

  • Strengthens delivery and oversight of Local Cultural Ecosystem Plans (B1) and Culture Forums (C2), providing the leadership spine through which cultural priorities are co-produced, monitored and evaluated.

  • Connects evidence to action by ensuring that local data and insights feed into the National Cultural Data Observatory (J1), supporting transparent and data-informed policymaking.

  • Raises visibility and ambition for the cultural, creative and heritage sectors – giving them an authoritative advocate able to engage confidently with investors, funders and international partners.

  • Builds public trust and civic pride by making cultural leadership transparent, professional and rooted in place – demonstrating that devolution delivers not only power but shared cultural purpose and local voice.

  • Institutionalises leadership beyond individual champions or political cycles, securing a durable mechanism for cultural stewardship within the architecture of English devolution.

Open opportunities for Cultural Devolution Pilots

Current Gap

Clauses 49–50 allow the Secretary of State to confer new functions on mayors and Strategic Authorities or respond to formal requests for such powers. However, the Bill and its Explanatory Notes do not identify culture, creativity and heritage as an area suitable for early pilot conferrals. Nor do they define what a pooled cultural settlement might entail, or how learning from such pilots would be captured and shared.

As drafted, cultural devolution risks remaining aspirational but untested – without structured experimentation to demonstrate feasibility, clarify fiscal flows, or build the confidence of both Whitehall and sub-regional partners.

Policy Objective

To activate the Bill’s conferral powers (Clauses 49–50) by establishing Cultural Devolution Pilots within Strategic Authorities who want to run them. The pilots will test how pooled cultural budgets, arm’s-length governance and participatory decision-making processes can deliver stronger local outcomes, build capacity and inform future cultural devolution across the country.

This amendment builds on our finding that several Strategic Authorities are keen to take on new powers and “do things differently” in their sub-regions through enhanced cultural devolution deals that see the sub-regional structure taking on more responsibilities for cultural decision making. It will also ensure that those sub-regions have the necessary plans and local oversight and accountability mechanisms in place before taking on additional responsibilities.

Piloting initiatives with Strategic Authorities sitting within different tiers of the new Devolution Framework will allow for meaningful comparative analysis and ensure that cultural devolution evolves in a way that works for sub-regions at different stages of their development and different regional contexts.

  • Amend the Explanatory Notes or MHCLG guidance accompanying Clauses 49–50 to:

    • designate culture, creativity and heritage as priority domains for early pilot conferrals;

    • invite vanguard Strategic Authorities to apply for “pooled cultural settlements” combining relevant DCMS and arm’s-length-body funding streams into a single multi-year devolved pot;

    • require each pilot to establish transparent, arm’s-length allocation mechanisms – which could be the Culture Forum (C1) or other; and

    • require areas to align any pilots with a clearCultural Ecosystem Plan (B1).

  • Make approval of any Cultural Devolution Pilot agreement contingent upon:

    • a regionally agreed Cultural Ecosystem Plan (B1);

    • the establishment of a Culture Forum (C1);

    • the appointment of a Culture Commissioner (D1);

    • two-way secondments between DCMS/ALBs and the Strategic Authority, ensuring national expertise is “crowded-in”;

    • a peer-learning commitment to share insights with other devolved areas; and

    • a robust independent evaluation protocol, with an agreement to feed relevant data and findings into the proposedNational Cultural Data Observatory (J1).

Intended Outcomes

  • Creates an evidence-based pathway to test and refine devolved cultural governance within the Bill’s existing framework, turning aspiration into practical delivery.

  • Builds institutional capacity and policy coherence in participating regions, ensuring governance, data and accountability structures are proven before wider roll-out.

  • Models how pooled, multi-year cultural settlements – administered through arm’s-length and participatory mechanisms – can improve efficiency, transparency and local responsiveness.

  • Encourages cross-departmental collaboration between MHCLG, DCMS, HM Treasury and arm’s-length bodies, demonstrating how cultural devolution supports wider missions on growth, wellbeing and levelling up.

  • Generates robust comparative evidence across different tiers and regional contexts, feeding data and analysis into the National Cultural Data Observatory (J1) to inform national policy design.

  • Codifies lessons learned through evaluation and peer-learning commitments, creating an open knowledge base that shapes statutory guidance and future legislation.

  • Builds long-term confidence among central and local partners that devolved cultural powers can be exercised responsibly, accountably and with public participation.

  • Positions culture, creativity and heritage as a testbed for high-trust devolution, showing how shared governance and community partnership can deliver both democratic legitimacy and tangible local impact.

Enable Strategic Authorities to establish an Overnight Accommodation Levy

Current Gap

The Bill currently provides fiscal powers for transport and infrastructure but omits culture, heritage and the visitor economy. This gap prevents local leaders from capturing even a modest share of visitor-driven revenue to reinvest in the cultural infrastructure that underpins local pride, identity and growth.

While voluntary models such as Accommodation BIDs have shown promise, they remain patchy, limited and legally fragile. Without a statutory power, regions cannot scale these efforts equitably or transparently – undermining both fiscal autonomy and the Bill’s broader mission to empower places to lead their own regeneration.

Policy Objective

This power would give mayors the tools to link cultural investment directly to local economic growth, visitor strategy and civic identity, ensuring that the assets attracting visitors are sustained by the revenues they help generate.

Comparable models, including the City Visitor Charge in Greater Manchester and Edinburgh’s Visitor Levy (operational 2026), demonstrate that modest, well-designed levies can be developed that add stable and publicly acceptable income streams for cultural and tourism reinvestment. Mayors across England have now publicly called for the same powers, underlining strong cross-regional and cross-party demand.

Embedding this fiscal flexibility within the English devolution framework would provide the funding backbone to operationalise the new cultural competence (A1–A2), deliver on Cultural Ecosystem Plans (B1–B2), and sustain the collaborative governance structures established through the Culture Forum (C2).

  • Insert a new clause enabling mayors or Strategic Authorities (and, where appropriate, constituent councils) to introduce a percentage-based levy on overnight accommodation within a nationally defined framework.

    This power should be enabling, discretionary, and locally co-designed, allowing each area to:

    • develop its levy structure in consultation with creative, cultural and heritage ecosystem (including hospitality and tourism sectors) and community stakeholders;

    • align it with delivering against the Cultural Ecosystem Plan (B1); and

    • allocate revenues in line with priorities agreed through theCulture Forum (C2).

  • MHCLG guidance should set out national guardrails while allowing flexibility in local design. Key principles could include:

    • Progressivity: levy set as a modest percentage (e.g. 3–5%) of room cost, so higher-end stays contribute proportionately more.

    • Ring-fencing: revenue restricted to investment in creative, cultural and heritage and visitor-facing public-realm infrastructure and programmes identified in each area’s Cultural Ecosystem Plan (B1).

    • Redistribution spine: a small national top-slice (e.g. 5–10%) to support areas with fragile cultural ecosystems or low visitor volumes.

    • Transparency: annual publication of revenue and expenditure through Annual Devolution Report (Clause 19) and Infrastructure Funding Statements.

    • Partnership safeguards: co-design with hospitality, including exemptions (children, emergency accommodation, etc.) and transitional arrangements to maintain competitiveness.

Intended Outcomes

  • Establishes a fair, progressive and locally accountable fiscal tool that empowers mayors and Strategic Authorities to reinvest visitor income in the creative, cultural and heritage assets that sustain local identity and economic vitality.

  • Provides a sustainable, predictable revenue stream that reduces dependence on short-term or competitive central funds, enabling multi-year, need-based investment across the cultural ecosystem.

  • Anchors culture and creativity within local economic and visitor strategies, directly supporting the integration goals of Clause 38 and delivering tangible benefits to residents and visitors alike.

  • Institutionalises joint governance and transparency, linking levy design and oversight to the Culture Forum (C2) and aligning reporting with the Bill’s data and accountability duties (Clauses 19 and 37–38).

  • Advances regional equity through a modest redistribution mechanism that channels resources to under-represented or lower-visitor-volume areas, spreading opportunity more evenly.

  • Demonstrates fiscal devolution in practice, showcasing how local, democratically led levies can strengthen both economic resilience and cultural sustainability.

  • Reinforces civic pride and public legitimacy by ensuring that the economic value generated by visitors is visibly reinvested in the shared cultural spaces, events and institutions that make each place unique. 

Introduce a Cultural Infrastructure Duty

Current Gap

Clause 33 of the existing Bill modernises CIL powers for Strategic Authorities, enabling revenue-raising for local infrastructure associated with growth and regeneration. However, no duty to consider cultural, creative and heritage infrastructure.

As a result, cultural assets compete informally with higher-profile priorities such as transport or housing, limiting mayors’ ability to invest strategically in the physical and civic infrastructure that underpins local identity and participation. This omission contradicts the Bill’s commitment to balanced, place-based growth and civic empowerment.

Policy Objective

To ensure that mayors and Strategic Authorities formally consider and invest in creative, cultural and heritage infrastructure when exercising their Community Infrastructure Levy (CIL) powers under Clause 33 and Schedule 14, placing culture on an equal statutory footing with transport, housing and skills as a driver of inclusive growth, wellbeing and civic pride.

Extensive analysis by Culture Commons and others demonstrates that current growth and planning frameworks consistently overlook the cultural infrastructure that anchors communities and drives regeneration. Cultural facilities – from theatres and studios to museums and civic spaces – generate measurable social and economic returns, including increased footfall, tourism, wellbeing, and local identity. Yet without statutory recognition, they remain structurally under-prioritised and under-funded.

Introducing a Cultural Infrastructure Duty would correct this imbalance, embedding culture as a core pillar of place-based investment. It would give mayors and Strategic Authorities legal clarity and fiscal confidence to direct levied funds toward theatres, heritage assets, creative workspaces and public-realm projects that sustain local economies and enrich civic life.

  • Amend Clause 33 and Schedule 14 making Strategic Authorities, as CIL charging authorities, have regard to the needs identified of the Cultural Ecosystem Plan (B1) when setting, revising and spending CIL.

    Clarify through the CIL Regulations and MHCLG guidance that cultural infrastructure should be defined broadly and dynamically in a way that is responsive, relational and place-specific, encompassing both tangible and intangible assets – an approach being developed at the Bennett Institute of Public Policy at the University of Cambridge.

    Accordingly, eligible cultural infrastructure could include:

    • Tangible assets: cultural and creative venues (theatres, studios, galleries, rehearsal and digital production spaces), heritage and museum facilities, community and civic cultural spaces, and public-realm improvements that enable participation and enhance the visitor offer; and

    • Intangible systems: the networks, social infrastructure, skills, and digital tools that sustain participation, access and creative activity across communities.

    Guidance should stress that cultural infrastructure planning must be adaptive and evidence-led, responsive to local demographic, economic and social change, and developed collaboratively through the Culture Forum (C1) and informed by data from the National Cultural Data Observatory (J1).

  • Use Schedule 19 guidance on Local Growth Plans to require each Strategic Authority to publish a Cultural Infrastructure Statement or annex that:

    • draws directly on the Cultural Ecosystem Plan (B1);

    • lists priority cultural projects and identifies both tangible and intangible assets, consistent with the adaptive framework (G1);

    • sets out how infrastructure priorities will evolve over time in response to population, participation and economic data where possible; and

    • details how CIL (and complementary funding sources (e.g. the Overnight Accommodation Levy (F1)) will be used to deliver and maintain these infrastructures.

    Economic assessments under Schedule 18 should be revised to:

    • incorporate baseline and trend data on cultural infrastructure, participation, and workforce dynamics;

    • use shared metrics and methodologies developed with the National Cultural Data Observatory (J1) to ensure consistency across regions; and

    • include a mechanism for periodic review, enabling Strategic Authorities to update infrastructure priorities as community needs change.

    Together, these provisions will make cultural-infrastructure planning iterative, evidence-led and responsive, linking CIL investment decisions directly to the evolving realities of local people, places and the cultural, creative and heritage ecosystem.

  • Integrate cultural infrastructure into core planning and funding documents. Require each Strategic Authority’s Infrastructure Funding Statement to explicitly reference cultural-infrastructure priorities, aligned with its Local Growth Plan (Clause 38) and Cultural Ecosystem Plan (B1). This will make culture visible within the statutory investment cycle and enable long-term, transparent tracking of outcomes.

    Issue joint statutory guidance defining and measuring cultural infrastructure. Direct the Secretary of State for MHCLG to issue guidance under Clause 33(7), developed jointly with DCMS and its arm’s-length bodies (Arts Council England, Historic England, The National Archives). This guidance should:

    • set out typologies and evaluation metrics for both tangible and intangible infrastructure, drawing on the Bennett Institute for Public Policy’s 2025 framework for Measuring Social and Cultural Infrastructure;

    • promote adaptive and participatory assessment, recognising that cultural infrastructure evolves with social and economic conditions; and

    • align definitions and indicators with the National Cultural Data Observatory (J1) to ensure data coherence across regions.

    Ensure governance alignment and accountability. Require that all CIL allocations for cultural purposes are consistent with the Cultural Ecosystem Plan (B1) and overseen through the Culture Forum (C1), ensuring participatory decision-making and arm’s-length accountability.

    Embed transparency and national learning. Mandate that outcomes and expenditure on cultural infrastructure are monitored and reported annually through theAnnual Devolution Report (Clause 19), using shared indicators from Clauses 37–38. This will provide a transparent evidence base for comparative analysis and continuous policy learning across devolved areas.

Intended Outcomes

  • Institutionalises culture, creativity and heritage within England’s statutory infrastructure-planning system, granting them parity with transport, housing and other growth priorities.

  • Creates a clear, lawful and flexible route for CIL funding to support both physical and social dimensions of cultural infrastructure.

  • Links fiscal, spatial and cultural planning, aligning investment with data, governance and accountability duties across Clauses 19, 33 and 38.

  • Modernises the definition of infrastructure, adopting the Bennett Institute’s adaptive model so that cultural investment remains responsive to social, demographic and technological change.

  • Strengthens regeneration and civic renewal through culture-led placemaking and sustained investment in community assets.

  • Builds long-term resilience, providing devolved authorities with a predictable mechanism for maintaining and expanding local cultural ecosystems beyond the usual funding cycles.

  • Enhances alignment and transparency through joint MHCLG–DCMS guidance and integrated oversight by the Culture Forum (C1) and National Cultural Data Observatory (J1).

  • Reinforces civic identity and pride, ensuring that every pound raised through the levy strengthens not only the built environment but also the cultural and social fabric that makes places thrive.

Protect & grow community cultural assets through Community Right to Buy

Current Gap

Part 5 of the Bill (Clauses 60–65) expands community-asset transfer and ownership rights but makes no reference to cultural infrastructure. As a result, theatres, studios, local museums, rehearsal spaces, and heritage buildings remain vulnerable to displacement by rising land values or redevelopment pressures.

Existing community-rights mechanisms (such as Assets of Community Value under the Localism Act 2011) have had limited success in the cultural sphere, largely due to:

  • the absence of clear definitions of cultural infrastructure;

  • insufficient technical support for communities wanting to make purchases; and

  • a lack of financial tools or guarantees to make acquisition viable.

Without reform, cultural devolution risks entrenching inequality – enabling well-resourced sub-regions and civic organisations with access to capital and expertise to take advantage of new powers, while leaving under-resourced or marginalised communities unable to protect the cultural assets most vital to their local identity and participation.

Policy Objective

To safeguard and strengthen the creative, cultural and heritage infrastructure that anchors local identity by explicitly including cultural assetswithin the Bill’s Community Right to Buy provisions (Clauses 60–65).

This measure will ensure that the new era of English devolution halts the loss of local cultural spaces – from rehearsal studios and grassroots venues to archives and heritage buildings – by giving communities a clear statutory route to ownership and stewardship.

Building on the new cultural competence (A1–A2), the strategic planning duty (B1–B2), and the participatory governance mechanisms established through the Culture Forum (C2), this amendment embeds community rights to take action to protect the cultural assets most important to them. It connects policy, planning, funding and ownership, ensuring that the spaces sustaining cultural life are treated as core infrastructure, not optional amenities.

  • Amend Clause 60 (Community Right to Buy: eligible assets) and related definitions to include cultural infrastructure as a distinct asset category encompassing, amongst other things:

    • cultural venues, rehearsal and performance spaces;

    • creative workspaces, studios, and digital production hubs;

    • libraries, museums and archives;

    • historic building and heritage sites; and

    • community-run or volunteer-led cultural activities of recognised local significance.

    Require MHCLG – in partnership with DCMS – to issue joint statutory guidance defining and categorising these assets taking the adaptive approach to social and cultural infrastructure prosed under G1. The guidance should:

    • provide nuanced definitions recognising both tangible and intangible value;

    • outline streamlined valuation, interim protection and transfer procedures; and

    • align asset listings with theCultural Ecosystem Plan (B1) andNational Cultural Data Observatory (J1) to ensure national coherence and comparability.

  • Create a technical assistance window to fund pre-feasibility studies, legal advice, business planning and valuation costs for community cultural acquisitions.

    Establish a loan guarantee or underwriting facility, potentially managed at the Strategic Authority level, to de-risk community acquisitions and encourage co-investment.

    Enable Strategic Authorities to act as facilitators and convenors, using devolved powers to:

    • broker partnerships between communities, developers and funders;

    • offer match-funding or long-term lease-back arrangements; and

    • coordinate support via the Culture Forum (C2) and Cultural Infrastructure Duty (G1–G3) to ensure sustainability beyond acquisition.

    This ecosystem approach ensures that local cultural assets are not only saved but also sustained and animated as living, productive parts of the regional cultural economy.

Intended Outcomes

  • Protects the physical and social fabric of local cultural life by giving communities a statutory right to acquire and steward creative and heritage assets of civic importance.

  • Aligns ownership with the new devolved planning framework, ensuring that cultural infrastructure identified in Cultural Ecosystem Plans (B1) is backed by enforceable rights and protections.

  • Empowers residents, freelancers and civic groups to take long-term responsibility for vital cultural spaces, shifting from reactive campaigning into structured stewardship.

  • Reduces loss and displacement of community venues, heritage buildings and creative workspaces that underpin participation, identity and local employment.

  • Creates a practical bridge between the Bill’s planning and empowerment functions – linking Clauses 33 (infrastructure), 38 (growth plans) and 60–65 (community rights) into a single, coherent framework.

  • Enhances equity by ensuring that even communities with low capital or limited professional expertise can access financial and technical tools to preserve their cultural fabric.

  • Builds civic pride and trust by embedding ownership, access and participation in the heart of the devolution settlement – demonstrating that the UK Government is serious about handing over powers that deliver for local people as much as for institutions.

Strengthen Accountability through Neighbourhood Provisions

Current Gap

At present, the Annual Devolution Report (Clause 19) contains no requirement to publish data or progress on cultural outcomes, and Clause 58, which establishes Neighbourhood Committees, offers wide discretion over remit and composition but no recognition of cultural or creative participation as part of local governance.

Without defined cultural metrics or channels for neighbourhood-level participation, the new regional tier risks appearing remote from the civic life it is meant to empower.

Research by Thinks Insight and Strategy commissioned by Culture Commons shows that residents often feel disconnected from sub-regional decision-making associated with our sectors, but that cultural activity is most valued when communities feel they can shape what is funded, how spaces are used, and how benefits are distributed.

Embedding cultural transparency and participation within the Bill’s accountability machinery would close this gap – making devolution visible, tangible and democratic in everyday civic life.

Policy Objective

To embed cultural participation, transparency and public oversight within the Bill’s accountability architecture by expanding Clause 19 (Annual Devolution Report) and Clause 58 (Neighbourhood Committees).

This amendment ensures that devolution is not only accountable upward to Parliament but also outward – as a a living contract with local people who can see and shape how cultural decisions are made, funded and evaluated.

By linking the new statutory competence for culture (A1–A2), the planning duties (B1–B2) and the participatory structures (C1–C2) to the Bill’s formal reporting and neighbourhood-governance mechanisms, this measure gives practical effect to the principle that devolution must include the public in its day-to-day operation, not just its design.

  • Amend Clause 19(3) so that the Secretary of State’s Annual Devolution Report must include a dedicated section on cultural devolution, drawing on shared data standards from the National Cultural Data Observatory (J1).

    This section should report headline indicators such as:

    • coverage and status of Cultural Ecosystem Plans (B1);

    • existence and composition of Culture Forums (C1);

    • distribution of devolved cultural investment (core vs competitive) and per-capita access;

    • participation and inclusion data, particularly for under-represented groups;

    • creative-workforce and freelancer metrics; and

    • assessment of regional disparities in cultural infrastructure and access.

    Embedding these metrics in the statutory report ensures that cultural devolution is measurable, comparable and reviewable on an annual basis, rather than anecdotal or symbolic.

  • Under Clause 58(4), require that regulations establishing Neighbourhood Committees include an explicit cultural-participation remit, ensuring that local people have a structured role in shaping and scrutinising key decisions.

    Neighbourhood Committees should:

    • enable participatory budgeting or advisory votes on local cultural programming, public-realm improvements and infrastructure priorities;

    • uphold minimum standards for accessibility and hybrid participation, ensuring that meetings are open, recorded and outcomes published;

    • create formal routes for public questions, petitions and recommendations on cultural issues; and

    • maintain a feedback loop connecting neighbourhood deliberations to the Cultural Ecosystem Plan (B1) and the reporting cycle under Clause 19.

    These provisions will make neighbourhood governance a working link between community voice, strategic planning and devolved accountability.

Intended Outcomes

  • Makes cultural decision-making visible, measurable and participatory within the devolved-governance system, aligning democratic practice with statutory duty.

  • Closes the accountability loop between planning (Clause 38), investment (Clause 33) and lived experience (Clause 58).

  • Empowers residents, freelancers and community groups to influence how cultural resources are designed, allocated and evaluated.

  • Establishes a consistent, nationally comparable framework for tracking cultural devolution outcomes through the Annual Devolution Report and National Cultural Data Observatory (J1).

  • Deepens civic trust by ensuring that devolution operates transparently, and that cultural participation becomes a core indicator of democratic health.

  • Delivers on the Bill’s founding ambition: a devolution settlement that empowers communities not only to manage local resources, but to co-author the meaning, identity and shared story of the places they call home.

Place Cultural Data, Evidence & Evaluation on a Statutory Footing

Current Gap

The Bill’s analytical core – Clauses 37 and 38 – requires Strategic Authorities to assess economic conditions and use those assessments in Local Growth Plans. Yet no equivalent duty exists for cultural, creative or heritage evidence. As a result, devolved decisions on investment, infrastructure and skills are made on partial insight, overlooking the contribution and needs of cultural ecosystems that drive regeneration and wellbeing.

Other provisions -such as Clauses 49–50 (pilot conferrals) and Clause 58 (Neighbourhood Committees) – present opportunities for evaluation and local accountability, but do not specify how cultural participation data should feed into those frameworks. Without a coherent, interoperable “data spine”, devolution risks producing well-intentioned plans without the evidence to back them up or measurable proof of progress over time.

Policy Objective

To create a shared, transparent and auditable evidence framework for cultural devolution – ensuring that decisions on culture, creativity and heritage, including those made within new mechanisms brought forward by our proposed amendments, are informed by robust data, consistent standards and public scrutiny at each tier of devolved governance.

While the Bill embeds strong analytical duties for economic assessment (Clauses 37–38), it does not establish equivalent provisions for cultural evidence. Without shared definitions, indicators and baselines, the creative, cultural and heritage sectors remain under-represented in local growth analysis, leaving the value of the ecosystem – including the GDP and non-monetary value generated by freelancers, micro-enterprises and community-led activity – invisible within devolved decision-making.

This amendment will place cultural data on an equal statutory footing with economic and spatial evidence – providing the backbone for the new cultural competence (A1), Local Cultural Ecosystem Plans (B1), participatory governance mechanisms (C2) and neighbourhood accountability (I1-I2). 

It will also support the development of a more joined up, multi-level data approach to cultural data – for example through the establishment of a National Cultural Data Observatory (J1) as a cost-effective, coordinated, government-endorsed mechanism to maintain standards and transparency without adding legislative complexity to sub-regional governments.

  • Amend Clauses 37 and 38 to require Strategic Authorities, when preparing or revising their Local Growth Plans and Cultural Ecosystem Plans(B1), to:

    • collect, publish and share data on cultural infrastructure, participation, workforce and investment flows using shared sub-regional indicators and common definitions;

    • coordinate data collection with constituent councils and relevant agencies to ensure interoperability with national frameworks; and

    • evaluate progress against agreed outcomes, including inclusion, wellbeing, productivity and regional equality.

    Empower the Secretary of State for MHCLG, working jointly with DCMS/DSIT, to issue statutory guidance setting out:

    • standard data typologies, indicators and evaluation methodologies; and

    • roles for coordination bodies such as the National Cultural Data Observatory (NCDO) - a government-endorsed, independent hub responsible for maintaining baselines, standards and open-access dashboards.

    Note: A consortium of partners, including the Centre for Cultural Value, The Audience Agency, My Cake and Culture Commons, has already developed a not-for-profit blueprint for a NCDO.

  • When exercising conferral powers or approving Cultural Devolution Pilots (E1) that will sit under Clauses 49–50, the Secretary of State (MHCLG) should require that each pilot includes:

    • data-sharing and evaluation protocols consistent with Clause 38 guidance;

    • commitments to feed anonymised pilot data into a national data and evidence base; and

    • an independent assessment of local impact, inclusion outcomes and governance effectiveness.

    This ensures that early cultural pilots generate comparative, publishable evidence to inform future national policy and scaling.

  • Use regulations under Clause 58(4) to require that Neighbourhood Committees - where established:

    • gather, publish and share cultural-participation and inclusion data derived from local engagement processes, consistent with Clause 38indicators; and

    • feed this data upward into the Strategic Authority’s evaluation framework and the Annual Devolution Report (Clause 19).

    This creates a full feedback loop between neighbourhood voice, regional strategy and national oversight.

Intended Outcomes

This proposal does not expand Clause 19 or introduce new central-government reporting burdens. Instead, it mirrors the existing statutory logic for economic data (Clauses 37–38) and extends it proportionately to the cultural data domain.

Guidance under Clause 38 should make use of outcomes from DCMS’s Measuring Culture and Heritage Capitals Programme and could validate a new National Cultural Data Observatory as the co-ordinating hub for shared standards.

  • Establishes a single, coherent evidence base for cultural devolution that is comparable, transparent and cost-efficient.

  • Delivers “data parity” – placing culture, creativity and heritage on an equal analytical footing with economic and spatial policy domains.

  • Integrates evaluation across the devolution cycle, embedding shared metrics in planning (Clauses 37–38), piloting (Clauses 49–50) and community accountability (Clause 58).

  • Supports equitable investment and levelling up by illuminating regional disparities in infrastructure, workforce and participation.

  • Enables Ministers, mayors and communities to plan and evaluate with confidence, informed by evidence rather than anecdote.

  • Transforms cultural devolution from aspiration to accountability, ensuring that progress can be measured, compared and celebrated across England.

  • Strengthens transparency and learning, allowing a National Cultural Data Observatory to function as a public-facing resource linking data to lived experience.