TAITMAIL. Post-Hodge ACE: slicker, clearer, fairer
By Jordan Mullineaux
Arts Council England’s 2028–33 National Portfolio Investment Programme has been published, following Margaret Hodge’s review which called for ACE to become less bureaucratic and prescriptive and to radically simplify its application and reporting requirements. There’s genuine simplification here.
The architecture of the old Let’s Create, with its three Outcomes and four Investment Principles, has gone from the application, replaced by a shorter and more direct test of an organisation’s previous work, future proposal, governance and management, and financial viability.
Excellence sits across all four with applicants explicitly asked to explain what excellence means in their own context rather than imitate an Arts Council definition. A huge shift, sure, but a simpler application is not necessarily a simpler investment process. ACE will assess fewer, broader questions while drawing on more external voices, more place-based intelligence and more explicit portfolio priorities. The writing may be simpler but the strategic judgement required will still be testing.
This will still be incredibly challenging for many organisations. The guidance repeatedly warns throughout that demand will significantly exceed the available budget : not every strong application will be funded. The scale of that competition should not be underestimated, with the last round attracting around 1,700 applications of which only 985 organisations, little more than half, got into the portfolio.
The headline changes
Perhaps most welcome change is the length of the investment period, running or five years (April 2028 to March 2033) instead of three, which should allow organisations to plan work, retain people, develop partnerships and make longer-term decisions with greater confidence.
But there is one somewhat unnerving caveat. The award does not amount to an unconditional five-year guarantee. Agreements remain subject to government and Arts Council policy and to the continued availability of funding, with ACE making it clear that previously agreed funding amounts may be reduced or withdrawn before the end of the investment period, so making good on any proposals will be key.
The application framework has also changed substantially. In 2022, applicants had to position their work against Let’s Create’s Outcomes and explain how they would embed the investment principles of ambition and quality, inclusivity and relevance, dynamism, and environmental responsibility.
The new round is shaped by ACE’s new Strategic Framework and its three objectives:
- Support Excellence
- Deliver for Everybody
- Reach Everywhere
Assessment itself is organised around four criteria:
- Previous work and development
- Proposed work and contribution
- Governance and management
- Financial viability
So, much simpler language giving organisations more space to describe themselves rather than as delivery vehicles for a set of funder-defined principles. Environmental responsibility, inclusion and organisational development have not disappeared, but they are no longer presented as four separate criteria. There is also no separate Investment Principles Support Organisation category. Organisations may deliver cultural activity directly to the public, strengthen the wider cultural sector, or do both; all successful applicants will be National Portfolio Organisations.
A stronger test of track record and organisational readiness
The new application looks backwards before it looks forwards. Applicants must evidence excellence in work delivered over the previous three years and show how they have learned, adapted and improved. This matters. A compelling five-year vision will not compensate for an unsupported track record, and a long history will not be enough unless the organisation can demonstrate learning.
The guidance describes strong applicants as organisations with a clear purpose, strong leadership and governance, sound financial management, meaningful public or sector benefit, realistic plans and the capacity to manage a long-term funding relationship. In other words, ACE is assessing investability as well as activity.
Practically, applicants need to begin with the evidence: gather evaluation, audience and participation data, partner testimony, workforce information, financial trends, evidence of board scrutiny and examples of decisions changed by learning – and don’t wait until drafting to discover whether the organisation can substantiate its claims.
Existing NPOs cannot simply bid for an uplift
One of the most consequential changes concerns existing organisations in the portfolio. These organisations will receive a planning figure, and their core proposal must be viable within it. The amount requested for that core proposal cannot exceed the figure provided. Any uplift must be requested separately as additional investment, and applicants will need to explain what the extra funding would add to what they are proposing.
ACE is unusually direct that it is unlikely to support most of these additional requests, which might be particularly trying for organisations that have already found themselves stretched within their existing NPO investment.
Existing NPOs should first design a credible five-year plan that works to the planning figure, then identify the distinct additional value an uplift would purchase. The uplift cannot quietly subsidise an unaffordable core plan. If the core proposal only works when the additional request is awarded, it is not a credible core proposal.
ACE has also published indicative funding data by organisational turnover. These figures are not recommendations, but they provide a useful reasonableness check. For organisations with turnover between £1 million and £5 million, for example, the median current award is £356,000 and the middle 50 per cent ranges from £190,000 to £612,000. This is more transparent than asking new applicants to “guesstimate” a figure.
Place and representation will influence the final portfolio
As ACE announced earlier this year, the programme has two stated priorities. The first is increasing opportunities for more people in more places, particularly in Culture Priority Places, with a focus on creating greater opportunities for children and young people in those places. The second is increasing investment in organisations whose leadership and governance better represent England’s population - ACE identifies disability, ethnicity and lower socio-economic background as particular areas of under-representation.
Not every organisation is expected to contribute equally to both priorities. The guidance explicitly accepts that some may contribute strongly to both, some to one, and others only to a limited extent. That is helpful and should discourage applicants from inventing weak projects simply to claim universal alignment. Nevertheless, the priorities will influence portfolio building, so applicants should be honest and precise about the contribution they can credibly make.
For the first time ACE will collect the views of more than 20,000 people, seek input from Mayoral Strategic Authorities and pilot 32 Regional Boards, bringing perspectives from health, education, housing, business, economic development and the voluntary sector. These inputs will not replace application assessment, but they will shape how ACE considers the overall portfolio. This means local relevance can no longer be asserted in generic language. Organisations should understand the needs, barriers and policy context of the places in which they work. National quality and local relevance are not opposites, but applicants will need evidence of both.
Assessment is clearer but competition remains collective
Applications will be assessed by panels of three ACE staff rather than a single assessor and all applicants will receive scores and comments to improve consistency and transparency.
Applicants should also note the limits of the Further Information Request process. ACE may seek clarification where information is contradictory, inconsistent or factually uncertain, normally allowing five working days to respond. It will not use the process to correct omissions, introduce new evidence or strengthen a weak case. If something is essential, it must be in the application when submitted.
Most importantly, a strong score will not secure funding on its own. ACE will move from assessment into portfolio building, considering the balance of places, communities, artforms, disciplines, organisational types, representation and affordability. The guidance states plainly that many strong applications will not be funded - this is public investment in a national ecology.
Other details applicants should notice
The £50,000 minimum annual request remains, with no published maximum, and the same amount must be requested in each of the five years. Organisations requesting £1m or more annually will also be asked whether part of their award could be treated as ongoing capital expenditure. This relates to eligible assets and building improvements, not major one-off capital projects, routine maintenance, staffing or reserves. ACE says the response will not affect the assessment of an application or its likelihood of receiving funding.
ACE now explicitly permits the use of generative AI in preparing applications, while placing responsibility for accuracy, quality and content firmly on the applicant. It says AI will not assess applications or make funding decisions, although it may support administration, analysis and verification. The advice is ultimately simple: use technology to interrogate, structure or test an application, but never outsource organisational judgement or submit language that colleagues and trustees cannot hear in their organisation’s own vernacular.
Finally, the guidance does not retain the former requirement for prospective applicants to arrange an introductory conversation before applying. Support, webinars and access assistance remain available, but responsibility for deciding whether NPO is the right path sits more squarely with the organisation.
Top tips for applicants
- Start with organisational truth, not ACE terminology. Agree your purpose, distinctiveness, organisational identity and long-term ambition before drafting answers.
- Build an evidence bank. Map every important claim to data, evaluation, feedback, financial evidence or a clear example from the last three years.
- Define excellence in your own context. Explain what excellent work and an excellent experience look like for the staff, practitioners, communities or organisations you serve.
- Work within the planning figure. Existing NPOs should produce a genuinely deliverable plan at their planning figure before constructing any additional investment case.
- Treat governance as evidence, not reassurance. Show how the board oversees risk, finances, safeguarding, representation and organisational learning.
- Know your place. Know and engage with your communities. Use local evidence and relationships to demonstrate relevance. Organisations shouldn’t claim to provide place-based work or simply name-check a local authority relationship without showing what they contribute to those communities.
- Write for the panel. Assume that at least some ACE assessors will not know your organisation, creative work or local context. Plain and simple language can go a long way when writing for the panel.
- Don’t treat the character limit as a target. Character limits are often too short, but in this case they seem reasonable. Follow the guidance, which repeatedly asks for direct, proportionate answers. More words do not create more evidence.
The key takeaway
This is a better application framework than the one it replaces. It is shorter, clearer and less dependent on applicants reproducing the language of a ten-year strategy. The recognition that excellence is contextual and that different organisations will contribute differently to national priorities is a welcome change.
With that in mind, it would be a mistake to see these simplifications as reduced scrutiny. The new process places greater emphasis on organisational readiness, learning, governance, financial credibility and demonstrable benefit. Your organisation may demonstrate excellence and investability but still not be the investment ACE believes the overall portfolio most needs in the national ecology.
The form is new. The strongest advice, however, is pretty old school: know the organisation you are asking the public to invest in.
Jordan Mullineaux is a theatre development professional and arts and culture consultant.