Scotland and Wales devolved policy for UGC campaigns

What to take away

Scottish policy: place, fair work and Gaelic in public sector UGC briefs

The Scottish Government treats creative industries as part of its wider economic strategy, not as a standalone arts budget. That matters because UGC campaigns funded through public bodies inherit the same policy aims, such as fair work, place-based growth and talent retention.

A brief for a tourism or health campaign in Scotland will often ask for Scottish-based creators before it asks for follower counts.

The Creative industries, talent and engagement page on gov.scot, alongside the National Strategy for Economic Transformation (2022), sits behind many of those briefs. It links screen, design and digital content to jobs and investment, so a UGC budget has to show how it supports those outcomes. A campaign that cannot explain its contribution struggles at the approval stage.

That policy reach is visible in the topics index that public bodies use to align spending with ministerial priorities. The Topics index on gov.scot is the reference point programme managers use when they justify a UGC budget to finance teams.

Place is a common condition. UGC shot in Glasgow, Dundee or the Highlands may be required to show a specific location, not a generic UK street. Creators who can evidence a Scottish postcode and local crew have an advantage in framework mini-competitions. Those without a Scottish base can still bid, but they usually need a named local partner.

Language and accessibility conditions also appear. Gaelic and Scots are not mandatory in every brief, but campaigns aimed at island or Highland audiences may ask for subtitling or dual-language variants. The Gaelic Language (Scotland) Act 2005 provides the statutory framework for Gaelic, and Bòrd na Gàidhlig promotes its use; public authorities may also have Gaelic language plans. Check the brief and relevant plan before pricing Gaelic versions.

Fair work criteria are the other Scottish signature. The Scottish Government's Fair Work First policy sets fair-work criteria for organisations receiving public sector funding, and buyers may ask suppliers to confirm payment terms, freelancer rates and working practices. For UGC suppliers, that means invoices and contributor agreements may be reviewed as part of the award, not just the creative treatment.

All of this sits on top of the UK-wide rules that already govern marketplace work. Scottish policy adds a layer of public purpose to those baseline checks.

Welsh policy: wellbeing, bilingual delivery and local supply in UGC procurement

The Welsh Government frames creative industries around wellbeing under the Well-being of Future Generations (Wales) Act 2015, culture and the Welsh language. That framing flows into campaign procurement through the questions buyers ask.

A UGC tender for a Welsh public body is likely to ask how the work supports community wellbeing or increases Welsh-language content, even when the campaign is about waste recycling or flu vaccination.

The Written Statement: Creative industries published by the Welsh Government, alongside the Programme for Government 2021 to 2026, shows how that link is made. It ties the sector to economic recovery and cultural identity, which is the language procurement officers reuse in social value questions.

Welsh-language delivery can be required, but not every campaign is automatically bilingual. The Welsh Language (Wales) Measure 2011 provides the basis for Welsh Language Standards; standards imposed on a public body can require Welsh-language communications and services. The Welsh Language Commissioner oversees compliance with standards, so check the body's applicable standards and brief to establish whether a UGC asset needs a Welsh-language version.

A typical bilingual version adds 15 to 25 per cent to the cost of each asset, depending on scripting and voiceover. Creators who can shoot and edit both versions without a separate translation budget are more competitive.

Local supply chains matter too. Welsh public bodies face pressure to spend within Wales, so they favour suppliers who can name Welsh-based creators, editors or studios. A London agency can win, but it usually needs a credible Welsh production partner in the bid.

Policy statements from the Welsh Government also signal which sectors get campaign money. When creative industries are linked to tourism, health or the economy, UGC briefs follow. A heritage campaign in north Wales may be funded because it supports both tourism and language goals, which makes the brief broader than a simple reach target.

Approval routes reflect the same priorities. Campaigns with a language element may need sign-off from a Welsh language officer as well as a communications lead. That adds a step to the timetable and a reason for rejection if the Welsh copy is an afterthought.

Procurement, approvals and supplier terms in devolved public body campaigns

Public sector marketing procurement in Scotland and Wales runs through named framework agreements. In Scotland, buyers use the Scottish Government Marketing Services framework; regulated procurement is governed by the Procurement Reform (Scotland) Act 2014 and the Public Contracts (Scotland) Regulations 2015. In Wales, buyers use the National Procurement Service (NPS) marketing and communications frameworks, alongside the Procurement Act 2023. Framework terms sit alongside, not replace, the applicable statutory rules.

Below the relevant threshold, buyers can make a direct award. In Scotland, regulated procurement for goods and services starts at £50,000. Many public bodies set direct award limits below £25,000. In Wales, NPS frameworks cover below-threshold buys, with direct awards commonly around £25,000. Above those limits, buyers run a mini-competition or open tender.

The route determines how much paperwork a UGC supplier faces. A mini-competition under a framework is faster than an open tender, but it still requires a written method statement and priced schedule.

Approvals are the part that catches creators out. A typical devolved campaign has four gates: budget approval, creative approval, legal and brand clearance, and publication sign-off. Each gate can send the work back, and each has its own owner.

Each gate can add one to three weeks, so a four-gate campaign often runs six to ten weeks behind a private sector equivalent. A change of minister, or a new policy priority, can pause a campaign after the shoot.

Worked example: a devolved UGC brief

This illustrative brief is for a Scottish health campaign.

The figures are typical ranges, not a real tender.

Supplier terms in devolved contracts tend to be stricter than private sector norms. Copyright is usually assigned to the public body, moral rights are waived, and the body claims the right to sub-licence the content to partner organisations. Payment is often on acceptance, not on delivery, which stretches cash flow for small studios.

Creators should also expect clauses on data protection, accessibility and record keeping. A public body may require captions, audio description and alt text as standard. It may also require the supplier to hold contributor consent forms for a set period, because those records can be requested later.

Insurance and financial standing are checked more often in devolved procurement than in private work. Public liability cover, professional indemnity and, for some campaigns, enhanced disclosure checks for creators working with children or vulnerable adults are common conditions.

When terms are unclear, review the contract clauses on rights, delivery, payment and termination. Knowing how each clause affects the campaign makes negotiation faster and reduces the risk of signing away more than the campaign needs.

Steps to prepare a bid for a devolved public body

FOI transparency duties that apply to publicly funded UGC

The Freedom of Information Act 2000 gives anyone the right to request recorded information held by public authorities in England, Wales and Northern Ireland. In Scotland, the Freedom of Information (Scotland) Act 2002 applies to Scottish public authorities.

For UGC campaigns, that means the brief, the tender documents, the winning bid, the invoices and the final assets can all be requested.

Creators often assume their creative treatment is commercially confidential. It may be, but the exemption is not automatic. A public body must test whether disclosure would harm commercial interests, and it must weigh that against the public interest in transparency. In practice, many campaign documents are released with only minor redactions.

That has three consequences for suppliers. First, write every document as if it will be published, because it may be. Second, keep contributor consent records in a form you can hand over, since personal data still needs protection under data protection law. Third, expect questions about how public money was spent, including creator fees and paid media budgets.

Public bodies also publish transparency data proactively, such as spend over a threshold and contract award notices. A UGC campaign funded through a devolved programme will usually appear in those returns. Suppliers who understand this can use the same data to find future opportunities.

FOI requests can arrive months after a campaign ends. If your records are scattered across email, chat and personal drives, responding becomes expensive. A simple project folder with briefs, consents, invoices and final files is enough to stay compliant.

What changes for creators pitching to Scottish and Welsh public bodies

The pitch itself changes. Devolved buyers score social value, language and place alongside creative quality. A reel of high-performing brand work is useful, but it will not answer the question of how your content supports a Scottish or Welsh policy aim.

Evidence of reach should be specific. Public bodies want to see how UGC performed for a comparable audience, not just total views. Screenshots of analytics, with dates and platforms, are more persuasive than a showreel.

Pricing should reflect the extra work. Bilingual versions, accessibility features, longer approval cycles and records retention all add cost. A quote built on private sector assumptions will either lose money or fail at the quality threshold.

Relationships matter more than in England. Framework managers in Scotland and Wales often reuse suppliers who understand their approval culture. Attending supplier events and responding to early market engagement is a low-cost way to become known.

Finally, plan for the rights to release. A public body may want to reuse your UGC in future campaigns, on its own channels and in partner communications. If your contributor agreements do not cover that, the campaign can stall at the final gate. Clear, written permissions from every person featured are the simplest protection.

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Common questions