Introduction of the CIISA Standards: what they mean for creative industry compliance
Following an industry consultation at the end of 2024, The Creative Industries Independent Standards Authority (CIISA) recently launched “The CIISA Standards”. This sets out minimum standards expected of individuals and organisations within the UK’s creative industries of film, music, TV and theatre. They are designed to address bullying, harassment, and discrimination.
CIISA was established in 2024, following a series of media stories focussing on a number of serious allegations of misconduct within these industries, such as those relating to Russell Brand. Whilst CIISA is not a statutory regulator of professionals in this industry, it has deep and wide support across the creative sector for its initiatives. Whilst organisations in the creative industries are not classified as members of CIISA, it sets standards for both individuals and organisations across the creative sector. In line with its founding aim of upholding and improving conduct and behaviour across the creative industries, CIISA has prepared “The CIISA Standards”.
These four Standards are designed to ensure safe, inclusive and respectful working environments. Each of the Standards requires participation at every level, regardless of an individual’s role or seniority.
The CIISA Standards: an overview
- Safe Working Environments
All individuals should understand what a safe working environment looks like and should act within those boundaries. However, it is also the responsibility of senior leaders and managers to set the tone and culture of organisations whereby the welfare of the whole workforce is protected and respected. This includes taking measures to address harassment, bullying and discrimination.
- Inclusive Working Environments
Regardless of their role or status, all members of a workforce should know what qualifies as discriminatory, harassing or otherwise inappropriate behaviour. It is the responsibility of more senior staff to promote cultures of inclusivity by treating everyone fairly, finding value in people’s differences, and thereby enabling all staff to thrive.
- Open and Accountable Reporting Mechanisms
All members of staff should know that they are able to report inappropriate or harmful behaviour to the organisation that contracted them whenever possible. Senior leaders and managers should empower their workforce to raise concerns in a safe manner (anonymised if requested) and should recognise their own accountability, thereby fostering a culture of speaking up.
- Responsive Learning Culture
To achieve a responsive learning culture, all individuals should be able to provide and receive feedback around any experiences of harmful behaviour and, if appropriate, should understand how this will contribute to positive changes in the future. Senior individuals must ensure that action is taken to learn from raised concerns and their impact.
Background and implementation
These Standards have been developed in consultation with the creative industries and the consultation responses gave the proposals a highly positive reception. There is no doubt that this is positive step from CIISA in the improvement of these behaviours in the creative industries. Before the work of CIISA, there were no universally accepted benchmarks for acceptable behaviour. Naturally, this resulted in inconsistent approaches to address misconduct. A single, unified approach across the creative industries will therefore go some way to addressing this.
However, one theme arising from the consultation responses was about the implementation and enforcement of these standards. One trade union commented that “[t]he standards are rigorous but prevention depends on those who need to engage most acknowledging and adopting the standards.” A similar concern arose from a membership body, who noted that “[t]he devil is going to be in the rolling out and implementation and consistent communication.” Notably, CIISA is not a regulator and so has no regulatory-type powers of enforcement. As there is no statutory regulation of this industry as a whole, there is also no direct duty, in a legal sense, on industry members to be compliant with the Standards.
CIISA’s report that accompanies the Standards explains that it will endeavour to produce tailored guidance on how to adhere to the Standards. However, the everyday regulation and enforcement of the Standards will fall to those in the creative industries themselves. As opposed to any discrete enforcement mechanism, what is relied upon by CIISA is the broad approval of CIISA and the Standards by the creative industries and, with that, the reputational threat to industry members of poor adherence to the Standards. In time, CIISA’s report notes that it will explore options around accreditation and introducing services aimed at resolving concerns over lack of adherence.
CIISA will also provide an independent reporting mechanism for organisations and individuals to report concerns relevant to the Standards. From these reports, CIISA will capture insights to develop a picture of how the creative industries are embedding the Standards within their cultures. It is hoped that this will also provide some insight into whether a non-legal duty is enough to reset the culture in the creative industries.
What should organisations do to prepare?
Organisations, productions and projects within the creative industries should assess their existing policies and procedures against the CIISA Standards to ensure that they are sufficiently compliant, and that all staff understand what is expected of them. CIISA has designed the Standards so that they are relatively straightforward and have released guidance on implementation. However, as these Standards are the first of their kind, many in the creative industries will have entrenched informal practices, meaning that shifting to a formal style of compliance could require something of a cultural change. Another challenge for setting new policies for organisations is how they will apply to what can be a diverse workforce, including freelancers, contractors, and self-employed individuals, in addition to regular employees. For those bodies which are also registered charities, these new Standards will need to be developed alongside any existing policies in place, and to be fully integrated within and alongside current or improved governance models.
The CIISA Standards set a new, unified benchmark for professionalism, inclusivity, and accountability in the creative industries. If your organisation operates in film, television, theatre, or music, now is the time to assess your policies and ensure alignment with this framework. Stone King’s Public Law and Regulatory Team and our Charities Team can assist you with navigating these changes and implementing the Standards effectively. For more information, see https://ciisa.org.uk/ or please contact Melanie Carter, Partner and Head of our Public Law and Regulatory Team, or Frances Godden, Senior Associate and co-lead of our arts, culture and heritage sub-sector focus within our Charities Team.