Chapter 3: Ending free movement: implications for the cultural sector
The UK cultural sector
20.The cultural sector in the UK is estimated to have contributed £27 billion GVA (Gross Value Added) to the UK economy in 2015, the last year for which comprehensive figures are available.25 According to DCMS, the UK cultural sector employs around 654,000 people, accounting for 2% of all jobs in the UK. Of these, DCMS estimates that 47.6% are self-employed. In written evidence, the Department noted that EU citizens made up 4.6% of workers in the cultural sector, including both employed and self-employed workers.26
21.However, the Creative Industries Federation argued that the DCMS figures provided “nowhere near enough detail” about the importance of EU citizens to the cultural sector, highlighting “massive variation” within sub-sectors that rely on much higher levels of EU citizens: “A survey of the visual effects industry by UK Screen Alliance, for example, found that 33% of its workers were from the EU.”27
Box 3: Definition of the UK cultural sector
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DCMS issues estimates measuring the economic contribution of sectors under their remit, including culture. The Department defines the cultural sector as “those industries with a cultural object at the centre of the industry”. The line between the broader creative industries sector, and the cultural sector, is not always clear-cut; and even within the DCMS definitions there is some cross-over. For example, certain sub-sectors, such as film and television, overlap between the creative and cultural sectors. The sub-sectors that the Government uses in its estimates of the size of the cultural sector are the arts, including the performing arts and the operation of arts facilities; film, television and music; radio; photography; crafts (including the manufacture of jewellery); museums and galleries; libraries and archives; cultural education; and heritage. |
Source: Department for Digital, Culture, Media and Sport, DCMS Sectors Economic Estimates 2017: Employment and Trade (26 July 2017, revised 16 August 2017): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/640628/DCMS_Sectors_Economic_Estimates_2017_Employment_and_Trade.pdf [accessed 19 July 2018] and Department for Digital, Culture, Media and Sport, DCMS Sector Economic Estimates: Methodology (18th July 2018): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/725926/DCMS_Sectors_Economic_Estimates_-_Methodology.pdf [accessed 24 July 2018]
22.Other witnesses provided a breakdown of various sub-sectors. UK Music and the Musicians’ Union told us that there were 142,208 people employed in the UK music industry, of which around 44% were self-employed.28 UK Music’s 2016 Diversity Study found that 10% of people employed in the UK music industry held a passport from a non-UK EU Member State.29
23.A survey of 992 stakeholders from the cultural sector published by Arts Council England in February 2017 showed that of all the cultural sector sub-sectors, dance organisations were among the most likely to employ EU27 citizens.30 Andrew Hurst from One Dance UK reported that around 40,000 people worked in the UK dance sector. The average proportion of EU27 citizens was “about 20 per cent”, while “some smaller companies have much higher proportions of EU nationals working with them”.31
24.The UK’s film and television industry contributed £7.7 billion to the UK economy in 2016.32 The Commercial Broadcasters Association (COBA) reported that the UK was also “home to more television channels than any other EU country”, most of which were international channels operating from the UK, but transmitting to overseas markets. We heard that 15% of the workforce of such channels were EU27 citizens.33
25.The National Museum Directors’ Council (NMDC) and the Museums Association noted that EU27 citizens accounted for “up to 15 per cent of the workforce in some large national museums”, and that national and large museums were more likely to employ a larger proportion of EU27 citizens than “small, rural and independent museums”.34 According to Historic England’s estimates, approximately 8%, or 10,800, workers in the heritage sector were third country nationals, with the “heritage construction sectors, archaeological occupations and heritage tourism sectors being particularly reliant on EU27 nationals”.35 Historic England reported that almost 10% of the tourism workforce worked in heritage tourism, and that “heritage visitor attractions” were “reliant” on staff from the EU27.36
26.Many witnesses emphasised how the cultural sector benefited local communities. The Musicians’ Union and Association of British Orchestras highlighted their members’ community work “in hospitals, care homes and prisons”, as well as their outreach programmes, including performances for children and young people.37 Witnesses underlined the value of the UK’s cultural sector in promoting the UK abroad.38 For the NMDC and Museums Association, the result was “an impact beyond the UK and … a major role in promoting Britain internationally, encouraging tourism and contributing to the UK’s soft power”.39
27.Witnesses’ overwhelming sentiment was that ending free movement would have a negative impact on the cultural sector.40 The NMDC and Museums Association told us that restricting access to EU27 cultural sector workers would “undermine [the] competitiveness, attractiveness and success of the UK’s museums”.41 Arts Council Wales/Wales Arts International were concerned that ending free movement would diminish opportunities to exchange ideas, while the Drawing Room, a charity providing free public drawing exhibitions, believed that it would jeopardise its ability to bring artists from the EU to the UK.42
Ending free movement: access to skills
28.In her 2 March Mansion House speech, the Prime Minister, the Rt Hon Theresa May MP, set out a broad principle for a future immigration system: “The UK must be able to attract and employ the people it needs.”43 Nevertheless, many witnesses were concerned about the impact that ending free movement would have on the cultural sector’s ability to access skilled labour. Art Fund told us that changes could “undermine the ability of UK museums to attract and retain skilled” EU citizens.44 COBA said that the “future success” of the broadcasting sector depended on developing an immigration system that reflected the skills needs of their sector.45 Arts Council Wales/Wales Arts International felt that the curtailment of free movement would lead to “a substantial loss of important skills”.46
29.We heard from heritage sector witnesses that skills shortages would be exacerbated by Brexit at a time of increased demand for skilled labour. The Heritage Alliance pointed out that demand for “heritage skills” was about to increase because of “large heritage and infrastructure projects” such as HS2, and the restorations of Buckingham Palace and the Palace of Westminster.47 Historic England feared that any restrictions on EU citizens’ free movement could mean that fewer academics came to the UK, which would weaken the UK’s position as a leader in heritage research:
“Much heritage research in England has been built around the model of the free movement of academics within the European Union … The flow is in both directions as UK researchers often take up positions within universities in EU countries. This has allowed the UK to play a prominent role in heritage research in Europe.”48
30.The NMDC and Museums Association were also concerned that an inability to attract skills from the EU could “threaten the international status of the UK’s world-class institutions”.49
31.In contrast, Historic England and the Heritage Alliance saw a possible upside: restrictions on free movement could provide a “stimulus to expand training and development” in heritage skills in the UK.50 For Fiona Biddulph, a postgraduate in Ballet Studies at the University of Roehampton, it was “a fallacy to suggest that protecting British graduates would prevent British [ballet] companies from being globally competitive”.51 She argued that ballet schools in the UK produced highly trained British dancers who were “displaced by EU and international students”; ending free movement from the EU could therefore provide an opportunity to invest in homegrown talent.52
Movement with a job offer—a viable option for the cultural sector?
32.There are three principal work visas currently used by third country cultural sector workers to enter the UK (see Box 4). These are:
(a)temporary workers—Tier 5 (creative and sporting);
(b)exceptional talent—Tier 1; and
(c)skilled workers—Tier 2 (general).
Box 4: Current UK visas for third country cultural workers
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Tier 5 is for paid temporary work for up to 12 months, and requires a UK sponsor. It is designed for people such as actors or touring musicians who come to the UK from outside the EU on short-term contracts or for short-term engagements. To act as a sponsor, a UK business must obtain a sponsor licence.53 The Government told us that it had “worked closely with the creative and cultural sector to develop specific Codes of Practice for organisations and individuals using the Tier 5 (temporary worker—creative and sporting) visa for non-EU workers, which reflect the unique working needs and patterns” of these sectors.54 Tier 1 is for individuals who are recognised as world leaders, or have demonstrated the potential to become world leaders, in the fields of science, engineering, humanities and the arts. Applications for this route need the endorsement of a designated ‘Competent Body’, a cultural sector organisation selected by the Home Office to assess visa applications.55 The Tier 2 (general) route allows UK employers to bring third country nationals to fill specific jobs. Tier 2 (general) visas are capped at 20,700 annually and subject to pay thresholds. The Tier 2 (general) system provides two pathways to a visa: the resident labour market test (RLMT) and the shortage occupation list (SOL). Jobs offered under the RLMT must first show that there is no suitable resident worker available, with the job being advertised to resident workers for a set period. The job must also meet a minimum skill requirement and an annual salary threshold (with effect from April 2017, £30,000).56 Jobs on the SOL are exempt from requirements to meet the RLMT, and are subject to salary thresholds specific to each job (which can be lower than the RLMT threshold). There are 17 roles in the creative industries on the shortage occupation list, including dancers, choreographers, and musicians.57 |
33.Witnesses were apprehensive about introducing movement with a job offer along the lines of the system that currently exists for third country nationals. The Creative Industries Federation told us that movement with a job offer would be “highly problematic” and “intolerable … [for] small and medium-sized enterprises” operating in the cultural sector.58 Mr Hurst and Arts Council Wales/Wales Arts International agreed that restrictions on free movement would hit smaller organisations the hardest.59
34.The City of London Corporation, which funds the Guildhall School of Music and Drama, the Barbican Centre, and Guildhall Art Gallery, considered the current non-EU visa regime to be “unsuitable” for the cultural sector: “Quotas … for the creative sector would lead to uncertainty [and] place additional administrative burdens on arts organisations.”60 Mark Pemberton, Director of the Association of British Orchestras, described Tier 2 and Tier 5 visas as “clunky”.61 The Drawing Room said that future restrictions on EU citizens similar to the Tier 1 and Tier 2 systems would have a “stymying effect” on the ability to recruit “new, bright, early-career talent”.62
35.Many witnesses were concerned about the salary threshold that forms part of the eligibility criteria for entering the UK via the Tier 2 route. Salary thresholds are used as a marker to distinguish between “high-skilled” and “low-skilled” workers. We heard that this distinction was challenging: many highly skilled people employed in the cultural sector are not paid enough to reach the threshold.63 Arts Council Wales/Wales Arts International wrote: “High levels of technical skill do not always translate into high salaries. The current Home Office requirement that third country nationals meet a minimum salary threshold for certain types of visa would be problematic.”64 Heritage England said: “Income thresholds for visas applied to workers from non-UK EU countries will have adverse impacts on the heritage sector. While many heritage sectors employ highly skilled workers, many are low-paid sectors with wages below [the] national median.”65
36.The City of London Corporation suggested that it would be difficult to recruit for roles that did not meet the salary threshold.66 Mr Pemberton believed that there was a misunderstanding in Government about the mismatch between skill level and pay:
“Some orchestras provide permanent employment, and they are recruiting permanent salaried musicians … That has its own problems now in relation to the increased salary threshold. Now it has to be £30,000. Unfortunately … musicians starting out in a career in an orchestra are not earning £30,000 a year. We are highly skilled but not highly paid. Sometimes, the people at the Home Office do not understand that. They assume that high skills equals high pay, and it does not in the creative sector.”67
Self-employed workers
37.Evidence from the Creative Industries Federation and the Heritage Alliance suggested that, post-Brexit, movement with a job offer would be less relevant for the cultural sector than provisions relating to self-employed workers. The sector relies heavily on consultants and freelance workers working on a project basis, or working on multiple projects at one time—people who would not usually enter the UK with a prior formal job offer.68
Box 5: Self-employment and the Citizens’ Rights Directive
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The 2004 Citizens’ Rights Directive codified a right of residence for up to three months in other EU Member States. The right of residence beyond three months is open to EU citizens who are employed or self-employed, self-sufficient, or students with sufficient resources and sickness insurance cover. 69 Individuals taking advantage of these provisions are referred to as “exercising treaty rights”. According to the Citizens’ Directive, self-employed EU citizens can work and travel within the EU without restrictions while they are exercising their treaty rights. Third country nationals, on the other hand, are subject both to EU rules on migration where applicable, or to the domestic immigration laws of individual Member States where no EU legislation exists.70 |
38.Witnesses saw post-Brexit arrangements for self-employed persons as a high priority, and the ability to move between the UK and EU27 at short notice as integral to the business model of many cultural sector organisations. The Creative Industries Federation told us that industries relied on a “rapid turnaround” to access talent, often on a “same-day” basis.71 The NMDC and Museums Association highlighted specialist conservators as “a good example” of the type of freelance workers hired to work in UK museums on a project basis.72 COBA reported that broadcasting and television productions in the UK needed to “appoint [talent] quickly”, requiring people to move either from the EU27 to the UK, or vice versa, to meet production schedules.73 Mr Hurst and Mr Pemberton said that it was essential to be able to bring in talent at short notice, particularly in the event of emergencies such as a lead singer or dancer falling ill or sustaining an injury.74
Permitted paid engagement and permit-free festivals
39.In the absence of a clear steer from Government about movement between the UK and EU post-Brexit, witnesses considered whether existing short-term entry routes for third country nationals might apply to EU citizens. There are currently two ‘visit’ routes for third country nationals seeking to enter the UK to take up short-term employment as artists and entertainers. These are visit (standard) and visit (permitted paid engagement) visas, which are of particular benefit to self-employed individuals.
40.The visit (standard) route allows individuals to carry out certain permitted activities. These include: giving performances as individuals or as part of a group; taking part in competitions or auditions; making personal appearances; undertaking promotional activities; attending workshops and giving talks; and appearing at one or more cultural events or festivals on the list of permit-free festivals.75
41.The visit (permitted paid engagement) (PPE) route allows professionals over the age of 18 to stay in the UK for up to one month to undertake specific paid engagements. This visa allows professional artists and entertainers who are invited to the UK to carry out one permitted engagement, or a short series of engagements, relating to their profession. It is a single-entry permission only. It extends to the performing and creative arts and includes musicians, visual artists, make-up artists, and writers.76
42.Witnesses from the dance and music sectors saw an opportunity to improve the PPE route post-Brexit, to make it more flexible for the needs of the cultural sector. Mr Pemberton told us that in its current form, PPE was “too restrictive” for artists who had not yet made a name for themselves.77 He suggested that the PPE route could be extended post-Brexit to include EU27 citizens.78 UK Music and the Musicians’ Union agreed that solutions might be based on the PPE route.79
43.Some witnesses saw an opportunity to extend the permit-free festival scheme to EU citizens post-Brexit. This allows an artist, entertainer or musician visiting the UK to perform at certain UK festivals without obtaining a work permit. Arts Council Wales/Wales Arts International sought “a review of the options around the permit-free festivals model and intermediary bodies providing certificates of sponsorship”.80 Mr Pemberton said:
“At the moment, there is a work-permit-free festival system, so that the Proms and the Edinburgh Festival, which have this endorsement process, can bring in ensembles from outside the EEA, because they are trusted through that permit-free status. An extension of that across a range of employers would make the difference.”81
Touring in the EU27 post-Brexit
44.Witnesses told us that short-term touring was essential to the business model of many self-employed artists, and that EU27 countries were their principal destinations.82 Mr Pemberton said that some freelance orchestral musicians who worked regularly for a UK orchestra, but lived in the EU27, would go “in and out [of the UK] to do 50 concerts a year”.83 For Horace Trubridge of the Musicians’ Union, if musicians had to get visas for each Member State while on tour, tours “would basically [be] impossible to schedule”.84 Witnesses such as Arts Council Wales/Wales Arts International were concerned about the potential increased costs of touring post-Brexit, particularly for smaller arts companies:
“Any reinstatement of mobility restrictions … will create new borders for our large-scale arts organisations. But whilst these companies will certainly find such impediments inconvenient, for the smaller-scale companies and artists such barriers might become insurmountable. Arts organisations operating on very lean budgets with limited financial flexibility may find themselves unable to cushion or manage the effects of regulation of movement.”85
45.The BFI argued that restrictions on free movement for “freelance professionals” could lead to a “significant” loss of inward investment for British film and television, raising costs for the British independent film sector.86
Posted workers
46.A posted worker is an employee who is sent by their employer to carry out a service in another Member State on a temporary basis.87 The Posted Workers Directive sets out terms and conditions of employment for posted workers. Posted workers are subject to the law of the Member State that they are posted to, but the Directive identifies a set of core rights that they must be granted. These include minimum rates of pay; maximum work periods and minimum rest periods; minimum paid annual leave; conditions for hiring through temporary work agencies; health, safety and hygiene at work; and equal treatment.88
47.Posted workers’ social security provision is also regulated at EU level.89 Posted workers or persons active in two or more Member States pay social contributions in the Member State in which they are regularly employed, and do not fall under the social security scheme of the Member State in which they are temporarily employed.90
48.The primary concern of those witnesses who discussed posted worker provisions was with future social security coordination. Mr Pemberton told us that the loss of the Posted Workers Directive provisions on social security would “cause substantial damage”, making touring “too expensive” for orchestras and similar outfits, should their members need to pay social security in other EU countries when on tour.91 The Incorporated Society for Musicians (ISM) desired that social security arrangements “be negotiated to enable UK musicians to continue to travel across the EU”.92
Multiple-entry visas
49.An EU-wide multi-entry, short-term visa was mooted by several of our witnesses as a possible option for facilitating touring after Brexit. Mr Hurst suggested that this could be a “no-cost or low-cost, long-duration, multiple-entry” visa.93 UK Music and the Musicians’ Union suggested that it could be based on the EU Blue Card,94 which allows high-skilled non-EU citizens to work and live in any EU country.95 The Creative Industries Federation and the British Film Institute also supported the idea of a visa system that permitted short-term visits to multiple EU countries, without needing a separate entry permission for each one.96
50.For the EU negotiators to consider such a scheme, the Government will need to make a reciprocal offer. Given the importance for the cultural sector of short-term travel between the UK and the EU27, there was concern from witnesses that failure to obtain a reciprocal deal on movement of people, particularly for the self-employed and individuals carrying out short-term work, could damage the cultural sector. UK Music and the Musicians’ Union also described reciprocity as a “major concern”, highlighting a risk that any restrictions applied by the UK could be reciprocated by EU Member States.97 The Creative Industries Federation thought that should the UK fail to reach a deal with the EU on migration, the UK should offer unilaterally “the best possible access to EU talent”.98
Conclusions
51.Individuals working in the UK cultural sector are highly mobile, and have thrived on collaboration with people from all over the world. Moreover, the country benefits enormously from the sector’s contribution to its economy and society. The sector also makes an important contribution to the UK’s international image and influence.
52.We did not hear conclusive evidence that free movement from the EU27 had led employers to neglect the training and development of UK cultural sector workers. Brexit nevertheless gives employers an opportunity to review training and development pathways for UK citizens wishing to enter the cultural sector, or to move up the skills ladder.
53.Arrangements for EU27 workers post-Brexit will either take the form of a preferential system for EU citizens, or EU27 workers will face the same restrictions as third country nationals. We reaffirm that the Government should “pursue preferential arrangements for UK-EU migration after the UK has ceased to be a member of the EU”, but we underline that whatever the final shape of the UK’s future immigration system, it will need to take account of the cultural sector’s suggestion that self-employed artists and entertainers be permitted to enter the UK for short-term engagements. To this end, the Government should explore whether it could extend the existing permitted paid engagement and permit-free festival arrangements to EU citizens post-Brexit.
54.The recently published White Paper acknowledges that “the UK and the EU will … need provisions that allow for mobility” to facilitate the proposed “cooperative accord” with the EU on culture and education. Yet it is unclear how this accord would relate to wider immigration policy, or the existing visa system. Given the cultural sector’s concerns about how it will be affected by any agreement with the EU on migration, the Government should urgently provide more detail on this proposal.
55.We are pleased that the Government has made a commitment in the White Paper to “support businesses to provide services and to move their talented people” post-Brexit. But because the Tier 2 visa currently admits only those cultural sector workers who are leaders in their fields, we share the concerns of some of our witnesses that it has had a negative effect on the sector’s ability to bring talent to the UK. If the Government’s intention is to extend this route to EU27 citizens, it should carry out a full assessment of any possible impacts.
56.If the Government is to achieve its wish to establish an immigration system that meets the needs of the post-Brexit economy, the UK’s negotiators will need to be flexible. This means recognising that any restrictions on EU citizens wishing to enter the UK to work may be matched by reciprocal restrictions on UK workers in the EU.
57.Many people working in the UK cultural sector rely on their freedom, as EU citizens, to carry out short-term work in other EU countries. One of the primary aims of EU social security coordination is to support this freedom of movement. We therefore support the Government’s aim, set out in the White Paper, that “workers [will] only pay social security contributions in one state at a time”.
58.To encourage the EU to reciprocate, the Government should guarantee that EU citizens travelling on short-term contracts to the UK after the transition period will not pay into its social security system. Failure to secure a reciprocal commitment on social security would undermine any broader agreement on migration between the UK and EU.
59.The Government should also seek a commitment for an EU-wide multi-country, multi-entry short-term ‘touring visa’ for UK citizens, and offer a reciprocal commitment for EU citizens. This would enable self-employed persons to travel for short-term visits between the UK and the EU, recognising the two-way benefits that accrue from allowing artists, entertainers and other cultural sector workers to move freely between the UK and EU to tour and work on short-term contracts.
60.Without effective reciprocal arrangements, the UK may see a decline in skilled cultural sector workers entering the UK from the EU. Such a development would be to the detriment of the UK cultural sector, and represent a significant loss to the audiences that enjoy seeing talent from across Europe performing in the UK.
25 Department for Digital, Culture, Media and Sport, DCMS Sectors Economic Estimates (August 2016): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/544103/DCMS_Sectors_Economic_Estimates_-_August_2016.pdf [accessed 19 July 2018]
26 Department for Digital, Media, Culture and Sport, DCMS Sectors Economic Estimates 2017: Employment and Trade, (26 July 2017, revised 16 August 2017): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/640628/DCMS_Sectors_Economic_Estimates_2017_Employment_and_Trade.pdf [accessed 19 July 2018]
32 Office for National Statistics, ‘Paddington, Star Wars and the rise of the UK film industry’ 14 December 2017: https://www.ons.gov.uk/economy/grossdomesticproductgdp/articles/paddingtonstarwarsandtheriseoftheukfilmindustry/2017–12-14 [accessed 19 July 2018]
36 Ibid.
38 Written evidence from Historic England (BSC0010), the National Museums Directors’ Council and Museums Association (BSC0013) and the Musicians’ Union (BSC0017)
42 Written evidence from Arts Council Wales/Wales Arts International (BSC0002) and the Drawing Room (BSC0007)
43 Rt Hon Theresa May MP, Prime Minister, Speech on ‘Future economic partnership with the European Union’, 2 March 2018: https://www.gov.uk/government/speeches/pm-speech-on-our-future-economic-partnership-with-the-european-union [accessed 19 July 2018]
52 Ibid.
53 Home Office, Tier 5 (Temporary Worker) of the points-based system (5 January 2015): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/581596/Tier-5-Temporary-Worker-v18.pdf [accessed 19 July 2018]
55 UK Visas & Immigration, Routes of entry for artists and entertainers (August 2015): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450237/Entering_the_UK_Arts_Ents_leaflet_August_2015.pdf [accessed 19 July 2018]
56 Home Office, Immigration Rules Appendix A: attributes (25 February 2016, updated 6 July 2018): https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-a-attribute [accessed 20 July 2018]
57 Written evidence from the Creative Industries Federation (BSC0018). See also Home Office, ‘United Kingdom Shortage Occupation List’: https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-k-shortage-occupation-list [accessed 19 July 2018].
68 Written evidence from the Creative Industries Federation (BSC0018) and the Heritage Alliance (BSC0009)
69 Directive 2004/38/EC of the European Parliament and of the Council of 29 April 2004 on the right of citizens of the Union and their family members to move and reside freely within the territory of the Member States amending Regulation (EEC) No 1612/68 and repealing Directives 64/221/EEC, 68/360/EEC, 72/194/EEC, 73/148/EEC, 75/34/EEC, 75/35/EEC, 90/364/EEC, 90/365/EEC and 93/96/EEC (OJ L 158, 30 April 2004)
70 The EU migration acquis covers family members (Directive 2003/86/EC), long-term residents (Directive 2003/109/EC), Single Permit Holders (Directive 2011/98/EC), students and researchers (Directive (EU) 2016/801 (recast)), EU Blue Card Holders (Directive 2009/50/EC), seasonal workers (Directive 2014/36/EU), and Intra-corporate transferees (Directive 2014/66/EU)
75 UK Visas & Immigration, Routes of entry for artists and entertainers (August 2015): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450237/Entering_the_UK_Arts_Ents_leaflet_August_2015.pdf [accessed 19 July 2018]
76 Ibid.
84 Ibid.
85 Written evidence from Arts Council Wales/Wales Arts International (BSC0002); Art Fund (BSC0001) and Arts Council England (BSC0015)
87 Directive 2014/67/EU of the European Parliament and of the Council of 15 May 2014 on the enforcement of Directive 96/71/EC concerning the posting of workers in the framework of the provision of services and amending Regulation (EU) No 1024/2012 on administrative cooperation through the Internal Market Information System ( ‘the IMI Regulation’ ) (OJ L 159, 28 May 2014)
88 European Commission, ‘Posted workers’: http://ec.europa.eu/social/main.jsp?catId=471 [accessed 19 July 2018]
89 Regulation (EC) No 883/2004 of the European Parliament and of the Council of 29 April 2004 on the coordination of social security systems (OJ L 166, 30 April 2004)
90 European Commission, ‘Posted workers’: http://ec.europa.eu/social/main.jsp?catId=471 [accessed 19 July 2018]
94 Council Directive 2009/50/EC of 25 May 2009 on the conditions of entry and residence of third-country nationals for the purpose of highly qualified employment (OJ L 155, 18 June 2009, pp 17–29)