We work to ensure legislation supports illustrators.

We feed into consultations to ensure the voice of illustrators is heard when legislation is changed, and work to ensure the Government safeguards the UK’s gold standard copyright regime that is so vital for sustaining our world-class creative sector, now worth around £100bn a year to the UK economy.

We also feed into and influence national level strategies and projects from the Government’s Orphan Works Licensing Scheme to DACS Payback.  We meet with politicians and law makers, raising concerns proactively.

Below are a selection of submissions we have made.

UK General

Expand all
A pro-innovation approach to AI regulation 2023

Issues around AI (Artificial intelligence/machine learning) are fast moving and in 2023 the Government issued a white paper consultation on the regulation of AI and how that could be done: ‘A pro-innovation approach to AI regulation’. Questions in the paper were posed around what AI regulators should be doing, should organisations be required to make it clear when they are using AI to ensure adequate transparency, what’s required for confidence and trust in AI technology use and routes to compensate for AI-related harms, amongst others.

AOI responded in June, making the case for illustrators, the massive importance of copyright where images are used for training AI and the requirement for regulators to ensure respect for creators’ rights, plus comment on their proposal for voluntary solutions between AI organisations and creators (rather than legislation).

We emphasised that illustrators support progress in technology but also recognise the need for protections and safeguards where technology is applied. That there are valid concerns over the unauthorised use of their images to train AI/Machine learning for text to image platforms, and around possible undermining of their livelihoods by AI generated imagery. We said the default position should be that creators work will not be used for machine learning without their express permission and that the legal framework for AI-related copyright infringement needs to be clear and in line with the UK’s existing copyright regime. See the full response here.

The UK's Future Regime for the Exhaustion of IP Rights August 2021

The Government wants to look at what our exhaustion regime could be post Brexit. Moving to what is termed ‘international exhaustion’ could have an impact for illustrators, as goods could be commissioned in any country worldwide which may pay lower fees, and then imported to the UK, potentially minimising commissioning capacity in the UK. This would not be in the UK’s interest, particularly for book publishing, and therefore it’s important the government chooses to amend the exhaustion regime in a way that protects UK markets. You can read the CRA’s submission here.

Treasury Inquiry: An Equal Recovery (CRA Submission) June 2021

The economic impact of the coronavirus crisis has been felt unevenly. This inquiry will examine different forms of inequality that have emerged or that may have been exacerbated by the crisis and how the Treasury can mitigate them. 

You can read the CRA’s submission here.

Spring Budget Submission 2021

As part of the CRA we submitted recommendations for the UK Spring budget.  These include the need to:

• Extend and expanding the Self Employment Income Support Scheme (SEISS) beyond April 2021 
• Establish a Creators Council to support creative workers.
• Maintain the £20 p.w UC rate and the suspension of the Minimum Income Floor.
• Level up of support for self-employed creative freelancers.
• Extend the reduced 5% VAT rate and the VAT deferral scheme.
• Increase funding for Public Lending Right (PRL).

You can read the full submission here.

Future UK-EU relations: Trade in Services 2021 Inquiry

This inquiry examined the future of UK-EU relations on trade in services and welcomed submissions from the breadth of UK services.  We raised concerns around Licensing, exhaustion and enforcement, tax,  travel and UK Policy making.  You can read our joint submission with the Society of Authors here.

Small Business Commissioner Consultation
As part of the CRA (Creators’ Rights Alliance) we have submitted to the consultation on the Scope and Powers of the Small Business Commissioner.  You can read it here.

Comprehensive Spending Review 2020

We have submitted four recommendations to Chancellor of the Exchequer, Rishi Sunak MP, ahead of the Government’s Comprehensive Spending Review (‘CSR’) in November 2020.

The CSR, which occurs every three years, will set Government budgets for the years 2021/22 to 2023/24 and provides an important opportunity for us to influence the Government’s medium-term spending priorities.

To read our submission click here.

Covid Related Submissions

Impact of Covid on Illustrators Nov 2020
We ran a survey to understand the ongoing impact of the pandemic on illustrators.  We communicated this to MPs directly in a letter here.  You can read the full survey findings here.  If you wish to write to your MP you can use relevant areas of this text.

Post Pandemic Economic Growth 2020
Similar to the submission in June to DCMS, we outlined to the BIS committee, the financial impact of Corona Virus on illustrators, and the action needed to support individuals and the industry going forward.  You can read it in full here: Post Pandemic Economic Growth BEIS AOI August 2020

Impact of Corona Virus on our Industry 2020
We have presented the evidence of the impact of Corona Virus on Illustrators, and urged the Government to offer remedial action, and ambitious, radical support going forward in our submission: Impact of Covid-19 on DCMS sectors AOI Submission 19 June 2020

Economic Impact of Corona Virus 2020

We have communicated the information from the survey to both the Treasury and the BEIS Inquiries. We have outlined both short and longer term support our industry needs here: Economic Impact of Corona Virus AOI Submission 27 May 2020

SEISS Scheme 2020

It is unacceptable for the SEISS scheme (supporting freelancers) not to be extended in line with the JRS scheme (supporting PAYE employees). You can read our letter of May 18 here: AOI re SEISS extension 18 May 2020

Support for Freelancers 2020
At the start of Covid we championed the need for Government support of Freelancers.  Covid AOI response to Gov March 23 2020. We followed this up here: Covid AOI response to Gov March 30 2020.

Trade Agreements

Trade Agreement: Japan 2019

We fed into the Department for International Trade’s consultation on trade with Japan in November 2019 which aims to inform DTI’s approach to the UK’s future trade relationship with Japan. You can read our submission: Japan Trade 2019.

DIT Trade consultation 2018

Trade considerations concerning UK withdrawal from the EU UK Department for International Trade July 2018

The UK is going to have to negotiate some new trade deals and we are working to ensure that our excellent copyright will be a benchmark of great practise and an exportable asset – not something to be bartered.
Again we are working with the BCC and we know we will be closely aligned with other large players in film, music etc. who all rely on copyright to sustain their industries.

British illustration talent is commissioned across boundaries, from the USA, Europe and the rest of the world and we want to make sure there are no barriers to that.

AOI wrote in July 2018 to the DIT supporting the British Copyright Council’s international trade consideration feedback concerning the withdrawal from the European Union.

Points include the importance of consultation on UK’s current copyright system regarding necessary modifications on withdrawal from the EU; that there must be level playing field between individual creators and online content-sharing services and other tech companies; that the UK should improve the streamlining of withholding tax procedures from other countries in trade agreements and that the UK’s strong copyright system be upheld. See the full document: DIT Trade Considerations

CPTPP 2018

Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

In October 2018 we responded to the Department of of International Trade consultation on the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP).

The UK Government is considering signing up to this, and it is important that copyright protected in any agreements with countries that do not have the UK’s robust copyright regime.

DACS sent a letter to the PM about the issues relating to the CPTPP in November 2018 and AOI was a signatory, along with Association of Photographers and Society of Authors. More details here.

European Legislation

Consultation on EU competition law and collective bargaining 2021

The European Commission has sought input as part of an initiative to ensure that EU competition rules do not stand in the way of collective bargaining by certain solo self-employed people.

The Commission recognises that some solo self-employed might be in a situation of unbalanced negotiating power leading them to have little influence over their payment and working conditions.

This initiative could ensure that EU competition rules do not prevent self-employed in a weak position from engaging in collective negotiations or agreements to improve their working conditions. You can read more on the consultation here.

In partnership with the Society of Authors the AOI has contributed to this consultation.  You can read the submission here.

Digital Services Act 2020

The AOI has fed into the Government’s Consultation on the EU’s Digital Services Act, through submissions made both by the CRA and BCC.

The Digital Services Act builds on regulation established over 20 years ago, which, with the pace of digital development is no longer fit for purpose.

Through the BCC we have underlined the need for licenses to be obtained for creative use online, regardless of whether the content is uploaded and / or shared directly by the platform or indirectly by users of digital platforms. This would ensure that rights holders receive compensation for use of their work.

There is also an imperative need for digital services, not rights holders, to have the responsibility of meaningfully addressing piracy, with robust sanctions for infringers and supervision to create an effective marketplace for rights holders.

You can read a summary of the BCC submission here

Directive on Copyright in the Digital Single Market 2019

UK Legislation and Strategies

Proposed Funding Cuts to Higher Education 2021

Funding cuts have been proposed to arts courses in Higher Education, which we believe would have a significant impact on the short and long term of the creative industries, and be hugely detrimental to the diversity of the sector.  We wrote to The Secretary of State for Education about this. You can read our letter here. 

Digital Market Taskforce 2020
The CMA (Competition Market Authority) are calling for information to inform their Digital Market Taskforce. They will provide the government with “practical advice to inform its decisions on what intervention, if any, is necessary to protect and promote competition and innovation in digital markets and to address the anti-competitive effects that can arise from the exercise of market power in those markets.”

We have worked with the BCC to submit a responce which calls for;
-recognition of the value of creativity and innovation;
-enforcement of rights to stop economic harm to grassroots creators;
-redressing the role and responsibilities of online platforms.
to ensure a fair and transparent digital marketplace that promotes creativity, innovation and competition.

You can read BCC’s submission in full here.

Fair Terms for Creators Bill

This is a proposed bill which will address many of the contract issues that creators have to deal with such as clarity in contracts, reasonableness of terms, fair remuneration and moral rights waivers – you can find out more here.

Copyright Licensing Agency Extended Collective Licence 2018
Building our Industrial Strategy 2018

This is an important review which will result in a modern industrial strategy and economy that works for everyone. There is a specific section considering the Creative Industries. We have fed into the consultation for this, articulating the role of illustration and the creative industries within the UK economy and the need for ongoing support to see this thrive. You can read the final report here.

In May 2018 the Intellectual Property Office (IPO) responded to the submissions to the Intellectual Property Call for Views on the Industrial Strategy, which in November 2017 had asked ‘What can we do to encourage innovators to do more collaboration and commercialisation, to stimulate knowledge exchange and promote follow- on innovation?’

The Call set out a number of example proposals IPO had received, including the setting up of a Voluntary Intellectual Property Register which IPO proposed may give creators more ‘legal certainty’. In their 2018 response IPO noted ‘There was a lack of broad support for the establishment of a Voluntary Register for unregistered IP rights, with many respondents noting the additional legal and administrative burdens such a system could introduce.’

There is no requirement for copyright holders to register their IP in the UK, and AOI had stated that we didn’t believe a voluntary register would benefit creators. Our response had mentioned concerns over the additional time and effort required to register works for individual freelancers or small businesses, combined with the potential cost of registering works, which many individual creators will consider an expense they cannot afford. We also queried how the scheme would legally ascertain the veracity of claims of ownership in registered works – this could lead to confusion rather than legal certainty.

Digital Economy Act 2017

This is a large Act covering many areas which do not pertain to illustrators – however there are some technicalities which do – for example the online intermediary codes. This is where providers are required to take responsibility for content which may be infringing copyright. AOI support this legislation.

World Illustration Awards 2023 – Winners Announced!
The WIA2023 Winners Have Been Announced!
Guide to Law & Business book
"An essential guide for all practicing illustrators" Purchase today!
Get Varoom 42 Free
Join AOI today and you'll receive a FREE Varoom 42!


Join our mailing list to get the latest news.