Corporate report

British Library framework document 2025 to 2028

Published 25 September 2025

Introduction and background

1. Purpose of document

1.1. This framework document (the “framework document”) has been agreed between the Department for Culture, Media and Sport (DCMS) and the British Library Board in accordance with HM Treasury’s handbook Managing Public Money^{[footnote 1]} (“MPM”) (as updated from time to time) and has been approved by HM Treasury.

1.2. The framework document sets out the broad governance framework within which the British Library and the DCMS operate. It sets out the British Library core responsibilities, describes the governance and accountability framework that applies between the roles of the DCMS and the British Library and sets out how the day-to-day relationship works in practice, including in relation to governance and financial matters.

1.3. The document does not convey any legal powers or responsibilities but both parties agree to operate within its terms subject to the British Library’s performance of its statutory functions and undertaking of its statutory rights and objectives, including under the British Library Act 1972, the Legal Deposit Libraries Act 2003, the Legal Deposit Libraries (Non Print Works) Regulations 2013, the Public Lending Right Act 1979 and the British Library Board (Power to Borrow) Act 2021 (in each case as such legislation is updated, amended or superseded from time to time, and including all subordinate legislation made under that legislation). The expectations set out here sit alongside the British Library’s statutory and charitable duties expected of staff and trustees. Any perceived conflicts should be brought to the attention of DCMS to discuss an appropriate way forward.

1.4. While commercial subsidies or trading arms may not be subject to the same requirements as the British Library itself, the British Library’s accounting officer should refer to Managing Public Money guidance on any delegations and oversight required for subsidiaries, if applicable. Prior to the next date for review and updating of this document, there shall be a document setting out the arrangements between the British Library and any subsidiaries.

1.5. Copies of the document and any subsequent amendments have been placed in the libraries of both Houses of Parliament and made available to members of the public on the British Library website and on gov.uk.

1.6. This framework document should be reviewed and updated at least every 3 years unless there are exceptional reasons that render this inappropriate that have been agreed with HM Treasury and the Principal Accounting Officer of the sponsor department. The latest date for review and updating of this document is September 2028. The Department and the British Library retain the right to amend this framework document at any time, subject to approval.

2. Objectives

2.1. The DCMS and the British Library share the common objective of discharging the British Library’s duty under section 1(2) of the British Library Act 1972, which is to manage the British Library as “a national centre for reference, study, bibliographical and other information services in relation both to scientific and technological matters and to the humanities” and for enabling the British Library to undertake and perform the British Library’s other statutory and legislative functions and objectives (including those set out under sections 1(3) of the British Library Act 1972).

2.2. To achieve this the British Library and the DCMS will work together in recognition of each other’s roles and areas of expertise, providing an effective environment for the British Library to undertake and perform its statutory and legislative functions, and subject to that, to achieve its strategic objectives through the promotion of partnership and trust and ensuring that the British Library also supports the strategic aims and objective of the department and wider government as a whole whilst discharging and performing its statutory and legislative functions and objectives. 

3. Classification

3.1. The British Library has been classified as a central government organisation by the ONS/HM Treasury Classifications Team. It has been administratively classified by the Cabinet Office as a non-departmental public body (NDPB).

3.2. The British Library is an exempt charity under the Charities Act 2011 but, for charity law purposes, the Secretary of State for Culture Media and Sport acts as its Principal Regulator. The British Library also complies with the duty under section 17 of the Charities Act 2011, to have due regard to public benefit guidance published by the Charity Commission.

3.3. The British Library is a ‘Freedoms Body’. This means that it operates under a set of exemptions from, or modifications to, a specific number of financial and operating requirements. These are detailed at Annex B: Cultural Freedoms Bodies’ Freedoms Charter.

Purposes, duties, aims and prioritie

4. Purposes

4.1. The British Library is the national library of the United Kingdom, formed in 1973 under section 1(1) of the British Library Act 1972.

4.2. Section 1(2) of the British Library Act, placed the library under the control and management of the British Library Board, a public authority whose duty is to manage the library as “a national centre for reference, study, bibliographical and other information services in relation both to scientific and technological matters and to the humanities”.

5. Powers and duties

5.1. The British Library’s primary powers and duties stem from the British Library Act 1972 (notably, under section 1 of the Act and the powers set out in Paragraph 11 of the Schedule to the Act). The British Library also has other statutory and legislative functions, as further described below.

5.2. Under the British Library Act 1972, the British Library’s statutory duties and functions are (in summary) to:

• control and manage the British Library as the national library of the United Kingdom (to be known as ‘the British Library’) consisting of a comprehensive collection of books, manuscripts, periodicals, films and other recorded matter, whether printed or otherwise;
• control and manage the Library as a national centre for reference, study and bibliographical and other information services, in relation both to scientific and technological matters and to the humanities;
• make the services of the British Library available in particular to institutions of education and learning, other libraries and industry;
• to carry out and sponsor research;
• contribute to the expenses of library authorities or of any other person providing library facilities, whether for members of the public or otherwise;
• lend any item, and make any part of the British Library’s collections, or premises, available, in connection with events of an educational, literary or cultural nature; and
• doing all such things and entering into all such transactions as are appropriate or conducive to the discharge of its functions, including imposing charges for any services provided, or for the loan or use of any items from its collections.

5.3. By combination of the Legal Deposit Libraries Act 2003, the Legal Deposit Libraries (Non-Print Works) Regulations 2013 and the Copyright, Designs and Patents Act 1988, the British Library:

• is mandated to receive a copy of every printed publication issued in the United Kingdom, as well as (subject to certain exemptions set out in the 2013 Regulations) non-print works published offline, and non-print works published on line, including websites and electronic publications;
• otherwise acts as a deposit library (amongst other deposit libraries) entitled to the delivery of printed and electronic and digital publications for persons who publish the same in the United Kingdom: and
• is entitled to (among other things):
  - transfer or lend material held under legal deposit to any other deposit library;
  - review and maintain the material held under legal deposit (including making copies of, or adapting, the material for preservation or replacement purposes);
  - use the material held under legal deposit for its own non-commercial research; and
  - supply copies of the materials held under legal deposit for the purposes of non-commercial research or private study.

5.4. Since 2014, under the Public Lending Right Act 1979, and in accordance with the provisions of that Act the British Library undertakes the functions formerly assigned to the Registrar of Public Lending Right, which include (in summary):

• establishing and maintaining a register showing the classes, descriptions and categories of books in respect of which the public lending right of authors (conferred by sections 1(1) of the 1979 Act) subsists and the persons entitled to the right in respect of any registered book;

• determining and paying the sums (if any) due by way of public lending right out of a funding allocation constituted by the relevant Secretary of State;

• controlling and managing the central fund;

• being entitled to the payment of a fee, according to prescribed scales and rates, for supplying copies of entries in the register, and;

• otherwise undertaking these functions in accordance with the scheme laid down by parliament from time to time.

5.5. The Board shall, in accordance with directions of the Secretary of State given after consultation with them, constitute Advisory Councils with responsibility for providing advice to the Board, or to any department of the British Library, on such matters as the Secretary of State or the Board may determine from time to time.

6. Aims and priorities

6.1. The Secretary of State outlined priorities for this period in the latest Settlement Letter sent to the British Library. The Secretary of State expects all Public Bodies, where reasonable, to align their activities with these general priorities.

6.2. Public Bodies also have a duty to ensure that they are working to eliminate discrimination and advance equality of opportunity. This includes ensuring that factors such as socio-economic background and geographic location are considered in the development and delivery of programmes, as well as protected characteristics.

6.3. The British Library’s performance in meeting these aims and priorities will be monitored through key performance indicators as agreed between DCMS and the British Library. The KPIs will be reviewed at least annually and updated as necessary.

6.4. The British Library’s strategic aims, published in a separate strategy document, are based on its Mission and Public Purposes:

Mission: to make our intellectual heritage accessible to everyone, for research, inspiration and enjoyment.

Public purposes:

• Custodianship: build, curate and preserve the UK’s national collection of published written and digital content
• Research: support and stimulate research of all kinds
• Business: help businesses to innovate and grow
• Culture: engage everyone with memorable cultural experiences
• Learning: inspire young people and learners of all ages
• International: work with partners around the world to advance knowledge and mutual understanding

6.5. The British Library’s strategic aims can be updated at any time, and will be published on its website.

Governance and accountability

7. Governance and accountability

7.1. Acknowledging its statutory and legislative functions and objectives, the British Library shall operate corporate governance arrangements that, so far as practicable and in the light of the other provisions of this framework document, its status as an exempt charity (or otherwise as may be mutually agreed), accord with good corporate governance practice and applicable regulatory requirements and expectations.

7.2. In particular (but without limitation), the British Library should:

• comply with the principles and provisions of the Corporate Governance in Central Government Departments Code of Good Practice^{[footnote 2]} (as amended and updated from time to time) to the extent appropriate and in line with its statutory and legislative functions and objectives (or specify and explain any non-compliance in its annual report);
• comply with MPM;
• in line with MPM have regard to the relevant Functional Standards^{[footnote 3]} as appropriate and in particular those concerning Finance, Commercial and Counter Fraud;
• take into account the codes of good practice and guidance set out in Annex A of this framework document, as they apply to ALBs;
• comply with its duties under charity law to the extent applicable as an exempt charity.

7.3. In line with MPM Annex 3.1 and the Charities Statement of Recommended Practice^{[footnote 4]} the British Library shall provide an account of corporate governance in its annual governance statement including the Board’s assessment of its compliance with the Code with explanations of any material departures. To the extent that the British Library does intend to materially depart from the Code, the sponsor should be notified in advance.

Role of the department

8. The responsible Minister

8.1. The responsible Minister is The Secretary of State for Culture, Media and Sport of the United Kingdom. The Secretary of State for the Department for Culture, Media and Sport, and other members of the Ministerial Team are accountable to Parliament for all matters concerning the British Library. For consistency, the Secretary of State will be referred to as ‘the responsible Minister’ throughout this Framework Document.

8.2. The Ministers’ statutory powers in respect of the British Library are set out in the British Library Act 1972. See section 5.

8.3. These are to (in summary):

• appoint the Chairperson and certain other members of the British Library Board;
• determine the date for receipt of an annual report of the proceedings and activities of the Board, and lay a copy of each report before Parliament;
• pay sums approved by Treasury towards the expenditure incurred by the British Library; and
• determine the remuneration and allowances paid to members of the British Library Board.

8.4. The Secretary of State’s role as Principal Regulator: The Secretary of State for Culture, Media and Sport will carry out the general duty as “principal regulator” for the British Library, as it is an exempt charity listed in Schedule 3 to the Charities Act 2011 . This role will also be fulfilled with respect to bodies that are closely connected with the British Library. The general duty is set out in section 26 of the Charities Act 2011 and it is a duty to do all that the Secretary of State reasonably can to promote compliance by the British Library Board members with their legal obligations in exercising control and management of the administration of the charity (“the compliance objective”).

Appointments to the Board

8.5. A full-time member of the British Library Board is appointed under section 2 of the British Library Act 1972 with the approval of the responsible Minister. This is usually, but does not have to be, the Chief Executive.

8.6. Under Section 2(1) of the British Library Act 1972, the responsible Minister shall have the following appointment and approval rights in relation to the British Library’s Board (which shall consist of a chairperson and not less than eight, nor more than thirteen, other members, one of whom must be appointed as a “whole time” member (as opposed to a part time member):

• The chairperson is appointed by the responsible Minister. This appointment is subject to the Public Appointments Order in Council and as such must comply with the Governance Code on Public Appointments.
• All other members of the Board, except two (one of whom shall be appointed by His Majesty and the other by the Trustees of the British Museum) shall be appointed by the responsible Minister (one of whom should appear to have special knowledge of Scotland)
• All such appointments should have regard to the principle that appointments should reflect the diversity of the society in which we live, and appointments should be made taking account of the need to appoint boards which include a balance of skills and backgrounds. Notwithstanding this, under sections 2(2) and 2(2A) of the British Library Act 1972, the responsible Minister shall (respectively) make appointments: that give preference to those who appear to have knowledge and experience of library and university affairs, finance, industry or administration; and following consultation with the Scottish Minister (in relation to the member of the Board intended to have knowledge of Scotland).

Other Ministerial powers and responsibilities

8.7. The responsible Minister is also responsible for:

• agreeing the policy framework within which the British Library operates
• Based on advice of the sponsor team, determining if it is necessary to read and consider British Library’s performance framework, strategy, annual plan.
• matters regarding spending approvals, in line with delegations as set out in the delegation letter and the Freedoms detailed in Annex B
• such other matters as may be appropriate and proportionate to and in the interests of, the statutory and legislative functions of the British Library
• approving the Public Lending Right Rate Per Loan, the value of which is advised by the British Library

9. The Principal Accounting Officer

9.1. The Principal Accounting Officer (PAO) is the Permanent Secretary of the department.

PAO’s specific accountabilities and responsibilities

9.2. The PAO of DCMS designates the Chief Executive (the ‘whole time’ member of the British Library Board) as the British Library’s Accounting Officer (AO) and ensures that they are fully aware of their responsibilities. The PAO issues a letter appointing the AO, setting out their responsibilities and delegated authorities.

9.3. The respective responsibilities of the PAO and AOs for ALBs are set out in Chapter 3 of MPM.

9.4. The PAO is accountable to Parliament for the issue of any grant-in-aid to the British Library.

9.5. The PAO is also responsible, usually via the sponsorship team, for advising the responsible Minister on:

• an appropriate framework of objectives and targets for the British Library in the light of the department’s wider strategic aims and priorities
• an appropriate budget for the British Library in the light of the sponsor department’s overall public expenditure priorities
• how well the ALB is achieving its strategic objectives and whether it is delivering value for money
• the exercise of the Ministers’ statutory responsibilities concerning the British Library as outlined above

9.6. The PAO via the sponsorship team is also responsible for ensuring arrangements are in place in order to:

• monitor the ALB’s activities and performance
• address significant problems in the ALB, making such interventions as are judged necessary
• periodically and at such frequency as is proportionate to the level of risk carry out an assessment of the risks both to the department and the ALB’s objectives and activities in line with the wider departmental risk assessment process
• inform the ALB of relevant government policy in a timely manner
• bring ministerial or departmental concerns about the activities of the ALB to the full (ALB) board, and, as appropriate to the departmental Board, requiring explanations and assurances that appropriate action has been taken

10. The role of the sponsorship team

10.1. The Libraries Team in DCMS is the primary contact for the British Library. The responsible senior civil servant for this relationship is the Deputy Director for Creative Places and Libraries (or the holder(s) of any subsequent post that takes on the equivalent functions). They are the main source of advice to the responsible Minister on the discharge of their responsibilities in respect of the British Library. They also support the PAO on their responsibilities toward the British Library.

10.2. Officials in Libraries Team and in relevant teams in DCMS will conduct their sponsorship roles in line with the Sponsorship Code of Good Practice^{[footnote 5]} and work in partnership with the British Library in line with the Partnerships with Arm’s Length Bodies Code of Good Practice^{[footnote 6]}.

10.3. Officials of Libraries Team in DCMS, supported by other relevant teams within DCMS, will liaise regularly with British Library officials to review performance against plans, achievement against targets including KPIs as agreed with the British Library and expenditure against its DEL and AME allocations, and review issues and risks. The Libraries Team will also take the opportunity to explain wider policy developments that might have an impact on the ALB. 

10.4. Accountability/partnership meetings will take place every quarter. Relevant officials from the DCMS Finance, Human Resources, Commercial and/or Public Bodies teams may attend accountability meetings as necessary.

11. Resolution of disputes between the British Library and department

11.1. Any disputes between the department and the British Library will be resolved in as timely a manner as possible. The department and the British Library will seek to resolve any disputes through an informal process in the first instance. If this is not possible, then a formal process, overseen by the senior sponsor, will be used to resolve the issue. Failing this, the senior sponsor will ask the relevant policy Director General to oversee the dispute. They may then choose to ask the Permanent Secretary to nominate a non-executive member of the department’s Board to review the dispute, mediate with both sides and reach an outcome, in consultation with the responsible minister.

12. Freedom of Information requests and other data requests

12.1. Where a request for information is received by either party under the Freedom of Information Act 2000, or the Data Protection Act 2018, the party receiving the request will consult with the other party prior to any disclosure of information that may affect the other party’s responsibilities.

13. Reporting on legal risk and litigation

13.1. The British Library shall provide a quarterly update to the sponsor on the existence of any active litigation and any threatened or reasonably anticipated litigation. The parties acknowledge the importance of ensuring that legal risks are communicated appropriately to the sponsor in a timely manner.

13.2. In respect of each substantial piece of litigation involving the British Library (threshold of £50k), the parties will agree appropriate and timely reporting on the status of the litigation and the protection of legally privileged information transmitted to the sponsor to facilitate this. the parties will ensure that:

• legally privileged documents and information are clearly marked as such
• steps are taken to ensure that legal privilege is not waived, including ensuring any circulation within Government is limited to that which is strictly necessary

The British Library governance structure

14. The Chief Executive

Responsibilities of the British Library’s chief executive as accounting officer

14.1. The Chief Executive as AO is personally responsible for safeguarding the public funds for which they have charge; for ensuring propriety, regularity, value for money and feasibility in the handling of those public funds; and for the day-to-day operations and management of the British Library. In addition, they should ensure that the British Library as a whole is run on the basis of the standards, in terms of governance, decision-making and financial management, that are set out in Box 3.1 of MPM. These responsibilities include the below and those that are set in the AO appointment letter issued by the PAO of the sponsor department.

Responsibilities for accounting to Parliament and the public

14.2. Responsibilities to Parliament and the public include:

• signing the accounts and ensuring that proper records are kept relating to the accounts and that the accounts are properly prepared and presented in accordance with any directions issued by the responsible Minister.
• preparing and signing a Governance Statement covering corporate governance, risk management and oversight of any local responsibilities, for inclusion in the annual report and accounts
• ensuring that effective procedures for handling complaints about the ALB in accordance with Parliamentary and Health Service Ombudsman’s Principles of Good Complaint Handling are established and made widely known within the ALB and published on the British Library website
• acting in accordance with the terms of MPM and other instructions and guidance issued from time to time by the department, the Treasury and the Cabinet Office
• ensuring that as part of the above compliance they are familiar with and act in accordance with:
  - any governing legislation (and other legislation under which the British Library has statutory and/or legislative functions and objectives)
  - this framework document
  - any delegation letter issued to the British Library
  - any elements of any settlement letter issued to the sponsor department that is relevant to the operation of the British Library
  - any separate settlement letter that is issued to the British Library from the sponsor department
• ensuring they have appropriate internal mechanisms for monitoring, governance and external reporting regarding non-compliance with any conditions arising from the above documents
• giving evidence, normally with the PAO, when summoned before the PAC on the ALB’s stewardship of public funds.

Responsibilities to the DCMS

14.3. Responsibilities to DCMS include:

• Following British Library Board approval, presenting the British Library’s corporate and business plans to the department to demonstrate these plans reflect the department’s wider strategic aims, agreed priorities and statutory and legislative functions and objectives
• informing the department of progress in helping to achieve the department’s policy objectives which coincide with the British Library’s statutory and legislative functions and in demonstrating how resources are being used to achieve those functions and objectives
• ensuring that timely forecasts and monitoring information on performance and finance are provided to the department; that the department is notified promptly if over or under spends are likely and that corrective action is taken; and that any significant problems whether financial or otherwise, and whether detected by internal audit or by other means, are notified to the department in a timely fashion.

Responsibilities to the Board

14.4. The Chief Executive (as AO) is responsible for:

• advising the Board on the discharge of its responsibilities as set out in this document, in charity law and in compliance with the British Library’s governing document, the founding legislation and in any other relevant instructions and guidance that may be issued from time to time
• advising the Board on the British Library’s performance compared with its aims and objectives
• ensuring that financial considerations are taken fully into account by the Board at all stages in reaching and executing its decisions, and that financial appraisal techniques are followed.

Managing conflicts

14.5. The Chief Executive (as AO) should follow the advice and direction of the British Library Board, except in very exceptional circumstances with a clear cut and transparent rationale for not doing so.

14.6. If the Board, or its chairperson, is contemplating a course of action involving a transaction which the Chief Executive as AO considers would infringe the requirements of propriety or regularity or does not represent prudent or economical administration, efficiency or effectiveness, is of questionable feasibility, or is unethical, the Chief Executive in their role as AO should reject that course of action and ensure that the Board has a full opportunity to discuss the rationale for that rejection.

14.7. If the British Library Board is minded to instruct its AO to carry out a course inconsistent with their duties as AO, then the AO should make their reservations clear, preferably in writing. If the Board is still minded to proceed, the British Library AO should then:

• ask the PAO of the sponsor department to consider intervening to resolve the difference of view, preferably in writing
• if the Board’s decision stands, seek its written direction to carry it out, asking the sponsor department to inform HM Treasury
• proceed to implement without delay
• follow the routine in paragraph 3.6.6 of MPM.

15. The Board

Composition of the Board

15.1. The British Library will have a board in line with good standards of corporate governance and as set out in its establishing statute and in guidance as set out in Annex A. Detailed responsibilities of the board shall be set out in the Board terms of reference. Remuneration of the Board will be disclosed in line with the guidance in the Government Financial Reporting manual (FReM).

15.2. The Board will consist of not less than 8 and no more than 13 members, including a chairperson, that have a balance of skills and experience appropriate to directing the British Library’s business. The Board is a unitary board.

15.3. The terms of appointment of the Chair and Board members are as set out in the British Library’s founding legislation or other founding documents. Where such appointments are made by Ministers, they will comply with the Governance Code for Public Appointments.

Board Committees

15.4. The Board may set up such committees as necessary for it to fulfil its functions. As is detailed below at a minimum this should include an Audit and Risk Committee chaired by an independent and appropriately qualified non-executive member of the Board.

15.5. While the Board may make use of committees to assist its consideration of appointments, succession, audit, risk and remuneration it retains responsibility for, and endorses, final decisions in all of these areas. The Chair should ensure that sufficient time is allowed at the board for committees to report on the nature and content of discussion, on recommendations, and on actions to be taken.

15.6. Where there is disagreement between the relevant committee and the Board, adequate time should be made available for discussion of the issue with a view to resolving the disagreement. Where any such disagreement cannot be resolved, the committee concerned should have the right to report the issue to the sponsor team, PAO and responsible Minister. They may also seek to ensure the disagreement or concern is reflected as part of the report on its activities in the annual report.

15.7. The Chair should ensure board committees are properly structured with appropriate terms of reference. The terms of each committee should set out its responsibilities and the authority delegated to it by the Board. The Chair should ensure that committee membership is periodically refreshed.

Duties of the Board

15.8. Notwithstanding the Accounting Officer’s responsibilities, the Board is the principal governance body within the organisation. The Board is specifically responsible for:

• establishing and taking forward the strategic aims and objectives of the British Library, consistent with its statutory and legislative functions and objectives, and within that, its overall strategic direction and charitable purposes, acknowledging to the extent applicable the policy and resources framework determined by the responsible Minister.
• providing effective leadership of the British Library within a framework of prudent and effective controls which enables risk to be assessed and managed
• reviewing management performance
• ensuring the financial and human resources are in place for the British Library to meet its objectives
• ensuring that the Board receives and reviews regular financial and management information concerning the management of the British Library
• ensuring that it is kept informed of any changes which are likely to impact on the strategic direction of the British Library Board or on the attainability of its targets, and determining the steps needed to deal with such changes and where appropriate bringing such matters to the attention of the responsible Minister and PAO via the executive team, sponsorship team or directly
• ensuring that any statutory or administrative requirements for the use of public funds are complied with; that the Board operates within the limits of its statutory authority and any delegated authority agreed with the sponsor department, and in accordance with any other conditions relating to the use of public funds
• ensuring that in reaching decisions, the Board takes into account guidance issued by the sponsor department
• ensuring that as part of the above compliance they are familiar with:
  - this framework document
  - their statutory functions and objectives
  - their duties under charity law
  - any delegation letter issued to the British Library
  - any elements of any settlement letter issued to the sponsor department that is relevant to the operation of the ALB
  - any separate settlement letter that is issued to the ALB from the sponsor department
  - that they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding any conditions arising from the above documents and ensure that the chief executive and the British Library as a whole act in accordance with their obligations under the above documents
• demonstrating high standards of corporate governance at all times, including by using external expertise or an independent audit committee to help the board to address key financial and other risks
• appointing with the responsible Minister’s approval a Chief Executive as AO and, in consultation with the department, set performance objectives and remuneration terms linked to these objectives for the Chief Executive as AO which give due weight to the proper management and use and utilisation of public resources
• cooperating with the DCMS-led annual appraisal of the chairperson, including sharing the Board’s own effectiveness review
• putting in place mechanisms for the Chief Executive to have visibility of Board activity with sufficient time before Board decisions are agreed. The mechanism will enable the Chief Executive to take action where needed as per paragraph ‘Managing conflicts’
• determining all such other things which the Board considers ancillary or conducive to the attainment or fulfilment by the British Library of its statutory functions and objectives, acknowledging its status as an exempt charity

15.9. The Board should ensure that effective arrangements are in place to provide assurance on risk management, governance and internal control.

15.10. The Board should make a strategic choice about the style, shape and quality of risk management and should lead the assessment and management of opportunity and risk. The Board should ensure that effective arrangements are in place to provide assurance over the design and operation of risk management, governance and internal control in line with the Management of Risk – Principles and Concepts (The Orange Book)^{[footnote 7]}. The Board must set up an Audit and Risk Assurance Committee chaired by an independent and appropriately qualified non-executive member to provide independent advice and ensure that the department’s Audit and Risk Assurance Committee are provided with routine assurances with escalation of any significant limitations or concerns. The Board is expected to assure itself of the adequacy and effectiveness of the risk management framework and the operation of internal control. Notwithstanding the above, the Board is responsible for ensuring that the organisation has adequate systems and controls in place including appropriate schemes of delegation, and that these are suitably assured/audited.

16. The Chair’s role and responsibilities 

16.1. The Chair is responsible for leading the Board in the delivery of its responsibilities. Such responsibility should be exercised in the light of their duties and responsibilities as set out in their appointment letter, the priorities in the chair’s letters issued to them by the sponsor team, the statutory authority governing the British Library, the ALB’s governing document and charity law, and this document and the documents and guidance referred to within this document.

16.2. Communications between the British Library’s Board and the responsible Minister should normally be through the Chair. 

16.3. The Chair is bound by the Code of Conduct for Board Members of Public Bodies^{[footnote 8]}, which covers conduct in the role and includes the Nolan Principles of Public Life^{[footnote 9]}.

16.4. In addition, the Chair is responsible for:

• ensuring including by monitoring and engaging with appropriate governance arrangements that the British Library’s affairs are conducted with probity
• ensuring that policies and actions support the responsible Minister’s wider strategic policies and where appropriate, these policies and actions should be clearly communicated and disseminated throughout the ALB. 

16.5. The Chair has the following leadership responsibilities: 

• formulating the Board’s strategy
• ensuring that the Board, in reaching decisions, takes proper account of guidance provided by the responsible Minister or the department
• promoting the efficient and effective use of staff and other resources
• delivering high standards of regularity and propriety
• representing the views of the Board to the general public.

16.6. The Chair also has an obligation to ensure that: 

• the work of the Board and its members are reviewed and are working effectively including ongoing assessment of the performance of individual board members with a formal annual evaluation and more in-depth assessments of the performance of individual board members when being considered for re-appointment
• that in conducting assessments that the view of relevant stakeholders including employees and the sponsorship team are sought and considered
• that all Board members (including the Chair) and the Chief Executive continually update their skills, knowledge and familiarity with the British Library to fulfil their role both on the Board and committees. This will include but not be limited to skills and training in relation to financial management and reporting requirements, risk management and the requirements of board membership within the public sector
• board members are fully briefed on terms of appointment, duties, rights and responsibilities
• they, together with the other board members, receives appropriate training on financial management and reporting requirements and on any differences that may exist between private and public sector practice
• the responsible Minister is advised of the British Library’s needs when board vacancies arise
• there is a Board Operating Framework in place setting out the role and responsibilities of the board consistent with the Government Code of Good Practice for Corporate Governance 
• there is a code of practice for board members in place, consistent with the Cabinet Office Code of Conduct for Board Members of Public Bodies.

17. Individual Board responsibilities 

17.1. Individual Board members should: 

• comply at all times with the  Code of Conduct for Board Members of Public Bodies, which covers conduct in the role and includes the Nolan Principles of Public Life as well as rules relating to the use of public funds and to conflicts of interest
• demonstrate adherence to the 12 Principles of Governance for all Public Body Non-Executive Directors as appropriate^{[footnote 10]}
• not misuse information gained in the course of their public service for personal gain or for political profit, nor seek to use the opportunity of public service to promote their private interests or those of connected persons or organisations
• comply with the Board’s rules on the acceptance of gifts and hospitality, and of business appointments
• act in good faith and in the best interests of the British Library
• ensure they are familiar with any applicable guidance on the role of public sector non-executive directors and boards that may be issued from time to time by the Cabinet Office, HM Treasury or wider government
• ensure that they are familiar with guidance on the duties under charity law
• comply with the ALB’s governing document.

Management and financial responsibilities and controls

18. Delegated authorities

18.1. The British Library’s delegated authorities and limits (beyond those set out in the British Library Act 1972 or other legislation referred to in this framework document under which the British Library derives its statutory functions and responsibilities) are set out in the delegation letter issued annually at the start of a new financial year. This delegation letter may be updated and superseded by later versions which may be issued by the sponsor department in agreement with HM Treasury.

18.2. In line with MPM Annex 2.2 these delegations will be reviewed on an annual basis.

18.3. The ALB shall obtain the department’s and where appropriate HM Treasury’s prior written approval before:

• entering into any undertaking to incur any expenditure that falls outside the delegations or which is not provided for in the ALB’s annual budget as approved by the department
• incurring expenditure for any purpose that is or might be considered novel or contentious, or which has or could have significant future cost implications
• making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by the department
• making any change of policy or practice which has wider financial implications that might prove repercussive or which might significantly affect the future level of resources required
• carrying out policies that go against the principles, rules, guidance and advice in MPM.

19. Spending authority

19.1. Once the budget allocation has been approved by the sponsor department and subject to any restrictions imposed by statute, the responsible Minister’s instructions, HM Treasury settlement letters, or this document the British Library shall have authority to incur expenditure approved in the budget and in line with its operational Freedoms without further reference to the sponsor department, on the following conditions:

• the British Library shall comply with the delegations set out in the delegation letter. These delegations shall not be altered without the prior agreement of the sponsor department and as agreed by HM Treasury and Cabinet Office as appropriate
• the ALB shall comply with MPM regarding novel, contentious or repercussive proposals
• inclusion of any planned and approved expenditure in the budget shall not remove the need to seek formal departmental approval where any proposed expenditure is outside the delegated limits or is for new schemes deviating significantly from activities and expenditure anticipated in the Corporate and/or Strategic Plan
• the British Library shall provide the sponsor department with such information about its operations, performance, individual projects or other expenditure as the sponsor department may reasonably require.

20. Banking and managing cash

20.1. As a Freedoms Body, the British Library does not need explicit approval to change banking provider, but should provide written notification to DCMS upon doing so.

20.2. The AO is responsible for ensuring ALB has a banking policy as set out in MPM and ensuring that policy is complied with.   

21. Procurement

21.1. As a Freedoms Body, the British Library has the flexibility to opt in and out of central procurement and is exempt from other spend controls (see Annex B). Nonetheless the following standards of good practice apply.

21.2. The British Library will ensure that its procurement policies are aligned with and comply with any relevant UK or other international procurement rules and in particular the Public Contracts Regulations (for example but not exclusive to, the Public Contracts Regulations 2015 and the Procurement Act 2023).

21.3. The British Library shall establish its procurement policies and document these in a Procurement Policy.

21.4. In procurement cases where the British Library is likely to exceed its delegated authority limit, and where a relevant Freedom does not apply, procurement strategy approval for the specific planned purchase must be sought from the department’s sponsor team.

21.5. Goods, services and works should be acquired by competition in line with procurement regulations. Proposals to let single-tender or restricted contracts above the delegated limit of £123,000 shall be limited and exceptional, and a report explaining those exceptions should be sent to the Department.

21.6. The delegated limit for single tender action contracts is set out within delegation letters and at Annex C. The British Library must comply with the Single Tender Action process as outlined at Annex C and as otherwise communicated to them by the Department.

21.7. In line with the PCR threshold of £123,000, procurement by the British Library of works, equipment, goods, and services shall be based on, a full option appraisal and value for money (VfM), i.e. the optimum combination and whole life costs and quality (fitness for purpose).

21.8. The British Library shall:

• engage fully with department and government wide procurement initiatives that seek to achieve VfM from collaborative projects
• comply with all relevant Procurement Policy Notes issued by Cabinet Office
• cooperate fully with initiatives to improve the availability of procurement data to facilitate the achievement of VfM.

21.9. The British Library shall comply with the mandatory aspects of the commercial^{[footnote 11]} and grants standards^{[footnote 12]}. These standards apply to the planning, delivery, and management of government commercial activity, including management of grants in all departments and ALBs, regardless of commercial approach used and form part of a suite of functional standards that set expectations for management within government.

22. Risk management

22.1. The British Library shall ensure that the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and develop a risk management strategy, in accordance with the Treasury guidance Management of Risk: Principles and Concepts^{[footnote 13]} .

22.2. The British Library will allow for risk-based DCMS involvement in Audit and Risk Committee meetings.

23. Counter fraud and theft

23.1. The British Library should adopt and implement policies and practices to safeguard itself against fraud and theft.

23.2. The British Library should act in line with guidance as issued by the Counter Fraud Function and in compliance with the procedures and considerations as set in in MPM Annex 4.9 and the Counter Fraud Functional Standard^{[footnote 14]}. It should also take all reasonable steps to appraise the financial standing of any firm or other body with which it intends to enter a contract or to provide grant or grant-in-aid.

23.3. The British Library should keep records of and prepare and forward to the department a quarterly report on fraud and theft suffered by the British Library and notify the sponsor department of any unusual or major incidents as soon as possible. The British Library should also report detected loss from fraud, bribery, corruption and error, alongside associated recoveries and prevented losses, to the counter fraud centre of expertise in line with the agreed government definitions as set out in Counter Fraud Functional Standard.

24. Staff 

Broad responsibilities for staff 

24.1. Within the arrangements approved by the responsible Minister, and subject to any relevant Freedom, the ALB will have responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities toward its staff are to ensure that:

• the rules for recruitment and management of staff create an inclusive culture in which diversity is fully valued; appointment and advancement are based on merit; there is no discrimination against employees with protected characteristics under the Equality Act 2010
• the level and structure of its staffing, including grading and staff numbers, are appropriate to its functions and the requirements of economy, efficiency and effectiveness
• the performance of its staff at all levels is satisfactorily appraised and the ALB performance measurement systems are reviewed from time to time
• its staff are encouraged to acquire the appropriate professional, management and other expertise necessary to achieve the ALB’s objectives
• proper consultation with staff takes place on key issues affecting them
• adequate grievance and disciplinary procedures are in place
• whistle-blowing procedures consistent with the Public Interest Disclosure Act are in place
• a code of conduct for staff is in place. 

Staff costs 

24.2. Subject to its delegated authorities, the British Library shall ensure that the creation of any additional posts does not incur forward commitments that will exceed its ability to pay for them. 

Pay and conditions of service 

24.3. The British Library’s staff are subject to appropriate levels of remuneration and terms and conditions of service (including pensions). As a Freedom Body, the British Library will not be subject to the Civil Service Pay Remit Guidance (“PRG”) and will have the ability to offer average pay awards in excess of caps set out in this guidance.

24.4. They shall continue to engage with their Sponsor Department during the process of making a pay remit application, particularly prior to completion. They shall also continue to provide outturn data to HM Treasury and adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office.

24.5. If civil service terms and conditions of service apply to the rates of pay and non-pay allowances paid to the staff and to any other party entitled to payment in respect of travel expenses or other allowances, payment shall be made in accordance with the Civil Service Management Code^{[footnote 15]}  except where prior approval has been given by the department to vary such rates. 

24.6. Staff terms and conditions should be set out and available to both staff and DCMS if requested.

24.7. The British Library shall continue to adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office including the Senior Pay Guidance.

24.8. The travel expenses of board members shall be tied to the rates allowed to all staff of the British Library. Reasonable actual costs shall be reimbursed. 

Pensions, redundancy and compensation 

24.9. Compensation scheme rules and pension scheme rules should reflect legislative and HM Treasury guidance requirements regarding exit payments.

24.10. The British Library staff shall normally be eligible for a pension provided by PCSPS. Staff may opt out of the occupational pension scheme provided by the British Library, altogether or switch to PCSPS Partnership arrangement but that employers contribution to any personal pension arrangement, including stakeholder pension, shall normally be limited to the auto enrolment minimum. As a Freedoms Body, the British Library has the right to opt out of the Principal Civil Service Pension Scheme for new starters.

24.11. Any proposal by the British Library to pay any redundancy or compensation for loss of office, requires the prior approval of the department. Proposals on severance must comply with the rules in Chapter 4 of MPM.

Business plans, financial reporting and management information

25. Corporate and business plans 

25.1. The British Library shall share its multi-year strategic plans in advance of publication, and provide annual progress updates. The plan shall reflect the British Library’s statutory and/or other duties, its charitable status, and, within those duties (acknowledging that status), the priorities set from time to time by the responsible Minister (including decisions taken on policy and resources in the light of wider public expenditure decisions). The plan shall demonstrate how the British Library contributes to the achievement of the department’s medium-term plan and priorities and aligned performance metrics and milestones in line with its charitable purposes.  

25.2. Subject to any commercial considerations, [a digest of] the corporate and business plans should be published by the British Library on its website and separately be made available to staff. 

26. Budgeting procedures 

26.1. Each year, in the light of decisions by the department on the updated draft DCMS corporate plan, the department will send to the British Library within an agreed timetable:

• a formal statement of the annual budgetary provision allocated by the department in the light of competing priorities across the department and of any forecast income approved by the department
• a statement of any planned change in policies affecting the British Library

26.2. The annual business plan will take account both of approved funding provision where this applies and, where this applies, any forecast receipts. It will include a budget of estimated payments and receipts together with a profile of expected expenditure and of draw-down of any departmental funding and/or other income over the year. These elements form part of the approved business plan for the year in question. 

27. Grant-in-aid and any ring-fenced grants 

27.1. Any grant-in-aid provided by the department for the year in question will be voted in the department’s Supply Estimate and be subject to parliamentary control. 

27.2. The grant-in-aid will normally be paid in monthly instalments on the basis of written applications showing evidence of need. The British Library will comply with the general principle, that there is no payment in advance of need. Cash balances accumulated during the course of the year from grant-in-aid or other Exchequer funds shall be kept to a minimum level consistent with the efficient operation of the British Library. Grant-in-aid not drawn down by the end of the financial year shall lapse. 

27.3. In the event that the department provides the British Library separate grants for specific (ring-fenced) purposes, it would issue the grant as and when the British Library needed it on the basis of a written request. The British Library would provide evidence that the grant was used for the purposes authorised by the department. The British Library shall not have uncommitted grant funds in hand, nor carry grant funds over to another financial year.

28. Annual report and accounts 

28.1. Prepare annual reports and accounts following the direction given by the Sponsor department (or HM Treasury) in line with Government Resource and Accounts Act 2000 (or the entity’s relevant legislation).

28.2. Information on performance against key financial targets is included within the annual report and subject to the auditor’s consistency opinion. The report and accounts shall be laid in Parliament and made available on the British Library website, in accordance with the guidance in the FReM. 

29. Reporting performance to the department 

29.1. The British Library shall operate management, information and accounting systems that enable it to review in a timely and effective manner its financial and non-financial performance against the budgets and targets set out in the corporate and business plans. 

29.2. The British Library shall inform the sponsor department of any changes that make achievement of objectives more or less difficult. It shall report financial and non-financial performance, including performance in helping to deliver Ministers’ policies, and the achievement of key objectives via quarterly Partnership Meetings with the department.

29.3. The British Library’s performance shall be formally reviewed by the department quarterly. The British Library will share a summary of its financial and non-financial performance – including performance in helping to deliver ministers’ policies, on key DCMS priorities and against KPIs - quarterly as part of partnership/governance meetings. The format of this information pack will be agreed between the British Library and their Senior Sponsor in advance. Board papers will be shared on a case-by-case basis, as appropriate.

29.4. The responsible Minister will meet a senior representative of the British Library once a year.

29.5. The Principal Accounting Officer (PAO) (Permanent Secretary) will meet the Chair and/or Chief Executive at least once a year. 

30. Information sharing  

30.1. Subject to any overriding legal rights or obligations, the department has the right of access to all the British Library records and personnel for any purpose including, for example, sponsorship audits and operational investigations. A Data Sharing Agreement/MoU will be required prior to the transfer of any personal data.

30.2. The British Library shall provide the sponsor department with such information about its operations, performance, individual projects or other expenditure as the sponsor department may reasonably require.

30.3. The department and HM Treasury may request the sharing of data held by the British Library in such a manner as set out in central guidance except as it is prohibited by law. This may include requiring the appointment of a senior official to be responsible for the data sharing relationship.

30.4. As a minimum, the British Library shall provide the department with information monthly that will enable the department satisfactorily to monitor: 

• The British Library’s cash management
• its draw-down of grant-in-aid
• forecast outturn by resource headings
• other data required for the Online System for Central Accounting and Reporting (OSCAR)
• data as required in respect of its compliance with any applicable Cabinet Office Controls pipelines or required in order to meet any condition as set out in any settlement letter

Audit

31. Internal audit 

31.1. The British Library shall: 

• establish and maintain arrangements for internal audit
• ensure that any arrangements for internal audit are in accordance with the Public Sector Internal Audit Standards (PSIAS) as adopted by HM Treasury^{[footnote 16]}.
• Ensure the sponsor department is satisfied with the competence and qualifications of the Head of Internal Audit and the requirements for approving appointments in accordance with PSIAS
• set up an audit committee of its board in accordance with the Code of Good Practice for Corporate Governance and the Audit and Risk Assurance Committee Handbook, or be represented on the British Library’s sponsor department’s Audit and Risk Committee
• forward the audit strategy, periodic audit plans and annual audit report, including the British Library Head of Internal Audit opinion on risk management, control and governance as soon as possible to the sponsor department
• keep records of and prepare and forward to the department an annual report on fraud and theft suffered by the British Library and notify the sponsor department of any unusual or major incidents as soon as possible
• will share with the sponsor department information identified during the audit process and the Annual Audit Opinion Report (together with any other outputs) at the end of the audit, in particular on issues impacting on the department’s responsibilities in relation to financial systems within the British Library.

32. External audit 

32.1. The Comptroller & Auditor General (C&AG) audits the British Library’s annual accounts and lays them before Parliament, together with their report.  

32.2. If the British Library has set up and controls subsidiary companies, the British Library will, in the light of the provisions in the Companies Act 2006, invite the National Audit Office (NAO) to tender and act as auditor of those company subsidiaries that it controls and/or whose accounts are consolidated within its own accounts.  The Board should consider approaching the C&AG/NAO in the first instance, particularly if the bodies are consolidated within the British Library’s own accounts. If the subsidiary is a company limited by guarantee, then the passage of the order would exempt them from the audit requirements of the Companies Act 2006 under s. 482 of that act. If the subsidiary is a company limited by shares, then the order would require a duplicate audit.

32.3. The C&AG: 

• will consult the department and the ALB on whom – the NAO or a commercial auditor – shall undertake the audit(s) on his behalf, though the final decision rests with the C&AG
• has a statutory right of access to relevant documents, including by virtue of section 25(8) of the Government Resources and Accounts Act 2000, held by another party in receipt of payments or grants from the British Library
• will share with the sponsor department information identified during the audit process and the audit report (together with any other outputs) at the end of the audit, in particular on issues impacting on the Department’s responsibilities in relation to financial systems within the British Library
• will consider requests from departments and other relevant bodies to provide regulatory compliance reports and other similar reports at the commencement of the audit. Consistent with the C&AG’s independent status, the provision of such reports is entirely at the C&AG’s discretion.

32.4. The C&AG may carry out examinations into the economy, efficiency and effectiveness with which the ALB has used its resources in discharging its functions. For the purpose of these examinations the C&AG has statutory access to documents as provided for under section 8 of the National Audit Act 1983. In addition, the British Library shall provide, in conditions to grants and contracts, for the C&AG to exercise such access to documents held by grant recipients and contractors and sub-contractors as may be required for these examinations; and shall use its best endeavours to secure access for the C&AG to any other documents required by the C&AG which are held by other bodies. 

Reviews

33. Review of ALB’s status

33.1. The British Library will be reviewed as part of the wider Public Bodies Reviews programme, at a time determined by the department’s ministers and their PAO. The date of the next review is to be determined and will be agreed between DCMS and CO.

Signatures

Ruth Hannant and Polly Payne
Director Generals
Department of Culture, Media and Sport (DCMS)

Date 22/09/25

Rebecca Lawrence
Chief Executive
On behalf of the British Library

Date 11/09/25

Annex A: Guidance 

The British Library shall have regard to and, where appropriate, comply with the following guidance, documents and instructions unless subject to an explicit exemption as a consequence of their status as a Freedoms Body

Corporate governance

• This framework document

• Corporate Governance Code for Central Government Departments (relevant to Arm’s Length Bodies) and supporting guidance

• Code of conduct for Board members of Public Bodies

• Code of practice for partnerships between Departments and Arm’s Length Bodies

Financial management and reporting

• Managing Public Money (MPM)

• Government Financial Reporting Manual (FReM)

• Relevant Dear Accounting Officer (DAO) letters

• Relevant guidance and instructions issued by the Treasury in respect of Whole of Government Accounts

• The most recent letter setting out the delegated authorities, issued by the parent department.

• The Charities Statement of Recommended Practice (SORP)

Management of risk

• Management of Risk: Principles and Concepts (‘the Orange Book’) and management of risk in government framework

• Public Sector Internal Audit Standards

• HM Treasury approval processes for Major Projects above delegated limits

• Government cyber-security strategy and cyber security guidance

Commercial management

• Procurement Policy Notes

• Cabinet Office spending controls; except where the British Library is exempt under the operational freedoms (see Annex B): 

• Transparency in supply chains - a practical guide

Public appointments

The following are relevant where public bodies participate in public appointments processes.

• Guidance from the Commissioner for Public Appointments

• Governance Code on Public Appointments

• Procurement Policy Note 08/15 – Tax Arrangements of Public Appointees

Staff and remuneration

• HM Treasury guidance on senior pay and reward

• Civil Service pay guidance (updated annually)

• Public sector pay and terms

• Whistleblowing Guidance and Code of Practice

• The Equalities Act 2010

General

• Freedom of Information Act guidance and instructions

• The Parliamentary and Health Service Ombudsman’s Principles of Good Administration

• Other relevant instructions and guidance issued by the central Departments (Cabinet Office and HM Treasury)

• Recommendations made by the Public Accounts Committee, or by other Parliamentary authority, that have been accepted by the Government and are relevant to the British Library

• Guidance from the Public Bodies team in Cabinet Office

• The Civil Service diversity and inclusion strategy (outlines the ambition, to which Arm’s Length Bodies can contribute)

• Guidance produced by the Infrastructure and Projects Authority (IPA) on management of major projects

• The Government Digital Service

• The Government Fraud, Error, Debt and Grant Efficiency function and grant standards

• Code of Practice for Official Statistics

• Accounting Officer System Statements (AOSS are produced by departments with input from ALBs)

Charity law

• Charity Commission guidance for trustees on their main duties under charity law: The essential trustee: what you need to know, what you need to do

• Charity Commission guidance on managing charities (note that some of this guidance will not apply to exempt charities): Managing your charity: detailed information

• Charity Commission guidance on exempt charities (if the ALB does not have the Charity Commission as its principal regulator): Exempt charities (CC23)

• Charity Commission guidance on political activity/impartiality

Annex B: Freedoms Charter (May 2023)

Background

The ‘Operational Freedoms’ are a set of exemptions from, or modifications to, a discrete number of financial and operating requirements applying to a group of arm’s length bodies (ALBs)^{[footnote 17]}. These ‘Freedoms Bodies’ have been granted these flexibilities in recognition of their distinct public-facing role and hybrid public/commercial funding model.

The following set of Freedoms was approved by HM Treasury and Cabinet Office on 26 April 2023. This document is an updated version of the Charter that was previously agreed by those parties and the Freedoms Bodies’ Sponsor Departments in Q1 2022/23^{[footnote 18]}.

It will be reviewed in Q3 2024/25, or at the next Spending Review, whichever is sooner. The Freedoms are extended at HM Government’s discretion and may be paused or withdrawn where circumstances dictate.

Freedoms- at a glance

Financial freedoms

1. Freedom to maintain and spend reserves of self-generated income.

2. Freedom to invest non-grant income.

3. Exemption from the requirement to use the Government Banking Service.

4. The power to borrow through voted loans from sponsoring departments.

5. Favourable consideration of requests for Departmental Expenditure Limit (DEL) cover to meet exceptional depreciation charges.

6. Freedom to offer pay awards in excess of caps set out in the Pay Remit Guidance.

7. Freedom to opt out of the Principal Civil Service Pension Scheme for new starters.

Spend control freedoms

1. Flexibility to opt in or out of central procurement on a case by case basis.

2. Exemption from advertising, marketing, and communications spend controls.

3. Exemption from the commercial spend control.

4. Exemption from property spend controls.

5. Exemption from facilities management spend controls.

Increases to delegated limits

1. Digital and Technology spend.

2. Self-funded capital projects (HMT delegated limit for DCMS Freedom Bodies only).

Financial freedoms

1. Freedom to maintain and spend reserves of self-generated income

HM Treasury will provide Freedoms Bodies with budgetary cover (for both Resource and Capital spend) for the required use of reserves. It will be based on Freedom Body forecasts and made via Supplementary Estimates. The use of reserves in excess of the allocation will be considered an overspend for which Bodies must alert DCMS/relevant department as early as possible.

2. Freedom to invest non-grant income

Freedoms Bodies are free to invest non grant income in line with the relevant Charity Commission guidance on investments.

3. Exemption from the requirement to use the Government Banking Service

Freedoms Bodies are exempt from the requirement to use the Government Banking Service (GBS). They will continue to provide DCMS/relevant department (“The Department”) with the normal monthly forecasts including the amount of cash held in their bank accounts. They should also continue to seek help and guidance from the GBS to help negotiate value for money banking contracts.

Where Freedoms Bodies elect to open non-GBS accounts, formal HM Treasury approval is not required, but Bodies must inform The Department and provide them with balances held in these accounts at set times during the year as communicated to them by the Department.

4. The power to borrow through voted loans from sponsoring departments

Freedom Bodies have the power to borrow to access seed funding which can be used for cost savings measures and to develop revenue raising projects.

Loans will be made available to Freedom Bodies by The Department up to a limit of £60m per year (across all Freedoms Bodies) and no longer than 25 years in length.

DCMS will include all requests within its Supplementary Estimates return to HM Treasury. Freedoms Bodies may request loans during each financial year up until the Supplementary Estimates return is submitted. Cash can however be made available ahead of Supplementary Estimates as HMT approval at Supplementary Estimates is assumed if DCMS provides the necessary approval to the loan request.

Loan requests from Freedoms Bodies will require a single-stage business case submission to be approved by The Department. If the loan request forms part of a larger business case, the request should be incorporated into an appropriate business case stage (although no earlier than Outline Business Case) . The Department will review any loan requests at an appropriate Committee that aligns with the value of the request.

5. Favourable consideration of requests for additional budgetary cover to meet exceptional depreciation charges

In exceptional circumstances, the impact of depreciation may result in a breach of the HM Treasury ring-fenced budgetary total. The Department will ensure it retains sufficient cover for any known depreciation charges and will explore avenues to manage exceptional depreciation charges within the delegated control totals. It may be for example that requests for additional budgetary cover can be made outside of the supplementary estimates window.

In the unlikely event that this is not possible, the Department would ask HM Treasury to look favourably on any breach caused by these circumstances.

Freedoms Bodies should proactively notify their Department if such an event is anticipated, so that HMT can be informed and remedies can be explored.

6. Freedom to offer average pay awards in excess of caps set out in the Pay Remit Guidance

Freedom Bodies are not subject to the Pay Remit Guidance (“PRG”). However they shall continue to engage with their Sponsor Department during the process of making a pay remit application, particularly prior to completion. They shall also continue to provide outturn data to HM Treasury and adhere to all other Civil Service Pay guidance issued by HM Treasury and the Cabinet Office. This freedom can include multi-year pay settlements as long as they are affordable and this does not prejudice future spending reviews.

This Freedom may be paused under extraordinary future circumstances, and should be reviewed as part of Spending Reviews.

7. Freedom to opt out of the Principal Civil Service Pension Scheme for new starters

Bodies may close, or amend the eligibility criteria to restrict access to the Civil Service Pension Schemes (CSPS) for new members. Current active and non-contributory members will be allowed to continue to accrue and receive their respective benefits. The CSPS closes completely once the last active scheme employee leaves the organisation.

The decision to use this Freedom will be taken by the Body’s Board of Trustees.

To take advantage of this Freedom, Bodies should first consult with The Department, setting out the case for the proposed course of action. They must also confirm that:

(a) relevant statutory requirements have been followed; (b) agreed Trade Union/Management negotiating processes have been undertaken as part of the consultation with staff; (c) a reasonable number of alternative pension providers have been considered to ensure good value.

Following this process, the Freedom Body will need to liaise with the Cabinet Office and Government Actuarial Department (GAD). The decision to close, or restrict access to the CSPS to new starters may incur an “exit charge”. This charge will be determined by the GAD, based on the particular circumstances of the Freedom Body, and will take into account current and future scheme liabilities and the impact on the CSPS. The presumption is that the Freedom Body will pay the exit charge from its own funds and/ or reserves, although they may be able to access the voted loans fund for this purpose.

Spend control freedoms

8. Flexibility to opt in or out of central procurement

Freedoms Bodies may decide whether or not to use central procurement for all items of expenditure on a case by case basis. Where centralised procurement deals exist, Freedoms Bodies should satisfy themselves that any contract outside of these arrangements demonstrates better whole life value for money.

9. Exemption from advertising, marketing, and communications spend control

Freedom Bodies are exempt from the Cabinet Office’s central advertising, marketing and communications (AME) spending control.

10. Exemption from the commercial spend control

Freedoms Bodies are exempt from the Cabinet Office’s Commercial spend control approval processes. This does not, however, supersede the requirement to adhere to the Government Functional Standard and other Cabinet Office guidance for those Bodies that make grants using public funding.

11. Exemption from property spend controls

Freedoms Bodies are exempt from the control on property spend, including the requirement to seek approval for all new facilities management contracts and contract extensions.

12. Exemption from facilities management spend controls

Freedoms Bodies are exempt from the spend control on facilities management, enabling them to procure specialist services, and to do so independently and at pace.

Increases to delegated limits (new)

13. Approval for digital and technology spend

All public bodies are required to record all spend in a digital and technology pipeline as part of a joint Cabinet Office / departmental assurance review process. The control applies to digital spend over £100,000 and technology spend over £1 million.

For Freedoms Bodies, this threshold is increased to £10m for both digital and technology spend. This threshold will be reviewed as part of review of wider freedoms - in Q3 2024/25, or at the next Spending Review, whichever is sooner.

14. Approval for self-funded capital projects (DCMS Freedom Bodies only)

HM Treasury has increased DCMS’ Delegated Capital Expenditure Limit from £30m to £60m for majority-self-funded ALB capital projects. This avoids the requirement of Treasury Approval Points for any projects below £60m, but does not negate the requirement for DCMS approval.

Freedoms retired

The final group of Freedoms may be more accurately described as ‘service level agreements’ (SLAs). They were intended to help streamline the process of complex approvals processes for Freedoms Bodies. Following a review of these commitments, they were found to be largely redundant or irrelevant. As such they will be replaced in the manner described below.

• HM Treasury commitment to respond to capital business cases within 28 days, and training to ensure business cases are proportionate and cost-effective.

   - To be replaced with departmental-led guidelines which clarify businesses case clearance processes, roles and responsibilities; these may include response time Service Level Agreements (SLAs).

• Cabinet Office commitment to respond to redundancy and restructuring applications within two business days.

   - To be replaced with departmental-led process maps which clarify roles and responsibilities; these may include response time SLAs.

• Pre-application guidance from HM Treasury to reduce the administrative burden from severance payment business cases and to achieve quicker decisions.

   - To be replaced with departmental-led process maps which clarify roles and responsibilities; these may include response time SLAs.

Schedule 1: List of Freedom Bodies

Department for Culture, Media & Sport (DCMS)

British Museum

Horniman Museum and Gardens

Imperial War Museums

Museum of the Home

National Gallery

National Museums Liverpool

National Portrait Gallery

Natural History Museum

Royal Armouries

Royal Museums Greenwich

Science Museum Group

Sir John Soane’s Museum

Tate Gallery

V&A Museum

Wallace Collection

British Film Institute

Historic England

British Library

Churches Conservation Trust

Department for the Environment, Food and Rural Affairs (Defra)

Royal Botanic Gardens Kew

Ministry of Defence (MOD)

National Army Museum

National Museum of the Royal Navy

Royal Air Force Museum

Schedule 2: List of Sponsor Departments

Department for Culture, Media & Sport (DCMS)

Department for the Environment, Food & Rural Affairs (Defra)

The Ministry of Defence (MOD)

Annex C: DCMS Commercial Activities and Reporting Requirements

The following outlines in full the commercial requirements of DCMS ALBs, as well as a list of mandated reporting requirements. This document provides additional detail to ALBs Framework Documents, in order to support their compliance with commercial and procurement requirements.

A: Commercial requirements

Public Procurement Regulations

1. The ALB will comply with and ensure its procurement policies are aligned with and comply with any relevant UK or other international procurement rules and in particular the current Public Procurement Regulations (For Example but not exclusive to Public Contracts Regulations 2015 and Procurement Act 2023). Further, as a Central Government Authority, the ALB is subject to certain thresholds when tendering for a procurement opportunity.

Central government policy and processes

2. The ALB shall acquire goods and services through fair and open competition, in accordance with the Government Commercial Operating Standards (including the Outsourcing Playbook), delivering value for money through procurement, and operating in line with UK and other international law, including restrictions on state aid/subsidy controls.

3. Subject to the exemptions listed (‘Freedoms’) at Annex B, the ALB shall comply with current and future requirements on additional spend controls, delegated authorities and authorisations on procurement and leases as notified to them by the Department.

4. The ALB shall not be required to comply with the Cabinet Office Learning and Development Spend control Guidance, nor any of the caps or restrictions set out in it.

5. ALBs designated as a freedom body have flexibility to opt in or out of central procurement on a case by case basis. However, where possible and appropriate, the ALB shall utilise whichever Crown Commercial Services frameworks are relevant to its needs..

6. The ALB must support the wider Government Commercial Function’s strategies and programmes in their design, implementation and sustained application.

7. The ALB must embed all applicable current and future Procurement Policy Notes into its commercial operations. In particular, the ALB must:

• Support the Government’s SME agenda through appropriate procurement activity where this does not conflict with the ALB’s charitable or Freedom body status.

• Promote the inclusion of the Social Value Act and its associated principles in procurement activity wherever possible.

• Comply with Government transparency policies and commitments.

8. Support Commercial Procurement and Contract Management improvement and oversight initiatives including:

• Contract Classification for all contracts

• Internal spend control assurance and governance processes, aligned to the department and Cabinet Office Commercial Spend Control approval processes (subject to exemptions detailed at Annex B - ‘Freedoms’)

• Pipeline reporting where relevant

• Assurance and audit implementation and reporting

• Contracts Finder compliance reporting

• Contract KPI reporting for external public publication

• Commercial Systems and Data improvement initiatives eg. CASIE

9. Attend Cabinet Office training programmes designed to raise commercial awareness and improve commercial capability, including Playbook and GCOS masterclasses, and Contract Management Capability Training.

Departmental policy and processes

10. Subject to the exemptions listed (‘Freedoms’) at Annex B, the ALB shall comply with departmental spend controls as set by DCMS Commercial.

11. In procurement cases where the British Library is likely to exceed any applicable delegated authority limit, procurement strategy approval for the specific planned purchase must be sought from the DCMS Commercial Director.

12. Direct Award Contracts: The ALB must notify DCMS a minimum of 48 hours in advance of its intention to award a direct award contract the value of which exceeds the threshold set out. These requirements do not apply to purchases for collections, acquisitions, core public offerings, or subscriptions that support these (e.g. subscriptions to unique journals).

13. The ALB must adhere to requirements of its charitable status (where relevant), and inform the DCMS Commercial Director if there may be a conflict with public law and its charitable status.

Collaborative initiatives

The ALB shall:

• Support all Commercial Procurement and Contract Management improvement and oversight initiatives from DCMS and the Cabinet Office.

• Support collaborative procurement and commercial efforts across the department and its ALBs. This will include supporting the establishment of a DCMS Commercial Council or similar body, where such a group has been instituted, and wider commitments to support knowledge-sharing and training for staff involved in Commercial and Procurement activity across DCMS ALBs.

• Support the formation and ongoing activities of a commercial function across the DCMS family of public bodies, through engagement with the DCMS Commercial team.

• Engage with department and Government wide procurement initiatives that seek to achieve VfM from collaborative projects.

Grants and other bodies

14. If applicable, the British Library shall comply with the government functional standard for the management of grants. These standards set expectations for the management of grants, and to promote efficient and effective grant making to ensure funding is used as intended and provides value for money through high quality delivery.

15. In circumstances where the ALB finds itself having oversight and assurance of other public bodies or the procurement activities of private bodies spending public money the ALB shall ensure, as far as is reasonably practicable, and in so far as it has legal authority to do so, that all such parties adhere to the principles of Managing Public Money including the encouragement of transparent and robust practices and compliance with any applicable law.

Management Information and Compliance

16. The Department and the British Library are committed to sharing information to ensure transparency and alignment.

17. The British Library recognises that the Department will at times need to request information on an ad hoc basis and/or with a short time frame as required. The British Library must (within any reasonable timescale required by DCMS) supply any information requested by DCMS, and should proactively seek to provide DCMS with advance sight of events and publications which the Government would take an interest in.

18. In addition to this ad hoc information and open lines of communication, DCMS expects the British Library to provide regular information as listed below at Part 2 (reporting requirements). The list is not definitive, and intended to enable advanced planning for periodic Departmental commissions.

B. Reporting requirements - Freedom Bodies

Commission title

Timescale

DCMS lead team

Purpose

Consultancy Spend Control pipeline and compliance return (including nil returns)

Quarterly

Commercial

For DCMS and the Cabinet Office to plan and keep track of the public sector consultancy contracts and approvals

Commercial Spend Control Pipeline return (including nil returns)

Quarterly

Commercial

For the submission of the Departments quarterly Commercial Spend Control pipeline to Cabinet Office in accordance with Cabinet Office guidelines

Contract register

To be kept updated and accessible if requested by DCMS

Commercial

For oversight of commercial liability and risk across sectors, categories and suppliers, if a contract register is available.

Government Commercial Operating Standards (GCOS) return

If required / requested

Commercial

For the submission of the Department’s Government Commercial Operating Standards (GCOS) return and update against improvement plans.

Contracts finder compliance report

Six months

Commercial

Transparency policy compliance reporting

Submission of procurement spend transactions to Bravo

Annually

Commercial

To comply with Cabinet Office spend reporting requirements

Government Key Contracts Public KPIs return (including nil responses if not on CCS)

If relevant - quarterly

Commercial

For the submission of the Department’s quarterly Key Contracts Public KPIs return to the Cabinet Office

Procurement pipeline for publication return (including nil responses if not on CCS)

Quarterly

Commercial

For the submission of the Departments quarterly pipeline return for publication on .Gov.uk

Social Value reporting return

If required / requested

Commercial

To comply with Cabinet Office policy on Social Value reporting. Specifically at (a) pipeline (b) procurement strategy (c) Contract award (d) contract close subject to PPN06/2020

Prompt Payment reporting for contracts

Annually

Commercial

To ensure accurate reporting to Cabinet Office of in-scope contracts including any exclusions and exemptions requested

Return for the review of key metrics, targets and reports related to procurement, contract management and commercial resourcing

Quarterly

Commercial

To benchmark procurement spend, compliance assessment to policy and provide data on economic effect of spend by Departments and PBs including 3rd party spend and commercial risk reporting.

Direct and Indirect SME spend

Quarterly and Annually

Commercial

To support the Government’s SME Agenda and the DCMS SME Action Plan

C. Delegated financial limits

All delegations are subject to the requirement that spending proposals falling within Managing Public Money Annex 2.2, box A.2.2C should be referred to DCMS. These are:

• Items that are novel, contentious, or repercussive, even if within delegated limits

• Items that could exceed the agreed budget and Estimate limits.

• Contractual commitments to significant spending in future years for which plans have not been set. Appropriate planning should be carried out to account for DCMS & HMT approval if required.

• Items requiring primary legislation (e.g. to write off NLF debt or PDC)

• Any item which could set a potentially expensive precedent

• Where Treasury consent is a specific requirement of legislation. Please refer to Managing Public Money and Framework Agreements for further detail.

A breakdown of delegated financial limits can be found in the delegations letter, issued by DCMS to ALBs annually shortly after the start of each financial year.

1. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1000670/MPM_Spring_21_with_annexes_080721.pdf ↩

2. https://www.gov.uk/government/publications/corporate-governance-code-for-central-government-departments-2017 ↩

3. https://www.gov.uk/government/collections/functional-standards ↩

4. https://www.gov.uk/government/publications/charities-sorp-2005 ↩

5. https://www.gov.uk/government/publications/arms-length-body-sponsorship-code-of-good-practice ↩

6. https://www.gov.uk/government/publications/partnerships-with-arms-length-bodies-code-of-good-practice ↩

7. https://www.gov.uk/government/publications/orange-book ↩

8. https://www.gov.uk/government/publications/code-of-conduct-for-board-members-of-public-bodies ↩

9. https://www.gov.uk/government/publications/the-7-principles-of-public-life ↩

10. https://www.gov.uk/government/publications/public-bodies-non-executive-director-principles/12-principles-of-governance-for-all-public-body-neds ↩

11. https://www.gov.uk/government/publications/commercial-operating-standards-for-government ↩

12. https://www.gov.uk/government/publications/grants-standards ↩

13. http://www.hm-treasury.gov.uk/orange_book.htm ↩

14. https://www.gov.uk/government/publications/government-functional-standard-govs-013-counter-fraud ↩

15. https://www.gov.uk/government/publications/civil-servants-terms-and-conditions ↩

16. https://www.gov.uk/government/publications/public-sector-internal-audit-standards ↩

17. Refer to Schedule 1 at the end of this document ↩

18. Refer to Schedule 2 at the end of this document ↩