As a general principle, Pearle* welcomes the European Commission's initiative to simplify the GBER and reduce administrative burdens for Member States and beneficiaries. Simplification of State aid rules can indeed increase efficiency, transparency, and legal certainty. However, we would like to highlight that in the pursuit of simplification, it is essential to safeguard the achievements of past reforms, particularly the cultural exemption, which has ensured a balanced and workable framework for the live performance sector.

The live performance sector depends significantly on public support to fulfil its cultural mission, ensure access to culture, and contribute to social and economic development. The introduction of a horizontal block exemption for cultural subsidies, combined with proportionate thresholds for operating aid and for investment aid, has been vital in reducing unnecessary notification burdens while maintaining transparency and control. In line with the Commission’s practice of regularly adapting thresholds, and in view of the ongoing objective of simplification, we would encourage the Commission to further increase the thresholds for culture as from 2027in line with inflation since the last update of 2023 [1].

In the context of the upcoming revision, we caution against any streamlining that would inadvertently weaken or narrow the existing cultural exemption. While simplification should remove overly complex or inconsistent provisions, it must not lead to fewer exemptions or lower thresholds for the cultural sector. Any rollback would risk reintroducing heavy administrative procedures, delay much-needed funding, and create legal uncertainty for cultural organisations and public authorities alike. On the contrary, the revision offers an opportunity to reinforce the clarity and usability of cultural provisions, ensuring that the specificities of the sector remain fully recognised.

In conclusion, we encourage the Commission to ensure that simplification efforts preserve the balance achieved by the current framework and do not reduce the scope of exemptions for the cultural sector. At the same time, we invite the Commission to adjust the thresholds to reflect inflation, thereby ensuring that the cultural exemption continues to provide legal certainty, proportionality, and effective support for the arts. Safeguarding and strengthening the cultural exemption must therefore remain a central element of the revised GBER.

[1] Commission Regulation (EU) 2023/1315 of 23 June 2023