The EGDF statement on the support for concept and project development of video games under Creative Europe.

The national support schemes for video games are often realised either through tax incentives or through technology and innovation funding. Consequently, European funding for the creation of digital content itself brings significant added value and enables the realisation of culturally ambitious projects pushing the artistic limits of interactive storytelling otherwise too risky to be completed.

For this reason the Creative Europe funding scheme for video games is especially important for the members of the European Games Developer Federation (EGDF) which represents about 600 EU games development studios. Consequently, EGDF both actively disseminated the call to its members and collected feedback from them. In their feedback, the members of EGDF highlighted the following challenges that we now wish to bring forward.

How the eligibility criteria should be reviewed:

  • Activities related to project dissemination activities should be included in the eligible cost
    According to the current guidelines, every project is required to have a clear and strong strategy for communication and dissemination. However, the dissemination costs are not included in the list of eligible costs. Including reasonable dissemination costs in the eligible costs both would increase the visibility of the Creative Europe funding instrument and encourage game developers to start dissemination activities early on in the project that is crucial for the commercial success of the projects. Therefore we propose that the dissemination cost be included with a ceiling of 20% of the total costs.
  • Gameplay should be THE cultural eligibility criteria, not the narrative component
    The current guidelines state that the digital content must provide substantial interactivity with a narrative component in order to be eligible for EU funding. A good game is an innovative and highly creative combination of a wide range of cultural contents. Game music, game design, audiovisual storytelling and graphic design are all tight together by gameplay. Consequently, making the narrative component the sole eligibility criteria significantly downgrades many other key cultural features in a game.As a matter of comparison, the European public funding instruments for literature do not exclude poetry under the pretext that it does not have a “significant” narrative component. Neither is narration a key eligibility criteria for public funding for music composers. Similarly, a narrative component should only be one eligibility criteria for public funding for games. We propose that gameplay, in its broad meaning as a combination of narrative, art, audio, design, music and technical creativity, should be the key criteria used.
  • Proven track record should be based on the team experience or crowd support
    It is completely understandable that the European Union wants to direct its funding to projects that have the best track record and thus the best chances to become commercial successes. However, the current guidelines are too narrow to reach this goal.Some of the most successful game development studios in Europe are second round start- ups, composed in many instances by highly experienced individuals. They are companies that are built around a unique team with cutting-edge talent and long industry experience. These are the companies that have the highest changes to succeed. Therefore we propose that if the key team members have experience on producing games, this experience itself be considered as an alternative eligible evidence on the proven track record.Secondly, the current requirements of published games, make it impossible for newly established but highly promising studios that have proven their high market potential with successful crowdfunding campaigns to apply the funding scheme. Consequently, we also propose that a studio having obtained at least 10 000 € of crowdfunding should be considered as having a sufficient track record to be eligible to the scheme.
  • The key terms should be clearly defined:
    Currently, some key concepts are only vaguely defined in the guidelines. The “commercial distribution”, for example, should be clearly defined as a game that has a monetisation element in it. We also propose that all games that are backed by at least 10 000€ of crowdfunding to be eligible for prototype funding, as the crowdfunding itself is an essential element of the business model.In addition, the difference between the creation of the content and production costs should be clearly defined.

The funding rates should be updated:

  • There should be a specific indirect cost rate for small enterprises
    At the moment, indirect cost rates are the same for both SME’s and non-SME’s applying the funding. Where for a non-SME artistically ambitious and commercially risky project funded by a creative Europe project is just another project in their portfolio, for a SME the project is often one of their few or the only project they are running in the company. Consequently, the indirect costs associated with the project are much higher for a SME than for a non-SME. Consequently, we propose that SME’s should have the same rate as in the Horizon 2020 programme, thereby 25%.
  • 150 000 € is not enough funding for a cutting edge AAA console game prototypes
    Game prototypes, especially on the console game side, are getting more and more expensive. Project budgets financed by publishers commonly reach 20 million, and be as high as 40 million euros, and prototypes cost at least 1% of the final budget to make. Consequently, we propose that the maximum EU contribution to prototype funding to be increased to at least 200 000€.

The call process should repaired:

  • The deadline should be unambiguousAt the moment, the deadline for applications is at 12:00 (noon) at Brussels time. This has caused unnecessary misunderstandings, as some applicants misread the deadline to be at 12:00 (midnight). We propose that the deadline for applications be at 1 pm CET, or at the end of the office day, to avoid any misunderstanding.
  • The application form should be rewrittenThe current application form is clearly based on film funding forms. Consequently, it should completely be rewritten to reflect the requirements set in the video game call. An excellent example of the film centric approach is the following question: “Over a three year period has the applicant company received more than 90% of its turnover from the same broadcaster?”There are no broadcasters in video games. This question is almost completely irrelevant to the games industry and it should thus be removed.
  • Applicants should be encouraged to add concepts art in an application and the length of the applications should be limited
    The current application form does not really encourage game developers to add concept art in the application. This significantly hinders the artistic evaluation and therefore some concept art pictures should be required.Furthermore, there should be a clear limit for the maximum length of an application.
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