Nehl frames cultural policymaking as infrastructuring, a concept borrowed from infrastructure theory that foregrounds the invisible, overlooked and taken-for-granted structures facilitating smooth everyday experiences. Infrastructures are never simply there; they are made and held stable through continuous work and changing ways of connecting people and things in socio-material relations. Cultural infrastructure, in this reading, includes buildings, facilities, spaces, practices, funding and legal frameworks, personal and institutional networks as well as social media sites. Nehl adds cultural policy itself to this list, since policy prescribes and shapes cultural practices and thus forms part of infrastructuring as both product and process. The availability of infrastructure components like a discursive policy framework, a building or a social network alone does not turn into supporting infrastructure without the continuous labour of cultural actors that enables involvement in policymaking in the first place.

The study situates CCSC within the architecture of EU cultural governance, where the subsidiary principle has always limited the EU’s role in culture. The Maastricht treaty of 1992 made culture a competency, and the Lisbon treaty of 2007 recognised the cultural and creative industries as a competitive economic factor, legitimising soft intervention through recommendations, guidelines and best practices rather than binding law. Funding programmes like Kaleidoscope, Culture 2000 and, most prominently, Creative Europe support these soft policy tools, with cultural networks acting as intermediaries that connect local actors to the transnational policy level. Policy coordination mechanisms like structured dialogues and the open method of coordination allow more strategic involvement in the cultural sphere, while broad and flexible concepts like creativity accommodate both commercial and non-commercial activity, aligning with the Lisbon agenda.

Yet the agency of cultural actors within these processes remains contested. Independent cultural actors, and especially smaller-scale, alternative actors, identify a tension between their situated perspectives and broader policy framings that risk marginalising the needs of art and cultural production. Policies uninformed by the realities of cultural small-scale producers or less central venues are perceived as ill-fitting, producing irritation and suspicion and ultimately hindering the collaboration that policymakers themselves seek. Research has further traced how networks, initially envisioned as tools for enhancing participatory policymaking, have paradoxically contributed to a form of standardisation that mutes dissent, complicating the political essence of cultural dialogues within the EU.

CCSC was composed of a consortium of eleven non-profit and public organisations, led by Trans Europe Halles, one of the oldest European cultural networks, established in 1983. The project partners included the University of Antwerp, the European Cultural Foundation and Timelab Gent. The methodology was built on the idea of local urban labs, where participating actors define, develop and test new methods and tools. Cultural centres Hablarenarte in Madrid, Ambasada in Timisoara, Kaapeli in Helsinki, the social innovation lab Coboi Lab in Sant Boi de Llobregat, Creative Industries in Kosice, and the public administration City of Lund as well as the cultural administration of the Scania region joined the project. During the three years, the local labs worked on their challenges through twenty-one workshops between May and December 2019, organised traineeships and urban explorations, and exchanged knowledge in policymaking events and a digital conference in early 2021.

To unpack the different stakeholders’ problem representations, Nehl draws on Carol Bacchi’s critical policy methodology entitled What’s the problem represented to be? The WPR approach conceptualises policy not as pregiven problems but as a set of problematisations, addressed through six guiding questions that foreground how power, knowledge and discourse are simultaneously shaped by, and productive of, social worlds. Policy documents are understood as purposefully produced artefacts through which actors seek to represent problems, solutions and roles. Combined with interpretive policy analysis, the approach is sensitive to the perspectives and interpretive frameworks of both analysts and stakeholders, foregrounding the interlinked knowing and doing and advocating for a practice-orientation attentive to how policymakers and administrators act in complex, unpredictable situations. Nehl applied the first, second, fifth and sixth questions primarily, with the fourth question engaged to a smaller but significant degree in the concluding discussion.

The analytical process was an infrastructuring-informed, software-supported abductive coding process. The first rounds of descriptive coding provided an overview and captured all participating actors, revealing actor constellation changes like the P2P foundation leaving for Timelab, a makerspace brought in to assist the methodological aspects of the project. In later coding, closely linked to the WPR questions, the in vivo code art versus system, found in an agenda-setting document from the first CCSC meeting in Brussels, shaped the inquiry. Based on this strong binary construction in the early project data, Nehl continued with versus coding, which serves policy studies attending to conflicts between individuals, groups, social systems, organisations, phenomena, concepts or processes. The coding was further sensitised by actors’ needs to unpack what the different CCSC stakeholders considered infrastructural.

The results reveal that the disconnect between cultural actors and administrative bodies in CCSC is articulated as a gap that occurs between different stakeholders and levels of governance. Whether at the urban, regional or EU level, a gap is palpable between public authorities and local cultural initiatives. Cultural actors report a feeling of distance from the EU institutions, and the lived experience of this distance between policy recommendations and real actions underlines the need for revised methods to include cultural stakeholders in policymaking. The project charter asserted that the gap between citizens and institutions can be narrowed and democratic legitimacy strengthened, positioning the urban labs as spatial solutions to address this widely experienced disconnect. The labs were framed as spaces of encounter where interactive policymaking practices are often the first instance where people who share a particular space actually meet.

However, the analysis exposes how bottom-up demands reverberate around problem formulations of a structural gap while the CCSC project simultaneously highlights a disconnect between EU-level framings of empowerment and the infrastructural needs exemplified by local cultural actors seeking recognition and systemic support for the work they already do. The project recommendations warned that neglecting social rights, precarisation, marginalisation and lack of security in many sectors, including the cultural sector, is a major barrier for participation. Participation was framed as proper labour but without remuneration, and the recommendations cautioned of exclusions affecting people and places lacking political recognition, financial stability or temporal resources, summarised as the cost of participation. In Timisoara, relations with the municipality were described as antagonistic and far from being based on principles of co-creation and participation, while in Sweden two public administration-led labs aimed to strengthen bottom-up participation, facing a reversed dilemma where non-participation was problematised as a lack of space of encounter and empowerment.

The study concludes that future EU cultural policy should more explicitly recognise and support the infrastructural labour that enables soft governance. The discursive sidelining of Trans Europe Halles’ central role as facilitating intermediary and advocate of participating cultural actors raises critical questions about what responsibilities fall on networks acting as intermediaries and what resources they require to fulfil their role as versatile intermediaries. Within the infrastructuring heuristic, it is perhaps not surprising that the work of facilitation remains invisible, especially in officially published reports. Yet the networks’ needs, as well as the risks and benefits entangled in the interdependency of cultural networks with large EU-funded projects, call for attention in further scholarly work, especially since Creative Europe, the most important funding body for networks, can no longer be taken for granted as it is being integrated into the new AgoraEU funding programme for 2028 to 2034. Sustaining bottom-up cultural engagement and democratic participation requires more than empowering EU policy; it calls for enabling frameworks that integrate implicit cultural needs into explicitly social cultural policy frameworks, moving beyond temporary arenas to improve structural conditions for participation, recognition and care.

Subject of Research: Cultural Policy Research

Article Title: Infrastructuring cultural policy: the case of Creative Europe’s “Cultural and Creative Spaces and Cities”

Article References: Nehl, M. (2026). Infrastructuring cultural policy: the case of Creative Europe’s “Cultural and Creative Spaces and Cities”. European Journal of Cultural Management and Policy, 16, Article 15478. https://doi.org/10.3389/ejcmp.2026.15478

Image Credits: AI Generated

DOI: 10.3389/ejcmp.2026.15478

Keywords: cultural policy, Creative Europe, cultural networks, infrastructuring, soft governance, participation, precarity, Trans Europe Halles, discourse analysis, EU policymaking, cultural, policy