Interactive Ontario’s mandate to promote the growth of Ontario’s interactive digital media industry includes a strong focus on advocacy at all levels of government. We are constantly working to ensure that the unique needs of our sector are considered when policy decisions are made.
Our advocacy work is informed by feedback from our members and input from our Advocacy Committee. See below for more information on our advocacy efforts surrounding key issues and please note Action Alerts where we are requesting participation from IDM companies.
Ontario Interactive Digital Media Tax Credit
In the fall of 2014, the Ontario government announced a review of the Ontario Interactive Digital Media Tax Credit. During this process, Interactive Ontario took part in numerous meetings with the Ministry of Tourism, Culture and Sport; the Ministry of Finance, the Treasury Board and the Premier’s Office. We were pleased with the outcome in the next provincial budget, with the OIDTMC rate left unchanged and guidelines changed to reduce “outliers” accessing the credit for products outside of its intended use.
Concerns remained around some of the new guidelines, so Interactive Ontario continued to collaborate with the government on issues such as:
- Promoting changes to filing deadlines in order to reduce the queue and improve cash flow predictability for IDM companies
- Promoting changes to regulations that would allow for collaboration between companies
- Ensuring a fair transition period to new 80/25 labour expenditure guidelines so as not to punish companies who had structured projects to match the previous 90% rule
- Clarifying the “standalone” product definition and raising concerns that it unintentionally punished work-for-hire products hosted on broadcaster websites
Ontario Culture Strategy
Interactive Ontario submitted comments during the development of the Ontario government’s first Culture Strategy. Our submission can be viewed here.
Interactive Ontario attends in-person budget consultations to help ensure that programs like the Interactive Digital Media Fund and others are sufficiently funded.
CAVCO – ‘Shown in Canada’ eligible platforms
In the spring of 2016, the Canadian Audio-Visual Certification Office issued a call for comments on proposed changes to eligible platforms for the ‘shown in Canada’ requirement. The changes were designed to allow audio-visual productions whose distribution is exclusively via online platforms (including through mobile video services) to be eligible for the Canadian Film and Video Production Tax Credit (CPTC), provided that the rights have flown through a Canadian distributor to the entity showing the production in Canada.
Interactive Ontario welcomed this as a first step towards much-needed improved funding for digital-first linear video content, but also said that the regulations should be further amended to allow producers of self-distributed content to access the tax credit. This would bring policy into line with new business models and viewing habits of consumers in the digital era, who no longer distinguish between CRTC-licensed and non-CRTC-licensed content providers. Read our full submission here.
Canada Media Fund
There are no major changes anticipated for the 2017-18 fiscal year, other than a re-allocation of $2 Million within the Experimental Fund to fund linear web series. However, CMF is looking to shift more funds increasing from the Innovation Program to the Commercial Projects Pilot Program. We will be monitoring that shift and the response to C3P, to identify any possible negative consequences for IO members.
As well, the CMF is looking to make changes to the Convergent Fund over the coming years that will impact how convergent digital media will be funded. They are looking to phase out the Digital Media Factor Weight in the calculation of broadcaster envelopes and replace that incentive with added funding to a revamped Convergent Digital Media Incentive. IO will be talking to CMF staff over the next year to minimize any negative impact on convergent digital media producers.
Interactive Ontario Executive Director Christa Dickenson is chair of our federal counterpart, the Canadian Interactive Alliance / Alliance Interactive Canadienne. CIAIC’s membership is comprised of Canada’s seven existing provincial interactive digital media trade organizations: Alliance Numérique, DigiBC, Digital Alberta, Interactive Ontario, New Media Manitoba, Nova Scotia Game Developers Association and SaskInteractive.
Advocacy matters involving federal departments are submitted via the CIAIC. Learn more about those efforts below.
Interactive Ontario actively encouraged members to submit their thoughts on Canadian Heritage’s Canadian Content in a Digital World consultations. We gathered feedback and ideas through a variety of methods, including a Twitter chat and Advocacy Committee meetings, in order to contribute to the CIAIC’s submission.
Certified Independent Production Funds
Recently, the CRTC released a new framework for Certified Independent Production Funds (CIPFs) on August 25, 2016 (CRTC 2016-343), implementing changes effective September 1, 2016. It contains ambiguous wording that affects the funding of digital media projects as it determined that the Commission would ‘maintain a 10% limit on funding that can be allocated to non-programming digital content’. Previously that 10% cap (which is 10% of the revenues that a fund receives from cable and satellite companies) was only for standalone digital media and there was no cap on digital media affiliated with television programming.
The Bell Fund confirmed with the CRTC that it intends to enforce a 10% cap on funding for all digital media (both affiliated with television and standalone).This new rule would devastate the mandate of the Bell Fund, Telus Fund and Quebecor Fund and prevent the Shaw Rocket Fund from having its digital fund. Digital-first linear video could still be funded as CIPFs are no longer required to demand a broadcast licence for eligibility but any media that incorporates interaction would have to fit within the 10% cap.
The Bell Fund made two requests to the CRTC, which the CRTC posted for comment. It is requesting a one-year transition period to give companies time to fully understand the ramifications of these changes, and the Bell Fund time to adjust its funding programs and guidelines. It is also requesting an increase in the 10% cap to a more reasonable level.
Interactive Ontario met with the CRTC to discuss the potential impact of these CIPF changes on Canada’s digital media industry and contributed to the CIAIC’s submission in support of the Bell Fund’s letter.
The Ministry of Innovation, Science and Economic Development issued a call for ideas regarding Canada’s Innovation Agenda. The CIAIC response included a number of ways the IDM sector can continue to help position Canada as a global leader in innovation. These included:
- Reducing barriers to collaboration, within IDM and across sectors
- Mechanisms to encouraging risk-taking, such as a tax credit claimed on an annual basis for labour expenditures on innovative products, regardless of the eventual completion or financial success of the project
- Funding for companies engaged in the production of content that is awarded on an enterprise, rather than per-project, basis