The Bill & Melinda Gates Foundation is one of the world’s largest private funders of global health and development research, and its open-access policy has long been treated as a bellwether for how funders enforce access mandates. The foundation confirmed a substantial policy refresh, effective for manuscripts arising from its funding starting January 1, 2025, that tightens the preprint and licensing requirements already in place and, most notably, removes financial support for article processing charges (APCs). This guide covers exactly what the 2025 policy requires, what changed from the prior (2021) version, and how grantees and their institutions can stay compliant.
What the 2025 policy requires
The current policy applies to peer-reviewed manuscripts (and preprints of those manuscripts) arising “in whole or in part” from Gates Foundation funding, for grants awarded from January 1, 2015 onward, with the refreshed terms taking effect for manuscripts as of January 1, 2025. Three requirements sit at the center of it:
- Mandatory preprint posting. Grantees must post the manuscript as a preprint “as soon as possible and to the extent feasible,” on a preprint server the foundation recognizes or a preapproved server that applies “a sufficient level of scrutiny” to submissions. The policy carves out a narrow exception: grantees may forgo posting a preprint where they determine one is not appropriate “due to ethical, safety, or other legitimate concerns” (for example, some clinical or sensitive-population research).
- Immediate open licensing under CC BY 4.0. Both the preprint and the final peer-reviewed version must be freely available immediately, with no embargo period, under a Creative Commons Attribution 4.0 International license (CC BY 4.0) or an equivalent license. This extends to any subsequent updates to a manuscript’s key conclusions, not just the original version of record.
- No foundation funding for APCs. This is the headline change. The foundation states plainly that it “will not pay Article Processing Charges (APCs)” — publication fees are now the responsibility of grantees and their co-authors, or must be covered through routes that don’t rely on foundation grant funds.
The policy scopes out certain outputs: opinion-type works such as white papers and policy positions are explicitly excluded from the mandate.
What changed from the 2021 policy
The foundation’s open-access mandate has existed in some form since 2015 and was updated in 2017 and 2021 before this refresh. The prior (2021) version already required immediate CC BY licensing with no embargo — that part is unchanged and, in fact, predates most funder mandates of similar strictness, including Plan S. What’s new in the 2025 refresh is the combination of (1) an explicit, affirmative preprint-posting requirement rather than an encouraged practice, and (2) the elimination of APC funding support. Under the 2015 and 2021 policies, the foundation made funds available to help cover open-access publishing fees; that financial support is removed under the 2025 terms. Coverage from Scholarly Kitchen at the time the refresh was announced characterized it as simultaneously increasing the compliance burden on grantees (via the preprint mandate) while removing a funding mechanism they had previously relied on.
Why the foundation dropped APC funding
The foundation’s own guidance frames the change as a push toward publishing routes that don’t depend on per-article fees at all — green open access via preprints and repositories, diamond/no-fee journals, and negotiated no-APC arrangements with individual publishers — rather than simply asking grantees to find APC money elsewhere. Alongside the policy refresh, the foundation has backed such arrangements directly: for example, it has supported PLOS with grant funding specifically so that Gates-funded researchers can publish in PLOS journals without incurring an APC through a multi-year partnership. Grantees should treat this as the intended compliance path for gold open-access venues, not as a one-off exception.
How grantees can comply
- Post a preprint immediately on submission (or as close to it as feasible). Use a server the foundation recognizes and applies real screening to — see CASRAI’s preprint servers guide for how these platforms differ and what “screening” typically means in practice.
- Confirm the license on both the preprint and the final version is CC BY 4.0 (or a license the foundation accepts as equivalent) before submission, not after acceptance — retrofitting a license after a publisher has already applied its own default terms is a common source of non-compliance.
- Route around APCs rather than budgeting for them from Gates funds. Options include self-archiving via the green open-access route, submitting to no-fee (diamond) venues, using an existing no-APC publisher partnership, or checking APC waiver eligibility where a publisher offers one. Where an institution has a read-and-publish agreement that already covers the fee, that can also satisfy compliance without drawing on grant funds — confirm this with the institutional library before submission.
- Track compliance actively. The foundation states that compliance “will be continuously reviewed” and that grantees and authors are contacted directly when found non-compliant. Research offices administering Gates funding should build a manuscript-tracking step into grant closeout rather than relying on authors to self-report.
How this compares to other major funder mandates
The Gates policy sits at the strict end of funder open-access mandates, alongside the Wellcome Trust’s open access policy and Plan S/cOAlition S funders: all three require immediate CC BY licensing with no embargo. Where Gates now diverges most sharply is the explicit removal of APC funding support combined with an affirmative preprint mandate — Wellcome and most Plan S funders still permit grant funds to cover APCs at compliant venues, and treat preprinting as encouraged rather than required in the same absolute terms. Researchers who hold funding from multiple such funders on a single manuscript should apply whichever mandate is strictest on each dimension (license, embargo, and now APC funding), since satisfying the strictest requirement generally satisfies the others as well.
Frequently asked questions
Does the 2025 policy apply retroactively to grants awarded before 2025?
The policy applies to manuscripts arising from grants awarded from January 1, 2015 onward, with the refreshed 2025 terms governing manuscripts as of the January 1, 2025 effective date — so it is the manuscript’s timing, not the grant’s original award date, that determines which version of the policy applies.
Can a grantee still get help paying an APC from the Gates Foundation?
No. The foundation states directly that it will not pay APCs under the 2025 policy. Grantees need to use a no-fee venue, a green/preprint route, an existing no-APC publisher partnership, an APC waiver, or a separately funded read-and-publish agreement instead.
Is there any exception to the preprint-posting requirement?
Yes, a narrow one: grantees may forgo a preprint where they determine posting one is not appropriate due to ethical, safety, or other legitimate concerns.
Does the policy cover datasets or only manuscripts?
This policy is specifically an open-access publishing mandate covering manuscripts and preprints. The foundation has separate expectations around data sharing; grantees should check their individual grant agreement and the foundation’s data and IP policies for what applies to underlying research data.
What license counts as “equivalent” to CC BY 4.0?
The foundation’s own language allows CC BY 4.0 “or an equivalent license” without enumerating a fixed list of substitutes in its public policy text; grantees uncertain whether a specific publisher-offered license qualifies should confirm directly with the foundation or their program officer before relying on it.
