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Wellcome Trust Open Access Policy: Requirements and Compliance

Wellcome Trust’s Open Access Policy requires immediate, embargo-free, CC-BY-licensed access to peer-reviewed articles from Wellcome-funded research. Covers requirements, compliance routes, and how it compares to other funder OA mandates.

The Wellcome Trust Open Access Policy requires that peer-reviewed research articles arising from Wellcome-funded research be made immediately and freely available, with no publisher embargo, under a Creative Commons Attribution (CC BY) licence. Wellcome was among the earliest research funders to mandate open access to funded publications, dating to a policy first introduced in 2005, and has revised the policy several times since — most significantly by moving from an embargo-tolerant model to a strict no-embargo, immediate-CC-BY requirement for articles submitted for publication from 1 January 2021 onward. It is a distinct instrument from Wellcome’s broader open-research and data-sharing expectations (see the Concordat on Open Research Data, which Wellcome co-signed alongside UK funders and sector bodies) and from Wellcome’s grant-specific guidance covered elsewhere on this site, such as the Wellcome Early-Career Award and Wellcome Career Development Award guides. This page covers the Open Access Policy specifically: what it requires, who it applies to, how compliance is achieved and checked, and how it compares to other funder open-access mandates.

What the policy requires

Wellcome’s current policy requires that the version of record (or, where that is not possible, the author’s accepted manuscript) of any peer-reviewed research article resulting from Wellcome funding be:

  • Immediately available — with no embargo period, at the time of publication;
  • Deposited in Europe PMC (Europe PubMed Central), Wellcome’s designated open repository, so the article is discoverable and accessible outside the publisher’s own platform; and
  • Published under a CC BY licence (or, in narrow cases involving third-party material, CC BY-ND), permitting reuse and redistribution with attribution.

This is a materially stricter requirement than Wellcome’s earlier policy, which allowed up to a 6-month embargo on the accepted manuscript. The no-embargo, immediate-CC-BY standard applies to articles submitted for publication on or after 1 January 2021, and it aligns Wellcome closely with the cOAlition S / Plan S model of immediate open access that a number of other major funders (UKRI among them) also adopted around the same period.

Compliance routes

Wellcome gives grant holders several ways to meet the policy, broadly mirroring the routes used by other immediate-OA mandates:

  • Publish gold open access in a fully open-access journal (typically one listed in the Directory of Open Access Journals) that publishes under CC BY immediately on publication.
  • Publish in a subscription (hybrid) journal and self-archive the accepted manuscript, making it freely available via Europe PMC under CC BY at the time of publication, with no embargo — this is the practical route for researchers who want to publish in a subscription venue without paying an article processing charge (APC) to that venue.
  • Publish via a transformative agreement between the researcher’s institution and the publisher, where the institution’s deal already covers immediate CC BY publication as part of a bundled subscription-and-OA arrangement.
  • Use a CC BY-licensed preprint as the compliant version where neither the version of record nor an accepted manuscript can be made compliant — a provision Wellcome added in a 2024 policy update, formalising a route it had already supported informally given its long-standing backing of preprint services (Wellcome was an early funder-backer of ASAPbio and has consistently encouraged rapid preprint sharing in the life and biomedical sciences).

Wellcome will pay reasonable open-access fees, including APCs, as part of the grant or through a separate open-access block/central fund at many host institutions, but payment of an APC alone does not satisfy the policy — the CC BY licence and immediate, embargo-free availability are the binding requirements regardless of which route is used.

What the policy covers

The policy applies to peer-reviewed research articles (including reviews) that acknowledge Wellcome funding, in or out of the grant’s active period, where Wellcome funding made a material contribution to the work. It does not, on its own, cover monographs, book chapters, conference proceedings, or research data — those are addressed by separate Wellcome guidance and by broader sector commitments such as the Concordat on Open Research Data. Wellcome’s wider funding acknowledgement and output-reporting expectations (covering datasets and other non-article outputs, not only journal articles) are addressed in the site’s Funding Acknowledgement Statement guide.

Compliance monitoring and enforcement

Wellcome checks compliance primarily through Europe PMC deposit records tied to the grant’s acknowledged funding, cross-referenced against outputs reported by grant holders. Non-compliant publications can affect a researcher’s standing on current and future Wellcome applications; Wellcome has stated it may withhold the final institutional payment on a grant, or decline future funding, where a grant holder has not made reasonable efforts to comply. As with most funder OA mandates, day-to-day compliance responsibility sits with the individual researcher, but many host institutions run their own checks (often through the institutional repository or research-information system) before article acknowledgement text or funder metadata is finalised.

How it compares to other funder open-access mandates

Wellcome’s policy is one of several immediate-OA, no-embargo, CC-BY funder mandates now in place, alongside UKRI’s policy and the cOAlition S / Plan S framework more broadly. It is useful to contrast against funder mandates that instead allow a green, embargoed route: the Tri-Agency Open Access Policy on Publications (Canada’s CIHR/NSERC/SSHRC joint policy) permits either immediate gold open access or a 12-month-embargo green self-archiving route, and does not mandate CC BY specifically — a meaningfully softer requirement than Wellcome’s. Research administrators supporting internationally co-funded or multi-funder projects need to track which mandate is strictest for a given article, since the strictest applicable funder policy generally governs the compliant venue and licence choice when a paper carries funding from more than one source.

Frequently asked questions

Does the Wellcome Open Access Policy apply to preprints?

Preprints are not a mandatory step, but since a 2024 policy update, a CC BY-licensed preprint can serve as the compliant output where the version of record or accepted manuscript cannot otherwise be made compliant. Wellcome has separately and consistently encouraged early preprint sharing as good practice in the life and biomedical sciences, independent of the formal compliance mechanism.

Is there any embargo allowed under the current policy?

No. For articles submitted for publication from 1 January 2021 onward, the policy requires immediate availability with no publisher-mandated embargo. Wellcome’s earlier policy did allow an embargo of up to six months; that provision no longer applies to newly submitted work.

What happens if a grant holder doesn’t comply?

Wellcome monitors compliance via Europe PMC deposit and output reporting, and can withhold final grant payments or factor non-compliance into future funding decisions. Institutions frequently build their own pre-submission compliance checks into repository or research-information workflows to reduce this risk.

How does this differ from the Concordat on Open Research Data?

The Open Access Policy governs peer-reviewed research articles specifically — licensing, embargo, and repository deposit of the written output. The Concordat on Open Research Data is a separate, broader sector commitment (which Wellcome co-signed) about making the underlying research data openly available and well-managed; it does not set article-specific licensing or embargo terms the way the Open Access Policy does.

Funder open-access policies are revised periodically. This page reflects Wellcome’s policy as most recently updated (including the 2024 preprint-compliance provision); research administrators should confirm current terms directly at wellcome.org before relying on specific dates or thresholds for a live compliance decision.

Referenced across the research world

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