CASRAI Dictionary

Author: MCP Service

  • Duke Research Misconduct Policy vs MIT, Stanford

    Duke, MIT and Stanford each operationalise the same federal research-misconduct standard through different institutional machinery. Duke routes allegations to a Misconduct Review Officer and a 24-hour Integrity Line; MIT centralises review under its Vice President for Research; Stanford assigns first-line assessment to school deans under a Research Policy Handbook chapter revised effective 1 January 2026. All three exist to satisfy one governing rule: the Public Health Service Policy on Research Misconduct.

    The federal policy on research misconduct — codified at 42 C.F.R. Part 93 and enforced by the HHS Office of Research Integrity (ORI) — defines research misconduct as fabrication, falsification, or plagiarism (FFP) in proposing, performing, or reviewing research, or in reporting research results. Every US university that accepts Public Health Service funding, including Duke, MIT and Stanford, must maintain an institutional policy that meets this baseline, then layers its own governance, reporting channels, and disciplinary structure on top.

    How does Duke’s research misconduct policy define and handle allegations?

    Duke’s research misconduct policy is set out in the Duke University Policy and Procedures Governing Misconduct in Research, part of the Faculty Handbook and last updated in May 2023. Allegations are directed to a designated Misconduct Review Officer (MRO), or to a department chair, division chief, or dean, who must promptly forward the matter to the MRO.

    Duke also operates an Integrity Line — a 24-hour, anonymous telephone hotline (1-800-826-8109) — so that reporters can raise concerns without disclosing their identity. This dual-channel design (a named institutional officer plus an anonymous hotline) reflects a broader reform effort: Duke’s policy was revised to extend coverage beyond faculty to research staff, alongside wider research-integrity reforms following a 2019 case in which the university agreed to a $112.5 million False Claims Act settlement over fabricated data in federally funded pulmonary research, as reported by Science. That episode is a documented driver of the university folding staff explicitly into the policy’s scope, according to case-study materials prepared for the Council on Governmental Relations (COGR).

    How does MIT structure its research misconduct procedures?

    MIT’s framework sits in MIT Policies and Procedures §10.1, “Procedures for Dealing with Misconduct in Research and Scholarship,” last updated 10 December 2025. Oversight is centralised: every allegation, wherever it is first raised, must be conveyed promptly to the Vice President for Research (VPR), MIT’s designated Research Integrity Officer.

    MIT’s definition tracks the federal FFP triad — fabrication (making up data), falsification (manipulating materials or altering results), and plagiarism (appropriating another’s ideas or words without credit) — but adds a fourth category not found in the core PHS definition: deliberate interference, meaning intentionally causing material harm to another’s research, such as damaging equipment or deleting data. MIT’s policy also explicitly excludes self-plagiarism (text recycling) and authorship or credit disputes among former collaborators from the definition of misconduct, mirroring longstanding ORI guidance on plagiarism.

    What changed in Stanford’s research misconduct policy for 2026?

    Stanford’s governing chapter, Research Policy Handbook (RPH) 1.7, “Research Misconduct: Policy on Allegations, Investigations, and Reporting,” dates originally to 3 February 1983 but carries a current version effective 1 January 2026. The update aligns Stanford’s procedures with the 2024 Final Rule amending 42 C.F.R. Part 93 — the same federal regulation that governs Duke and MIT.

    Two provisions distinguish Stanford’s approach. First, the “Six-Year Rule” (42 C.F.R. §93.104): research misconduct allegations are only actionable if the conduct occurred within six years of the date Stanford or a federal agency received the allegation, subject to a “subsequent use” exception (if the respondent later cited or republished the disputed material) and a “public health and safety” exception. Second, first-line responsibility sits with the school dean, who must assess an allegation and, if it meets the definition, immediately open an inquiry and notify the Dean of Research — a more devolved structure than MIT’s single VPR intake point.

    How do Duke, MIT and Stanford compare side by side?

    The table below sets the three institutional policies against each other and against the federal baseline they all must satisfy.

    Institution Governing document First-line authority Reporting channel Misconduct definition
    Duke University Policy and Procedures Governing Misconduct in Research (Faculty Handbook, updated May 2023) Misconduct Review Officer MRO, department chair/dean, or anonymous Integrity Line FFP, per 42 C.F.R. Part 93; covers faculty and staff
    MIT MIT Policies and Procedures §10.1 (updated 10 Dec 2025) Vice President for Research Report to VPR, typically via supervisor or department head FFP plus deliberate interference; excludes self-plagiarism and authorship disputes
    Stanford University Research Policy Handbook 1.7 (current version 1 Jan 2026; original 1983) School dean, then Dean of Research Report to school dean for initial assessment FFP per 42 C.F.R. Part 93 (2024 Final Rule); six-year time limitation
    Federal baseline PHS Policy on Research Misconduct, 42 C.F.R. Part 93 HHS Office of Research Integrity (ORI) Institutional report to ORI after a finding Fabrication, falsification, or plagiarism (FFP)

    All three institutions converge on the same two-stage process required by federal policy:

    • An inquiry — a preliminary assessment of whether an allegation has substance and warrants formal review.
    • An investigation — a full evidentiary examination that produces findings reported to ORI when federal funding is involved.

    Common questions on federal and institutional research misconduct policy

    What is the US federal research misconduct policy?

    The US federal research misconduct policy is the Public Health Service Policy on Research Misconduct, codified at 42 C.F.R. Part 93 and enforced by ORI. It applies to fabrication, falsification, and plagiarism in proposing, performing, reviewing, or reporting PHS-supported research, and requires every recipient institution to maintain a compliant local policy.

    What is 42 CFR Part 93 research misconduct?

    42 C.F.R. Part 93 is the federal regulation setting the definitions, procedural standards, and reporting obligations that PHS-funded institutions — including Duke, MIT, and Stanford — must follow. A 2024 Final Rule to Part 93 took effect on 1 January 2026, updating provisions including the definition of plagiarism that institutions must now apply.

    What are the three types of research misconduct?

    The three federally recognised types are fabrication (inventing data or results), falsification (manipulating materials, equipment, or data so the research record is inaccurate), and plagiarism (using another’s ideas, processes, or words without credit). Honest error and legitimate differences of scientific opinion are explicitly excluded.

    What constitutes research misconduct according to federal regulations?

    A federal finding requires three elements together: a significant departure from accepted research practices, conduct committed intentionally, knowingly, or recklessly, and an allegation proven by a preponderance of the evidence. All three tests must be met before ORI or an institution can record a formal finding of misconduct.

    What this means for research administrators

    For research administrators, compliance officers, and institutional leaders, the practical lesson is that federal alignment does not mean procedural uniformity. Duke, MIT, and Stanford each satisfy 42 C.F.R. Part 93, yet route allegations through different first-line authorities — an MRO, a VPR, and a school dean respectively — and set different scope boundaries around staff coverage, deliberate interference, and time limitations. Institutions benchmarking their own research administration policy against peer practice should treat the federal rule as the floor, not the template, and expect further local revisions as the 2024 Final Rule to Part 93 continues to work through university policy cycles into 2026 and beyond.

    Given that Stanford’s update took effect only this year and MIT revised its procedures in December 2025, institutional research misconduct policies are clearly still catching up to the federal 2024 Final Rule — administrators reviewing their own institution’s policy should confirm which version of 42 C.F.R. Part 93 it currently cites before assuming compliance.

  • Elsevier’s Research Integrity Screening Process

    Elsevier screens research submissions for integrity issues through a layered pipeline: automated tools such as Check Integrity and Crossref Similarity Check flag plagiarism, duplicate submissions and image anomalies at intake, specialist Research Integrity and Publishing Ethics (RIPE) analysts investigate confirmed concerns, and outcomes range from correction through expression of concern to full retraction, following guidelines set by the Committee on Publication Ethics (COPE).

    Research integrity screening is the set of technical checks and human review stages a publisher applies to a manuscript, before and after publication, to detect fabrication, falsification, plagiarism, undisclosed image manipulation and paper-mill activity. At Elsevier, that pipeline runs continuously from the moment a manuscript is submitted to the point, if necessary, of retraction.

    How Elsevier’s research-integrity pipeline works, from submission to retraction

    Elsevier operates one of the largest editorial screening operations in scholarly publishing. In 2025, the publisher received 4.2 million manuscript submissions across roughly 3,000 journals and published 795,000 after validation and peer review, according to Elsevier’s own account of its editorial process. Elsevier states that its published output accounts for over 18% of global research output and 29% of citations — a scale that shapes why it has invested heavily in both automated screening and dedicated integrity staff rather than relying on peer review alone.

    The pipeline runs across four broad stages, each with a different primary tool or team responsible for catching a different class of problem.

    Stage Primary tool or team Typical trigger
    Submission intake Check Integrity screening tool; Crossref Similarity Check (iThenticate) Text overlap, duplicate manuscript, unauthorised authorship change
    Peer review Editors, external reviewers, RIPE analysts Implausible data, reviewer-flagged inconsistency, suspicious image reuse
    Post-publication monitoring Research Integrity and Publishing Ethics (RIPE) team Reader or whistleblower reports, cross-journal pattern analysis
    Enforcement Editors-in-chief, following COPE-guided process Confirmed fabrication, falsification or plagiarism

    What does Elsevier screen for at the point of submission?

    Every manuscript submitted to an Elsevier journal is routed through automated checks before an editor sees it. Check Integrity, Elsevier’s proprietary screening tool, had been expanded across more than 2,000 journals as of March 2026, according to trade press coverage in Research Information. The tool automatically reviews submissions for red flags — including unauthorised authorship changes, undisclosed conflicts of interest and signs of duplicate or template-like submission — and routes anything flagged to specialist integrity analysts, freeing editors to focus on scientific merit.

    Plagiarism screening runs in parallel through Crossref Similarity Check, powered by iThenticate, which compares submitted text against a large index of published articles and web content. There is no fixed similarity percentage that automatically triggers rejection; editors interpret each report to distinguish appropriate citation from genuine textual misconduct.

    Paper-mill detection layers on top of these checks. Integrity analysts look for patterns that recur across industrialised fraud, including:

    • Formulaic, template-like titles or methods sections
    • Unusual or inconsistent author affiliations and contact details
    • Data or experimental descriptions that do not match the stated methodology
    • Systematic image reuse across ostensibly unrelated papers
    • Irregular peer-review patterns, such as reviewer suggestions tied to the same small pool of contacts

    How does Elsevier detect image manipulation and data-integrity problems?

    Image screening combines editorial guidelines with a mix of manual and software-assisted checks. Elsevier’s policy permits minor adjustments to brightness, contrast or colour balance only where they do not obscure or eliminate information present in the original image; the use of generative AI to create or alter a figure is prohibited outright. Where manipulation is suspected, editors can apply forensic image-analysis tools of the kind recommended by the US Office of Research Integrity, and will typically request the original, unprocessed image files directly from the authors.

    Elsevier has also published on the scale of automated flagging behind these checks. At the 8th World Conference on Research Integrity in 2024, Elsevier data scientist Yuri Kashnitsky presented on large-scale flagging of integrity misconduct across the publisher’s portfolio, noting that all system-generated findings are manually checked and confirmed by investigators before any corrective action is suggested to editors — underscoring that software narrows the search space, but a human analyst still makes the determination.

    Who investigates confirmed misconduct, and what enforcement follows?

    Once a concern is substantiated, Elsevier’s in-house Research Integrity and Publishing Ethics (RIPE) team leads the investigation, working with journal editors and, where warranted, the authors’ institutions. Elsevier states that it follows retraction guidelines developed by COPE, and confirmed problems resolve into one of three outcomes: a correction or erratum for errors that do not undermine the paper’s conclusions, an expression of concern where the investigation is inconclusive but doubts remain, or a retraction where the findings are no longer considered reliable.

    A recent case shows this enforcement ladder operating at scale. In a statement updated in May 2026, Elsevier disclosed that a comprehensive, multi-year audit of the journal Heliyon — using Check Integrity screening combined with manual review by RIPE analysts — had produced approximately 1,100 corrections to the scientific record, affecting around 3% of everything the journal had published across 12 years. Those 1,100 actions spanned corrections, expressions of concern and retractions; impacted authors were notified and given the chance to respond before editors made a final determination. Following the audit, Web of Science removed an indexing hold it had placed on Heliyon, and Elsevier said it was applying lessons from the case to workflows across its wider journal portfolio.

    Common questions about Elsevier’s integrity screening

    Does Elsevier use iThenticate for plagiarism screening?

    Yes. Elsevier’s journals route submitted manuscripts through Crossref Similarity Check, which is powered by iThenticate, comparing text against a large index of published articles and web content. Editors, not the software alone, judge whether flagged overlap reflects proper citation or genuine plagiarism before any editorial decision is made.

    Who investigates allegations of research misconduct at Elsevier?

    Elsevier’s in-house Research Integrity and Publishing Ethics (RIPE) team investigates confirmed concerns, working alongside journal editors and, where relevant, the authors’ institutions. Investigations follow COPE guidelines and typically involve requesting raw underlying data before any corrective action is taken.

    What is considered the most serious form of research misconduct?

    Fabrication and falsification of data are generally treated as the most serious forms of misconduct, alongside plagiarism, because they directly corrupt the reliability of the published record. Elsevier’s policies place these above lesser breaches such as citation gaming or unresolved authorship disputes.

    What happens after a research-integrity investigation confirms a problem?

    Confirmed issues lead to one of three outcomes: a correction for errors that do not undermine the findings, an expression of concern where evidence is inconclusive, or a retraction where the results are no longer considered reliable. All three are published and linked to the original article, per COPE guidance.

    What this means for institutions, authors and integrity offices

    For research administrators, the Heliyon case is a reminder that publisher-side screening is a complement to institutional processes, not a substitute for them. When a journal’s RIPE team contacts an institution about a flagged submission or published paper, that request typically triggers — and depends on — the institution’s own research-integrity office and record-keeping, an area covered in more detail in CASRAI’s research administration resources and its wider research-integrity dictionary entries. Authors, in turn, should expect to be asked for raw, unprocessed data or images at any stage, including years after publication, and should retain those records accordingly.

    Elsevier is not acting alone: it collaborates with other publishers through the STM Integrity Hub to detect duplicate submissions across the wider industry, reflecting a broader shift toward cross-publisher, not just single-journal, integrity infrastructure. As automated screening tools mature, the balance is likely to keep shifting toward earlier detection at submission — but the Heliyon audit shows that human RIPE analysts, not algorithms, remain the ones who make the final call on correction, expression of concern or retraction.

  • ACM Open Access vs Plan S: 2026 Compliance Check

    ACM open access is now the default, not an option: since 1 January 2026 the Association for Computing Machinery publishes all journals, conference proceedings and magazines under a fully open-access model, replacing its previous hybrid Read & Publish arrangement. Under the CC BY licence, zero-embargo release and author-retained copyright that now apply across the ACM Digital Library, the model satisfies cOAlition S’s Plan S licensing, immediacy and rights-retention requirements — closing a compliance gap that existed while ACM operated as a transformative agreement.

    ACM Open is the Read & Publish framework through which participating institutions pay a fixed annual fee, based on their average publishing output over the previous three years, in exchange for unlimited open-access publishing by their corresponding authors and full institutional read access to the ACM Digital Library.

    What is ACM open access?

    As of 1 January 2026, ACM transitioned every journal, magazine and conference proceeding in the ACM Digital Library to full open access, removing the mixed subscription/hybrid model that had applied since the ACM Open programme launched in 2020. The ACM Digital Library itself was split into two tiers on the same date: a free Basic edition giving open access to ACM’s full published corpus, and a paid Premium edition adding discovery tools, usage metrics, citation management and the ACM Guide to Computing Literature.

    Institutional participation still runs through ACM Open, ACM’s Read & Publish framework. Corresponding authors at a subscribing institution publish an unlimited number of open-access articles without paying an article processing charge (APC) directly; the institution instead pays one fixed annual fee tied to its historical publishing volume. Authors at non-participating institutions can still publish open access but may be liable for an APC.

    What does Plan S actually require?

    Plan S is the funder-driven open-access mandate coordinated by cOAlition S, a consortium of national and charitable research funders including UKRI, Wellcome and members of the European Research Council network. It sets three non-negotiable conditions for compliant publication, in force since the policy’s 2021 implementation date:

    • Licensing — the published article must carry a Creative Commons Attribution (CC BY) licence, or an equivalent that permits free reuse, as a default condition.
    • Immediacy — there can be no embargo period; the Version of Record, or an accepted manuscript carrying the same licence, must be open at the moment of publication.
    • Rights retention — authors, not publishers, must retain the rights needed to comply, formalised in cOAlition S’s Rights Retention Strategy (RRS), which lets funded authors apply a CC BY licence to their accepted manuscript regardless of the publisher’s own copyright terms.

    cOAlition S also phased out support for hybrid and transformative-journal routes: funding for APCs in hybrid subscription journals was withdrawn after 2024, meaning publishers relying on transformative agreements needed to complete a full flip to open access to remain straightforwardly fundable under Plan S.

    Does ACM Open satisfy cOAlition S requirements?

    Measured against each Plan S condition, ACM’s current model clears the bar directly rather than through a transitional workaround. The table below maps ACM’s terms to the three cOAlition S requirements.

    Plan S requirement ACM Open / ACM Digital Library position
    CC BY licence by default CC BY is the default licence under ACM Open; authors may select an alternative Creative Commons licence such as CC BY-NC-ND where a funder permits it.
    No embargo (immediacy) Zero embargo — the Version of Record is openly accessible in the ACM Digital Library at the point of publication for every ACM title.
    Author/institution rights retention ACM ceased requiring copyright transfer from authors; authors grant ACM a non-exclusive licence to publish rather than assigning copyright, satisfying the Rights Retention Strategy.
    Sustainable, transparent cost model ACM Open’s Read & Publish fee is fixed for the agreement term and based on three-year historical output, giving institutions a predictable APC-equivalent cost.

    The practical effect for a cOAlition S-funded computer scientist is that publishing in an ACM venue no longer requires checking whether a specific journal is “transformative” or tracking an embargo clock — the open-access, CC BY, zero-embargo position now applies uniformly across the ACM catalogue.

    What happened to ACM’s transformative agreements?

    Before the January 2026 flip, ACM Open operated as a transformative agreement: a Read & Publish deal under which subscription revenue was gradually redirected toward open-access publishing, with the expectation that the journal portfolio would eventually convert fully to open access. UK higher-education institutions negotiated ACM Open terms through Jisc, whose subscriptions catalogue still lists the prior “ACM OPEN Journals 2023-2025” agreement as the precursor arrangement that libraries used to budget for the transition.

    ACM’s own SIGGRAPH leadership signalled the scale of this shift well in advance: in a June 2024 community Q&A, ACM SIGGRAPH chair Jonathan Aldrich stated that ACM anticipated 60-65% or more of authors would already be covered by institutional open-access agreements by the time of the full transition, with the remainder needing an author-paid or waiver route. That anticipated coverage gap is precisely what the January 2026 full flip was designed to close, since every article — not just those from ACM Open institutions — is now open access regardless of the author’s institutional agreement status.

    What this means for institutions and researchers

    For research administrators tracking funder compliance, ACM’s flip removes a recurring due-diligence step: computer-science output published with ACM no longer needs an individual title-by-title check against a cOAlition S-approved transformative journal list, because the requirement is now met at the publisher level. Institutions still weighing whether to join ACM Open should note that the Read & Publish fee is separate from open-access compliance itself — declining to subscribe does not make an ACM article closed, but it may shift APC liability onto individual authors or their grants.

    For authors publishing under UKRI, Horizon Europe or other cOAlition S-aligned funder mandates, the practical takeaway is that ACM venues can now be selected on scholarly merit without a separate compliance audit — a meaningful simplification for research administrators supporting authors across computing, information systems and related interdisciplinary fields.

    Frequently asked questions

    What is ACM open access?

    ACM open access refers to ACM’s publishing model, under which, as of January 2026, all ACM journals, conference proceedings and magazines are freely accessible with no reader-side subscription barrier. Authors retain copyright and publish under a CC BY licence by default, typically funded through their institution’s ACM Open Read & Publish agreement rather than a per-article fee.

    Is ACM open access free for readers?

    Yes. The ACM Digital Library’s Basic edition gives free, open-access reading of ACM’s full published corpus. A separate paid Premium edition exists, but it adds discovery and analytics tools rather than gating access to the research articles themselves.

    Does ACM’s open-access model satisfy Plan S?

    Yes. ACM’s default CC BY licence, zero-embargo release of the Version of Record, and author rights retention policy together meet all three of cOAlition S’s core Plan S conditions, without relying on a transformative-agreement exception.

    What licence does ACM Open use?

    ACM Open’s default licence is CC BY (Creative Commons Attribution), which permits free reuse with attribution and satisfies cOAlition S’s licensing requirement. Authors may request an alternative Creative Commons licence, such as CC BY-NC-ND, where their funder’s terms allow it.

    Looking ahead

    ACM’s move puts one of computing’s two dominant scholarly publishers — alongside IEEE, which retains a hybrid subscription model for most titles — fully inside the Plan S compliance perimeter without caveats. For funders and institutions monitoring discipline-specific open-access uptake, ACM’s flip is a useful signal that field-specific societies can complete a full transition to open access while keeping a Read & Publish fee structure recognisable to library budgets. Research administrators supporting computer-science authors should update internal compliance checklists to reflect that ACM no longer requires case-by-case verification against transformative-journal criteria.

  • Plan S Wikipedia vs cOAlition S: What Changed

    Plan S is an initiative for open-access science publishing, launched in September 2018 by cOAlition S, a consortium of research funders. Wikipedia’s article on Plan S is broadly accurate on the initiative’s origins and ten principles, but its most-cited figures on transformative agreements, rights-retention uptake, and coalition membership are frozen between 2021 and 2023 — and the article makes no mention of cOAlition S’s own Strategy for 2026-2030, published in November 2025.

    Plan S is the requirement, backed by cOAlition S funders, that peer-reviewed research they fund be made immediately and freely available in a compliant open-access journal, platform, or repository, without embargo, under an open licence.

    What does Wikipedia say about Plan S?

    Wikipedia’s “Plan S” article opens by describing the initiative as a consortium of national research agencies and funders from twelve European countries, requiring that publicly funded research be published in open repositories or fully open-access journals by 2021. It correctly identifies cOAlition S as the coordinating body and lists the ten founding principles set out in the original implementation guidance.

    The article also notes real, later developments: the extension of the compliance deadline from 2020 to 2021, the Rights Retention Strategy, an October 2023 proposal to explore publishing models without author-facing fees (“diamond” open access), and a 2024 Gates Foundation policy shift described as not fully aligned with Plan S. This shows the page is edited, not abandoned — but the edits are sparse and several core figures have not been touched in years.

    Where the Wikipedia article holds up

    Several elements of Wikipedia’s account remain a fair summary of Plan S as it was designed. The ten principles — author copyright retention, standardised and capped publication fees, funder-level monitoring of compliance, and the explicit statement that hybrid open-access journals do not satisfy the key principle — match the original guidance released by the Science Europe-coordinated task force on 27 November 2018.

    The licensing detail is also accurate: compliant articles must carry a CC BY 4.0 licence, or alternatively CC BY-SA 4.0 or CC0, and journals must meet baseline peer-review standards consistent with guidance from the Committee on Publication Ethics (COPE) and listing in the Directory of Open Access Journals (DOAJ). None of this has changed, and Wikipedia states it correctly.

    Where the record is stale

    The gaps are concentrated in exactly the areas that move fastest: funding mechanics, uptake statistics, and coalition scope. The table below sets Wikipedia’s wording against cOAlition S’s own published record.

    Wikipedia’s claim Current cOAlition S position Source
    Transformative agreement contracts “may not last beyond 2023” cOAlition S confirmed in January 2023 that member funding for transformative arrangements would continue but cease entirely on 31 December 2024, with no new agreements accepted after 30 June 2023 cOAlition S, “cOAlition S confirms the end of its financial support for Open Access publishing under transformative arrangements after 2024”
    Rights Retention Strategy uptake given “as of October 2021 … over 500 works” No comparable running total has been added since; the Strategy remains active guidance with no current uptake figure cited on the page cOAlition S Rights Retention Strategy guidance (ongoing)
    Lede describes cOAlition S as funders “from twelve European countries” Membership and policy alignment now extends beyond that founding European core, as the article’s own later reference to the Gates Foundation’s 2024 policy shift illustrates cOAlition S member list; Wikipedia “Plan S” article, “Policy changes by member organizations” section
    No mention of a forward strategy beyond 2023-24 developments cOAlition S published its Strategy for 2026-2030 in November 2025, setting three strategic priorities across two implementation phases cOAlition S, “cOAlition S Strategy for 2026-2030”

    None of this makes the Wikipedia article wrong about what Plan S was. It makes the article an increasingly incomplete guide to what Plan S is now — a distinction that matters for anyone citing it in a policy brief, grant compliance note, or institutional guidance document.

    What cOAlition S’s 2026-2030 strategy adds

    cOAlition S’s Strategy for 2026-2030, published in November 2025, is the most authoritative recent statement of where the coalition is heading, and it is entirely absent from Wikipedia’s coverage. The strategy sets three strategic priorities: reinforcing the foundations for full, immediate, and equitable open access to peer-reviewed articles; supporting the digital infrastructure that underpins open access; and exploring financially sustainable and equitable publishing models while tracking their outcomes.

    Implementation runs in two phases. Phase one (2026-2027) concentrates on foundational work, digital infrastructure, and member services. Phase two (2028-2030) is intended to deepen work on sustainability and equity, subject to review of phase-one outcomes by the Leaders Group. This phased structure directly supersedes the transitional, 2018-2023 “transformative agreement” framing that still anchors Wikipedia’s implementation section.

    • Three strategic priorities replace the earlier single-minded focus on the 2021 compliance deadline.
    • A defined two-phase timetable (2026-2027, then 2028-2030) gives institutions a planning horizon Wikipedia’s article does not mention.
    • Financial support for transformative arrangements ended on 31 December 2024, closing a funding route Wikipedia still frames as open until “2023”.

    Common questions

    What is Plan S in open access?

    Plan S requires that peer-reviewed publications resulting from research funded by cOAlition S members be made immediately open access on publication, with no embargo, under an open licence such as CC BY 4.0. Authors must retain copyright. The requirement applied to grants awarded from 1 January 2021 onward.

    What are the five pillars of Wikipedia?

    Wikipedia operates on five pillars: it functions as an encyclopedia, is written from a neutral point of view, offers free content anyone can use or edit, expects civility among editors, and has no firm rules. Those norms explain why fast-moving funder guidance, like Plan S’s, can lag behind primary sources between volunteer edits.

    What this means for institutions and publishers

    Research administrators, library staff, and publishers who cite Wikipedia’s Plan S article as a compliance reference should treat it as a starting point, not a current-state document. Anyone advising on plan s open access obligations should verify funding-route and deadline details directly against cOAlition S’s guidance pages before applying them to a grant, agreement, or institutional policy — particularly anything touching transformative agreements, which stopped receiving cOAlition S funding at the end of 2024, not 2023.

    This pattern is not unique to Plan S. Fast-moving standards and funder mandates routinely outrun general-reference encyclopedia coverage, which depends on volunteer editors noticing and sourcing each change. The practical fix is straightforward: use Wikipedia to orient, then confirm operative dates, funding rules, and current strategic priorities against the originating body’s own published guidance.

    For related standards and terminology used across research administration, see CASRAI’s open research dictionary and the research administration pillar.

  • PMC Open Access Subset vs Plan S: Not the Same

    The PMC Open Access Subset and Plan S are not the same thing. The PMC Open Access Subset is a licensing classification inside PubMed Central (PMC) that flags which archived articles carry reuse-permitting licences for text mining and redistribution. Plan S is a funder mandate from cOAlition S that requires immediate open access publication of funded research. One is a repository filter; the other is a compliance requirement — and confusing them leads authors to think a PMC listing satisfies a funder’s open access policy when it may not.

    The PMC Open Access Subset is the portion of PubMed Central’s full-text archive made available under Creative Commons or similar licences that permit reuse beyond reading, including text mining and redistribution. This distinction — repository versus mandate — is the source of a persistent mix-up among authors preparing to comply with funder open access requirements.

    What Is the PMC Open Access Subset?

    The PMC Open Access Subset is maintained by the U.S. National Library of Medicine (NLM), part of the National Institutes of Health (NIH). It contains articles and preprints made available under machine-readable licences — Creative Commons or similar — that permit reuse beyond simple reading access.

    NLM groups the subset into three licence tiers:

    • Commercial Use Allowed — CC0, CC BY, CC BY-SA, CC BY-ND licences
    • Non-Commercial Use Only — CC BY-NC, CC BY-NC-SA, CC BY-NC-ND licences
    • Other — no machine-readable licence, no licence, or a custom licence, with restricted redistribution on the PMC Cloud Service

    As of the NIH’s most recent update, the subset spans well over 3.4 million journal articles and preprints, retrievable via the PMC FTP Service, Cloud Service, OAI-PMH Service, or BioC API. Not every article in PMC belongs to the Open Access Subset — many PMC-hosted articles remain under standard copyright and are excluded from bulk text-mining retrieval.

    This is a critical, frequently missed distinction: PMC itself (the archive) and the NIH Public Access Policy (which mandates deposit of NIH-funded manuscripts into PMC) are separate from the Open Access Subset (the licensing classification). An article can be freely readable in PMC under the Public Access Policy while still sitting outside the Open Access Subset, because it lacks a reuse-permitting licence.

    What Is Plan S?

    Plan S is a funder-driven open access initiative launched in September 2018 by cOAlition S, a coalition of national and international research funders including UKRI, Wellcome, and members of the European Commission’s Horizon Europe programme. It requires that peer-reviewed publications arising from funded research be made immediately and fully open access, with no embargo period.

    Under Plan S principles, compliant publication routes include:

    • Publishing in a fully open access journal or platform
    • Publishing in a subscription journal while depositing the accepted manuscript in an open access repository immediately on publication (the “Rights Retention Strategy”)
    • Publishing on an open access platform or in a repository that meets cOAlition S technical requirements

    cOAlition S states that authors or their institutions should retain copyright, and that a Creative Commons Attribution (CC BY) licence is the preferred licence type. Compliance is assessed against funder-specific policy terms, not against any single repository’s inclusion criteria.

    PMC Open Access Subset vs Plan S: Key Differences

    The clearest way to separate these two is by function: a repository classification versus a funder policy. The table below sets this alongside a third commonly conflated mechanism — the United States’ federal public access requirement — since UK and international researchers frequently encounter all three in the same compliance conversation.

    Feature PMC Open Access Subset Plan S US federal public access mandate
    Nature Repository licensing classification Funder policy mandate Federal agency policy (via OSTP)
    Governing body National Library of Medicine (NIH) cOAlition S funders Office of Science and Technology Policy (OSTP)
    What it governs Reuse rights of archived articles Where/how funded research is published Timing of public access to federally funded research
    Embargo position Not applicable — licence-based, not time-based Zero embargo required from 2021 Zero embargo required by 31 December 2025 (OSTP’s 2022 Nelson Memo)
    Geographic scope Global archive, US-hosted Primarily European and international funders United States federal agencies
    Enforcement mechanism None — it is a content filter, not a compliance check Funder grant conditions Agency public access plans

    The overlap that causes confusion: research funded under Plan S can end up in the PMC Open Access Subset if it carries a qualifying licence, but Plan S compliance is judged by the funder against its own policy terms, not by whether NLM has classified the article into the subset.

    Does Plan S Compliance Require the PMC Open Access Subset?

    No. Plan S does not name the PMC Open Access Subset as a compliance route. cOAlition S funders accept publication in a compliant journal, an institutional or subject repository meeting technical requirements, or immediate deposit of the accepted manuscript under an approved licence. PMC is one possible repository destination for biomedical research, but Plan S compliance is assessed by licence terms and embargo length, not by NLM’s internal subset classification.

    Authors publishing biomedical research funded by a cOAlition S member should check the funder’s own open access policy and, separately, confirm whether their institution or publisher will additionally deposit the manuscript into PMC. These are two distinct actions that happen to intersect for US-relevant biomedical literature, not one unified process.

    Common Questions

    What is PMC open access?

    PMC open access refers to the PMC Open Access Subset, the portion of PubMed Central archived under licences — typically Creative Commons — that permit reuse, including text mining and redistribution. It is not a funder policy; it is a licensing classification applied to specific articles already deposited in PMC.

    Are PMC and PubMed the same?

    No. PubMed is a database of citations and abstracts, while PMC (PubMed Central) is a full-text archive of biomedical journal articles. Both are maintained by the National Library of Medicine, but PubMed indexes metadata, whereas PMC stores the complete article text, of which only a subset carries reuse licences.

    Is PMC free to use?

    Yes, reading PMC articles is free. However, reuse rights differ by article: NLM states that PMC provides long-term preservation and free reading access, but text mining or redistribution beyond fair use requires the article to carry a qualifying licence within the Open Access Subset — free-to-read is not the same as free-to-reuse.

    Implications for Authors and Institutions

    For authors, the practical takeaway is definitive: satisfying a funder’s Plan S obligation and appearing in the PMC Open Access Subset are two separate compliance checks. Meeting one does not automatically satisfy the other. Institutional research administration teams tracking funder compliance should verify licence type, embargo length, and deposit location independently for each requirement, rather than treating “it’s in PMC” as proof of open access mandate compliance.

    For publishers and repository managers, the distinction matters for metadata accuracy: an article’s PMC Open Access Subset licence tag should be checked and communicated separately from any funder compliance statement attached to the same article.

    Looking ahead, the gap between these mechanisms is narrowing. The US federal government’s move toward zero-embargo public access by the end of 2025, alongside Plan S’s established zero-embargo requirement since 2021, signals convergence on immediate access as the global norm — even though the underlying legal and technical mechanisms (funder mandate versus repository licence versus agency policy) remain distinct and will continue to require separate verification.

  • Journal Finder Tools Compared for Plan S Authors

    Springer, Elsevier, Wiley and Taylor & Francis each run a free journal finder that matches a manuscript’s title, abstract or keywords to journals in their own portfolio — but none of them checks Plan S open-access compliance. That verification step belongs to cOAlition S’s separate Journal Checker Tool, which authors should run after shortlisting journals, not instead of it.

    A journal finder is a publisher-run search tool that recommends candidate journals for a manuscript by matching its subject area, title or abstract text against that publisher’s own list of active titles. This distinction matters more than it first appears: a Plan S-funded author who only uses a publisher’s finder can end up with a well-matched journal that is not, in fact, a compliant venue for their grant.

    What Do Publisher Journal Finder Tools Actually Do?

    Every major publisher-run journal finder performs the same core function: it takes a manuscript’s title, abstract or keywords and returns a ranked list of journals from that publisher’s own portfolio likely to fit the manuscript’s scope. None of them search across competing publishers, and none independently verify a journal’s open-access route against a specific funder’s mandate.

    • Input is usually a title, abstract or a short set of keywords, sometimes with a subject-area filter.
    • Output is a ranked shortlist, often annotated with impact metrics, acceptance rate or review speed.
    • Coverage is limited to titles the publisher itself owns or manages — this is the single biggest limitation for cross-publisher comparison shopping.

    How Do Springer, Elsevier, Wiley and Taylor & Francis Compare?

    Elsevier’s Journal Finder lets authors search by journal title, subject area or aims and scope, or run a “match my abstract” search against Elsevier’s own journal list. Springer Nature’s Journal Suggester, reached via the Springer Nature Link journals hub, matches manuscript details against the combined Springer, Nature, BMC and Palgrave Macmillan portfolio and surfaces open-access funding options alongside journal suggestions. Wiley’s Journal Finder states on its own page that it lets authors “search and filter across 1,800+ journals” by keyword, subject or abstract match. Taylor & Francis’s Journal Suggester, hosted on its Author Services site, uses a short five-question, AI-assisted form to recommend titles from the Taylor & Francis and Routledge list.

    Tool Provider Input method Portfolio scope Checks Plan S compliance? Best for
    Journal Finder Elsevier Title/abstract match, subject/scope search Elsevier’s own journals No Fast shortlisting within Elsevier imprints
    Journal Suggester Springer Nature Title, abstract or keyword input Springer, Nature, BMC, Palgrave Macmillan No (shows OA funding options, not funder-mandate checks) Authors targeting Springer Nature imprints
    Journal Finder Wiley Keyword, title or abstract search, with filters 1,800+ Wiley journals Partial — separate Wiley Author Compliance Tool checks funder policy Discipline-specific filtering within Wiley’s list
    Journal Suggester Taylor & Francis Five-question AI-assisted form Taylor & Francis / Routledge portfolio No Quick AI-generated shortlist
    Scopus Source Search Elsevier (Scopus) Lookup by ISSN or title, not manuscript matching Scopus-indexed sources, cross-publisher No Verifying CiteScore or indexing status of a journal already in mind
    Journal Checker Tool cOAlition S Funder, institution and journal input Any journal, cross-publisher Yes — this is its sole purpose Confirming a compliant open-access route before submission

    Does Scopus Have Its Own Journal Finder?

    Scopus, Elsevier’s abstract-and-citation database, does not run a manuscript-matching journal finder in the way Elsevier, Springer Nature, Wiley or Taylor & Francis do. Its Scopus Source Search instead looks up journals you already have in mind, by ISSN or title, to confirm indexing status and metrics such as CiteScore.

    Authors who search “journal finder scopus” are usually trying to do one of two different things, and conflating them causes wasted time. If the goal is to discover new candidate journals for a manuscript, a publisher’s own finder (or a cross-publisher tool such as JournalGuide) is the right starting point. If the goal is to confirm that a journal you have already chosen is Scopus-indexed, Scopus Source Search is the correct tool, not a substitute for journal discovery.

    Do Any of These Tools Check Plan S Compliance?

    Not directly, with one partial exception. Plan S, launched by cOAlition S in 2018 and taking effect for grants awarded from 2021, requires that publications from funded research appear in a fully open-access journal, on a compliant platform, or via a transformative arrangement recognised by the funder. Publisher journal finders match content to scope; they do not check a specific funder’s mandate against a specific journal’s business model.

    Wiley is the partial exception: alongside its Journal Finder, it offers a separate Author Compliance Tool that checks whether a given Wiley journal’s policies align with a named funder’s requirements. For every other publisher listed above, compliance checking sits outside the finder entirely.

    The authoritative cross-publisher tool is cOAlition S’s Journal Checker Tool (JCT). It requires three inputs — the author’s cOAlition S funder, their institution, and the intended journal — and returns whether that journal offers a Plan S-compliant route: full open access, a transformative agreement, or a self-archiving right that satisfies the funder’s policy. Authors should treat this as a mandatory second step after shortlisting journals with a publisher finder, never as an optional extra.

    Self-archiving (green open-access) rights specifically were historically checked via Sherpa/RoMEO. That lookup function has since migrated into Jisc’s Open Policy Finder, which now performs the same self-archiving and copyright policy search that Sherpa/RoMEO ran for over two decades, and remains a useful companion to the JCT when a transformative agreement is not available. Research administration teams tracking institutional compliance across multiple funders often run the JCT and Open Policy Finder together as a two-step check before an author submits.

    Common Questions From Plan S Authors

    Is Wiley JournalFinder free to use?

    Yes. Wiley’s Journal Finder is a free public tool at wiley.com that lets authors search or filter across 1,800+ Wiley journals by keyword, subject area or manuscript abstract. No login or subscription is required to generate a shortlist, though saving results and using the separate Author Compliance Tool may require a free Wiley account.

    What are the alternatives to Wiley Journal Finder?

    Authors publishing outside Wiley can use Elsevier’s Journal Finder, the Springer Nature Journal Suggester, or the Taylor & Francis Journal Suggester, each matching a manuscript to that publisher’s own portfolio. Cross-publisher alternatives include JournalGuide and Scopus Source Search, though neither replaces a funder-specific Plan S compliance check.

    What is Sherpa Romeo mainly used for?

    Sherpa/RoMEO was historically used to check a journal’s self-archiving policy — whether authors could deposit a preprint, accepted manuscript or published version in a repository. Its self-archiving data has since migrated into Jisc’s Open Policy Finder, which now performs the same green open-access policy lookup for Plan S authors.

    Is Wiley better than Elsevier?

    Neither is objectively “better” — each journal finder only searches that publisher’s own portfolio. Wiley’s tool covers 1,800+ titles with subject filters, while Elsevier’s adds an abstract-matching search across its list. The right choice depends on which publisher’s journals suit the manuscript’s discipline and the author’s funder requirements, not on the tool itself.

    For research administrators and institutional open-access teams, the practical takeaway is procedural rather than technical: publisher journal finders solve the discovery problem, but only a funder-aware checker like the JCT solves the compliance problem, and treating the two as interchangeable is the most common cause of post-acceptance compliance disputes. As more funders align with cOAlition S principles, expect publisher finders to integrate compliance flags directly — Wiley’s Author Compliance Tool is an early sign of that direction — but until that integration is universal, running a publisher finder followed by the Journal Checker Tool remains the safest two-step workflow for Plan S authors.

  • Predatory Journal Checker vs Plan S Compliance

    A Plan S compliant journal is not automatically screened by a predatory journal checker: Plan S tests open-access licensing and Directory of Open Access Journals (DOAJ) registration, not editorial integrity or peer-review conduct. The two checks answer different questions, and treating DOAJ/Plan S clearance as proof a journal is legitimate leaves a real compliance gap that research administrators need to close separately.

    A predatory journal checker is a tool, checklist, or reference list — such as the Think. Check. Submit. checklist, Cabells’ Predatory Reports, or the archived Beall’s List — used to test whether a journal’s peer review, editorial board, and fee practices are genuine rather than a vehicle for harvesting article-processing charges.

    What is a predatory journal checker?

    A predatory journal checker evaluates the operational and editorial conduct of a journal rather than its licensing terms. It looks at whether peer review actually happens, whether the editorial board is real and contactable, whether article-processing charges are disclosed upfront, and whether the publisher’s indexing claims can be verified.

    Common red flags that these tools and checklists are built to catch include:

    • Unsolicited, aggressive email invitations promising rapid publication
    • No transparent article-processing-charge (APC) schedule until after acceptance
    • An editorial board listing academics without their knowledge or consent
    • A journal scope so broad it covers unrelated disciplines
    • Fabricated or unverifiable impact-factor and indexing claims

    These are the criteria a checker tests. None of them is what Plan S compliance actually checks — which is the source of the confusion this article addresses.

    Does Plan S compliance screen for predatory journals?

    Not directly. Plan S is a funder mandate — led by cOAlition S — requiring that publicly funded research be published open access under specific licensing terms. Its technical requirements state that a fully open-access journal must be listed in the Directory of Open Access Journals (DOAJ), or apply for DOAJ listing within one year of publishing its first article, to count as a compliant venue.

    DOAJ listing is a proxy signal, not a predatory-publishing audit. cOAlition S guidance separately points authors toward the Think. Check. Submit. checklist for journal-selection due diligence — a clear indication that cOAlition S itself does not treat DOAJ/Plan S clearance as a substitute for a dedicated predatory check. Responsibility for the final journal-selection decision sits with the researcher and their institution, not with the funder’s compliance rule.

    DOAJ listing vs a dedicated predatory journal checker

    DOAJ vetting and a predatory journal checker overlap in intent — both aim to exclude disreputable venues — but they differ in scope, update frequency, and what they miss. DOAJ’s 2014–2016 re-application process is a useful illustration: it removed roughly 3,300 previously listed journals that failed revised inclusion criteria, which shows DOAJ listing is a snapshot assessment, not a continuously monitored guarantee.

    Mechanism What it verifies What it misses Best used for
    Plan S / DOAJ listing Open-access licence terms; baseline transparency criteria at time of listing Ongoing editorial conduct; peer-review quality after listing Confirming funder-mandate eligibility
    Predatory journal checker (Think. Check. Submit., Cabells, Beall’s archive) Editorial board authenticity, peer-review conduct, fee transparency Funder licensing compliance Author-level due diligence before submission
    Scopus / Web of Science journal check Active indexing status, citation metrics, discontinued-title flags Newer or non-English-language legitimate journals not yet indexed Cross-checking indexing claims a journal makes about itself
    Publisher/journal finder tools Journal-manuscript fit by scope and audience Legitimacy screening entirely — these tools assume the candidate pool is already vetted Narrowing a shortlist of already-verified journals

    What does a Scopus journal check add?

    A Scopus journal check confirms whether a title is actively indexed, flags titles that have been discontinued from Scopus for quality reasons, and surfaces citation-based metrics. This is a useful cross-check against a journal’s own indexing claims — predatory titles frequently claim indexing status they do not have — but Scopus coverage is not designed as a predatory-publishing screen and does not evaluate peer-review conduct directly.

    It is also asymmetric: a legitimate new journal may not yet be Scopus-indexed, so absence from Scopus is not itself proof of a predatory operation. Administrators should treat a Scopus check as one data point in a layered process, not a standalone verdict.

    How should administrators layer both checks?

    Institutions handling funder-mandate compliance and research-integrity screening as two separate workstreams should merge them into one journal-selection workflow. A practical sequence:

    1. Confirm funder eligibility first. Check DOAJ listing (or ROAD registration) to establish Plan S / open-access mandate compliance.
    2. Run a dedicated predatory check second. Apply the Think. Check. Submit. checklist, or consult Cabells’ Predatory Reports where the institution has a subscription, against the same candidate journal.
    3. Cross-check indexing claims. Verify any Scopus, Web of Science, or PubMed indexing the journal advertises against the indexing service’s own database.
    4. Escalate ambiguous cases to the institution’s research-integrity office or library scholarly-communications team rather than relying on a single automated pass/fail signal.
    5. Record the outcome in the researcher’s submission file, since funders and REF-style assessment exercises increasingly expect an audit trail of due-diligence steps, not just a final compliance flag.

    This sequencing matters because each mechanism fails differently: DOAJ/Plan S can clear a journal on licensing grounds while missing recent editorial decline; a predatory checker can flag conduct issues DOAJ has not yet caught up with; Scopus can catch a false indexing claim that neither of the other two checks is built to test.

    Common questions about predatory journal screening

    How do you check if a journal is predatory?

    Run the Think. Check. Submit. checklist against the journal, verify the editorial board members individually, confirm the article-processing charge is disclosed before submission, and cross-check any indexing claims (Scopus, DOAJ) directly against the indexing service rather than trusting the journal’s own website.

    What is a red flag for a predatory journal?

    Aggressive, unsolicited invitation emails promising unusually fast peer review are the most cited red flag. Other consistent signals include an editorial board that cannot be independently verified, a scope spanning unrelated disciplines, and article-processing fees disclosed only after acceptance.

    How do you check if a journal is reputable?

    Confirm active listing in DOAJ or an equivalent recognised index, verify the publisher belongs to COPE or a comparable ethics body, check that peer-review policy is published and specific, and confirm the editorial board’s affiliations independently rather than trusting journal-supplied contact details.

    What is considered a predatory journal?

    A predatory journal is one that charges publication fees while failing to provide the genuine editorial and peer-review services legitimate scholarly journals promise, prioritising revenue from article-processing charges over publication quality and research integrity, per definitions developed by COPE and reflected in Frandsen et al.’s peer-reviewed literature review.

    Implications and the path forward

    For institutional research offices, the practical implication is procedural: a single “is this journal Plan S compliant?” check cannot double as a research-integrity sign-off, and treating it that way creates audit risk when a funder or REF-style exercise later asks how a submission venue was verified. Layering a DOAJ/Plan S check with a dedicated predatory journal checker and an indexing cross-check is not duplicative effort — each step tests a distinct failure mode that the others do not cover.

    As open-access mandates expand and predatory operations grow more sophisticated at mimicking legitimate indexing and DOAJ-style transparency signals, the gap between funder-mandate compliance and editorial-integrity verification is likely to widen rather than close. Institutions that formalise the layered workflow now — rather than relying on DOAJ/Plan S status as an implicit predatory-publishing seal of approval — will be better positioned as funders tighten reporting expectations around journal-selection due diligence.

  • AI Act Regulation: Penalties for Research Bodies

    AI Act regulation penalises non-compliance on a three-tier scale: up to €35 million or 7% of global annual turnover for prohibited AI practices, up to €15 million or 3% for high-risk and general-purpose AI failures, and up to €7.5 million or 1% for supplying false information to regulators — whichever figure is higher in each case. For a university, spinout, or research consortium, the exposure is rarely the maximum headline number; it is the cost of misclassifying an admissions algorithm, an exam-proctoring tool, or a recruitment screen as “low risk” when the law says otherwise.

    The EU Artificial Intelligence Act (Regulation (EU) 2024/1689) is the harmonised EU law setting risk-based obligations and penalties for AI systems, and it applies to research institutions as deployers whenever an AI system’s output affects people in the EU.

    What actually counts as an AI Act violation for a research institution?

    Universities and consortia rarely build the AI systems they use — they deploy them. Under the Act, a deployer is any organisation using an AI system in a professional capacity, and deployers carry real obligations even when a vendor built the underlying model. A learning-management platform that scores exam integrity, an HR tool that ranks job applicants, or an admissions filter all fall within scope if they touch people inside the EU, regardless of where the institution is based.

    Non-compliance is not a single offence. It spans failing to conduct a fundamental rights impact assessment, deploying an unregistered high-risk system, ignoring human-oversight requirements, or running a system the Act classifies as prohibited. Each failure mode sits on a different penalty tier.

    How much can an AI Act fine cost, tier by tier?

    Article 99 of Regulation (EU) 2024/1689 sets three fine bands. The final figure is whichever is higher — the flat euro cap or the percentage of worldwide annual turnover — which matters enormously for a university with a large total budget but a tiny AI-specific footprint.

    Violation type Maximum fine Turnover percentage Typical trigger for a research institution
    Prohibited AI practices (Art. 5) €35,000,000 7% Emotion-recognition in exams; covert biometric categorisation of students or staff
    High-risk system / GPAI obligation breaches €15,000,000 3% Recruitment or admissions AI deployed without a rights impact assessment
    Supplying incorrect, incomplete or misleading information €7,500,000 1% Inaccurate disclosures to a market surveillance authority or notified body

    Regulators must apply fines proportionately, weighing the nature, gravity and duration of the breach against the size of the organisation. Article 99(6) directs authorities to consider the interests of small and medium-sized enterprises and start-ups — relevant for university spinouts on constrained budgets — but this softens the number, not the underlying obligation.

    • Fines apply per infringement, so a consortium running several non-compliant systems faces cumulative, not capped, exposure.
    • Turnover is calculated on the whole legal entity’s global turnover, not just the department’s AI-related revenue or grant income.
    • National market surveillance authorities, not the EU AI Office, issue most fines against deployers; the AI Office focuses on general-purpose AI providers.

    Which of your institution’s AI systems could be “prohibited” outright?

    Article 5 bans a specific list of practices regardless of sector, and several map directly onto tools already used in higher education and research settings. A prohibited AI practice cannot be risk-managed into compliance — it must be withdrawn.

    The clearest overlaps for a research institution are:

    • Emotion recognition in educational institutions or workplaces, except for narrow medical or safety purposes — implicating some exam-proctoring and staff-monitoring software.
    • Biometric categorisation systems inferring race, political opinion, trade union membership, religion, or sexual orientation from biometric data.
    • Untargeted scraping of facial images from the internet or CCTV to build a recognition database — relevant to campus security systems built on scraped datasets.
    • Social-scoring-style evaluation of individuals by behaviour or personal traits leading to detrimental treatment unrelated to the original context.

    From 2 December 2026, two further prohibited categories take effect under the Digital Omnibus agreement: AI systems that generate or manipulate non-consensual intimate imagery (“nudifier” applications) and systems used to produce child sexual abuse material. Institutions running student-safeguarding or content-moderation tooling should confirm vendor compliance well ahead of that date.

    Has the Digital Omnibus changed the deadlines that matter?

    Yes, but selectively. The Act’s obligations phase in from its 1 August 2024 entry into force: prohibited practices became enforceable on 2 February 2025 (six months later), and general-purpose AI model obligations followed on 2 August 2025 (twelve months later). Both dates already passed and remain in force.

    In November 2025, the Council and Parliament agreed a “Digital Omnibus” simplification package — analysed by law firms including DLA Piper, Gibson Dunn and White & Case — pushing back the two remaining high-risk deadlines. Stand-alone high-risk systems under Annex III (covering most education, employment and public-service AI) now face obligations from 2 December 2027 rather than August 2026, a sixteen-month reprieve. High-risk AI embedded in regulated products under Annex I moves to 2 August 2028.

    Two dates were not delayed: Article 50 transparency obligations — labelling AI-generated content and disclosing chatbot interactions — still apply from 2 August 2026, the same date the Commission gains full penalty-enforcement powers over general-purpose AI providers. Institutions assuming the whole Act slipped to 2027 risk missing this transparency deadline.

    What should a research institution do now?

    The Digital Omnibus buys time on high-risk classification work, not on everything. A defensible position by August 2026 requires:

    • Inventory every AI system touching students, staff, applicants, or research subjects, tagged against the Article 5 prohibited list and Annex III high-risk categories.
    • Confirm any generative AI or chatbot-facing tool meets the Article 50 transparency requirement before 2 August 2026, independent of the high-risk delay.
    • Assign a named owner — typically in research administration or data governance — to track phased deadlines rather than treat the Act as one compliance date.
    • Apply vendor due diligence to procured AI tools, since deployer obligations do not disappear because a third party built the system.

    Answer-first: common questions on AI Act penalties

    Is the AI Act a regulation?

    Yes. The Artificial Intelligence Act is Regulation (EU) 2024/1689, meaning it applies directly and uniformly across all EU member states without needing national transposing legislation. It entered into force on 1 August 2024, and its obligations phase in over a multi-year timeline extending to 2028.

    What is the EU AI Act in 2026?

    By mid-2026, the prohibited-practice and general-purpose AI rules are already fully enforceable, while most high-risk system obligations have been pushed to December 2027 and August 2028 under the November 2025 Digital Omnibus agreement. Article 50 transparency duties and full GPAI enforcement powers still take effect on 2 August 2026 as originally scheduled.

    Does the UK have to comply with the EU AI Act?

    The UK has no domestic equivalent to the AI Act, but the regulation’s extraterritorial scope reaches UK institutions whenever their AI system’s output is used by, or affects, people in the EU. A UK university running an EU-facing admissions or research-collaboration platform can fall within scope despite being outside the bloc.

    Does the UK have any AI regulation of its own?

    Not a single statute. The UK relies on a sector-by-sector, principles-based approach enforced by existing regulators (ICO, EHRC, Ofcom) rather than one AI Act. This is why UK institutions with EU-facing systems must track both the domestic guidance and the EU regulation’s extraterritorial reach separately.

    What this means for institutional risk management

    The headline €35 million figure will rarely apply to a university outright, but the reputational cost of a prohibited-practice finding is not confined to the fine itself. A finding against emotion-recognition exam software invites scrutiny of every other AI-enabled assessment tool on campus, and funders increasingly expect institutions to demonstrate AI governance maturity, mirroring assurance expectations already familiar from research administration compliance frameworks.

    Treating AI Act regulation as a procurement and governance discipline — inventory, classification, named ownership, phased deadline tracking — converts an open-ended legal risk into a manageable operational programme.

    Where this is heading

    The Digital Omnibus shows the EU will adjust timelines under pressure, but it has not softened the penalty structure, and it has added prohibited categories rather than removed any. Research institutions should expect further phased deadlines and continued extraterritorial reach, and should treat every delay as a planning window, not a reason to deprioritise compliance work.

  • cOAlition S Executive Steering Group Explained

    The cOAlition S Executive Steering Group (ESG) is the body that develops and implements Plan S strategy day to day, taking majority-vote decisions and reporting upward to the funder-led Leaders’ Group. It is chaired by Lidia Borrell-Damián, Secretary General of Science Europe, and is now working alongside Curt Rice, appointed Director in May 2026 after Johan Rooryck’s departure in July 2025.

    The coalition s executive steering group is the operational engine most people mean when they ask “who actually runs Plan S” — as distinct from the Leaders’ Group, which sets overall direction but meets far less frequently. For research administrators trying to work out who to brief, lobby, or route a query to, the distinction matters.

    cOAlition S is an informal alliance of research funders and performers that have publicly committed to implementing the open-access principles of Plan S; it holds no independent legal capacity of its own, according to its published Terms of Reference.

    What is the Executive Steering Group and who sits on it?

    The Executive Steering Group is the standing body responsible for developing cOAlition S’s strategy and overseeing its implementation across member organisations. It sits below the Leaders’ Group in the governance hierarchy but is where most of the substantive, ongoing work happens.

    According to cOAlition S’s published governance roster, current and recent ESG representatives include:

    • Lidia Borrell-Damián (Chair) — Secretary General, Science Europe
    • Zoé Ancion — ANR, French National Research Agency
    • Michael Arentoft — European Commission
    • Rachel Bruce — UKRI, UK Research and Innovation
    • Ian Coltart — World Health Organisation
    • Ashley Farley — Gates Foundation
    • Mongezi Mdhluli — South African Medical Research Council
    • Bodo Stern — HHMI, Howard Hughes Medical Institute

    Two cOAlition S Office roles — a Programme Manager and a Communications Manager — sit in the ESG in a Secretariat capacity, and Marc Schiltz, an architect of the original Plan S principles, continues as a non-voting adviser. Because national funder representatives rotate, administrators should treat any published roster as a snapshot rather than a permanent list.

    How does the ESG fit into cOAlition S’s wider governance?

    cOAlition S runs a four-layer structure: the Leaders’ Group (heads of funding and performing organisations, who approve overall strategy and budget), the Executive Steering Group (which develops and executes that strategy), an Experts Group (technical working groups), and the cOAlition S Secretariat, which is hosted by OPERAS AISBL in Brussels and provides day-to-day administrative and communications support.

    Body Role Chair / lead Decision power
    Leaders’ Group Sets overall Plan S strategy and budget Prof. Mari Sundli Tveit, Chief Executive, Research Council of Norway Highest authority; approves ESG proposals
    Executive Steering Group Develops and implements strategy; runs operations Lidia Borrell-Damián, Science Europe Majority vote; reports to Leaders’ Group
    Secretariat / Office Administrative, financial and communications support Curt Rice, Director Executes decisions; no independent vote
    Experts Group Technical and policy working groups Rotating co-chairs Advisory input to ESG

    The Secretariat’s own budget illustrates how much the operation has contracted: cOAlition S’s published accounts show total Office spending of €545,167 in 2025, down from €1,108,186 in 2024, with staffing falling from roughly 3 full-time-equivalent posts in 2024 to 2 in 2025 — consistent with reporting that cOAlition S is scaling back its ambitions and shifting focus toward funding sustainability.

    Who leads the ESG now Curt Rice has replaced Johan Rooryck?

    Prof. Johan Rooryck, cOAlition S’s Executive Director since 2019, left the role on 3 July 2025 after overseeing the coalition’s expansion to 28 research funding and performing organisations. Following his departure, the Executive Steering Group itself took on interim oversight of operations while cOAlition S undertook a strategic review.

    cOAlition S announced on 13 May 2026 that Curt Rice, former rector of Oslo Metropolitan University with more than three decades in Norwegian and international higher education, would become its new Director. Notably, the title changed from “Executive Director” to “Director” — a small but real signal of a leaner operating model. The appointment coincided with the adoption of cOAlition S’s 2026–2030 Strategy, which administrators should read as the current reference document for near-term priorities.

    Under the Terms of Reference, the Director leads the Secretariat team, reports to the Chair of the Executive Steering Group, and acts as cOAlition S’s main spokesperson — meaning press and policy enquiries typically route through this office rather than directly to individual ESG members.

    What does the ESG actually decide, and how?

    The Executive Steering Group takes decisions by majority vote among its members and reports those decisions to the Leaders’ Group. Its remit covers developing strategic input, overseeing joint programmes and funding streams, and directing cOAlition S’s public communications through the Office.

    In practice this means the ESG — not the Leaders’ Group — is where day-to-day questions about Plan S implementation, transformative journal assessments, and funder-alignment issues get resolved before reaching the funders’ principals. The Leaders’ Group retains final sign-off on strategy and budget, but rarely intervenes at the operational level.

    Answer-first Q&A

    Who are the members of the cOAlition S Executive Steering Group?

    The ESG is chaired by Lidia Borrell-Damián of Science Europe and includes representatives from funders such as UKRI, the European Commission, ANR, WHO, the Gates Foundation, HHMI, and the South African Medical Research Council, plus non-voting cOAlition S Office staff. Membership rotates as national funders change their delegates.

    What is the difference between the Leaders’ Group and the Executive Steering Group?

    The Leaders’ Group comprises heads of member organisations and approves overall Plan S strategy and budget. The Executive Steering Group develops that strategy in detail, runs day-to-day implementation, and takes majority-vote decisions, reporting upward to the Leaders’ Group rather than acting independently.

    Who is the current Director of cOAlition S?

    Curt Rice became Director on 13 May 2026, succeeding Johan Rooryck, who departed on 3 July 2025. Rice previously served as rector of Oslo Metropolitan University and leads the Secretariat team, reporting to the Chair of the Executive Steering Group.

    Does the Executive Steering Group have the final say on Plan S policy?

    No. The ESG develops strategy and takes operational decisions by majority vote, but the Leaders’ Group holds final authority over overall strategy and budget. The ESG’s role is to execute and report, not to set Plan S’s ultimate direction unilaterally.

    What this means for research administrators

    For an institution needing to raise a Plan S implementation question, engagement route should generally go through the Secretariat/Office first — now under Curt Rice’s Directorship — rather than direct outreach to individual Executive Steering Group members, who serve in a part-time, delegated capacity alongside their home-organisation roles.

    Administrators tracking funder-mandate compliance for research administration purposes should also note the contraction in cOAlition S’s own resourcing: a shrinking Secretariat budget and headcount suggests slower turnaround on ad hoc queries and a narrower work programme under the 2026–2030 Strategy than in the coalition’s 2019–2023 growth phase.

    • Route policy and compliance queries to the Secretariat/Office, not individual ESG delegates.
    • Cite the Terms of Reference and governance page directly when briefing institutional leadership — both are publicly hosted by cOAlition S.
    • Expect the 2026–2030 Strategy, not the original 2018 Plan S text, to be the live reference point for near-term commitments.

    cOAlition S’s governance has moved from a growth-and-advocacy phase under Rooryck to a leaner, sustainability-focused phase under Rice and Borrell-Damián’s ESG chairmanship. Administrators who track this shift — rather than relying on the original 2018 Plan S announcement — will have a more accurate picture of who holds real influence over open-access mandates in 2026 and beyond.

  • AI Governance UK: What Universities Hire For

    AI governance UK hiring is real but narrow: employers are advertising standalone “AI governance” titles mainly in consultancies and tech firms, while UK universities and research funders are folding AI oversight into existing research-governance, integrity and data-protection roles rather than minting a new job category. Certifications such as IAPP’s AIGP and the ISO/IEC 42001 Lead Auditor credential map to genuinely different parts of that work — one to policy and compliance, the other to formal audit.

    AI governance is the set of policies, controls and accountability structures an organisation uses to ensure AI systems are developed, procured and used safely, lawfully and transparently across their lifecycle.

    What is driving the AI governance UK hiring wave?

    Search interest in AI governance credentials has accelerated sharply. Keyword-demand data tracked into June 2026 shows “ai governance certification” search volume in the UK up 129% year-on-year, and “ai governance job” postings now surface daily on LinkedIn, Indeed and Totaljobs for roles spanning “Director AI Governance” to “Responsible AI Specialist.”

    The trigger is regulatory, not academic. Under the government’s 2023 White Paper AI regulation: a pro-innovation approach, the UK deliberately chose not to pass a single AI statute. Instead, existing regulators — the Information Commissioner’s Office, Ofcom and the Competition and Markets Authority — enforce five cross-sector principles: safety, security and robustness; appropriate transparency and explainability; fairness; accountability and governance; and contestability and redress.

    That distributed model pushes the compliance burden into individual organisations, which is exactly the vacuum “AI governance” job titles are appearing to fill. Employers with EU exposure are also hiring against the EU AI Act, whose obligations extend to UK organisations that deploy AI systems into EU markets.

    What are UK research institutions actually hiring for?

    A survey of current academic job boards shows standalone “AI Governance Officer” titles remain rare in UK higher education. What is expanding instead is AI content grafted onto established research-governance and research-integrity posts.

    • The University of Oxford has run a postdoctoral researcher post inside its Oxford AI Governance Initiative, focused on AI and risk research rather than institutional compliance.
    • The University of Bristol advertises a Head of Research Governance role — the University’s lead officer for research regulation, ethics and integrity across human participants, tissue and data, a remit now stretching to cover AI-enabled research methods.
    • The Alan Turing Institute’s AI Ethics and Governance in Practice programme, an eight-workbook resource for project teams, functions as the de facto training reference most UK research-intensive institutions point staff toward, in place of a dedicated internal certification.
    • The Russell Group published sector-wide principles on generative AI in education in January 2025, giving member universities a shared policy baseline rather than each hiring separate AI governance specialists.

    The pattern is consistent: research institutions are governing AI through their existing research-integrity, ethics-committee and data-governance infrastructure, supplemented by sector guidance from the Turing Institute and Russell Group, rather than building a parallel AI governance function from scratch.

    Which certifications map to the job?

    Two credentials dominate current job advertisements, and they are not interchangeable. IAPP’s AIGP is a policy and compliance credential; ISO/IEC 42001 Lead Auditor is a formal management-systems audit qualification built on the international AI management system standard published in 2023.

    Certification Body Format Best fit
    IAPP AIGP International Association of Privacy Professionals 100 multiple-choice questions, 180 minutes Privacy, legal and policy staff who need to interpret AI law and risk, not audit systems
    ISO/IEC 42001 Lead Auditor Accredited training bodies (e.g. PECB, BSI) against the ISO/IEC 42001:2023 standard Multi-day course plus exam Auditors and compliance managers validating a formal AI management system (AIMS)
    Vendor foundational courses (e.g. Securiti) Commercial vendors Short on-demand modules, 2–3 hours Awareness-level onboarding, not a substitute for either credential above

    Neither certification is a licence to practise. Both function as evidence that a candidate has studied a defined body of knowledge — AIGP for law and policy, ISO/IEC 42001 Lead Auditor for management-system audit method — which is why job advertisements almost always list them as “desirable,” not mandatory.

    Genuine career pathway or rebadged compliance role?

    The honest answer is both, depending on sector. In consultancies and large tech employers, “AI governance” is emerging as a distinct, senior, well-paid track — UK job boards currently list Director-level AI governance roles paying well above general compliance-officer rates. In research institutions, it is largely a rebadged extension of research integrity, data protection and ethics-committee work that already existed.

    That does not make it hollow. It means the credential value differs by employer type: a corporate AI governance hire benefits most from IAPP’s AIGP or an ISO/IEC 42001 audit qualification, while a university research-governance officer gains more from Turing Institute and Russell Group sector guidance, since their day job already sits inside an ethics and integrity framework those resources were built for.

    Which is the best AI governance certification?

    There is no single “best” credential; fit depends on function. IAPP’s AIGP suits policy, legal and privacy specialists working across jurisdictions and the EU AI Act. ISO/IEC 42001 Lead Auditor suits professionals who must formally audit an organisation’s AI management system rather than advise on policy.

    Is AI governance certification worth it?

    It is worth it for candidates whose work already touches AI policy, compliance, risk management or privacy, where it demonstrates structured knowledge to employers. It adds little on its own without underlying domain experience, since UK job advertisements consistently list these credentials as desirable evidence rather than a mandatory gate.

    How to become an AI governance professional?

    Most current UK postholders arrive via data protection, legal, risk or research-integrity backgrounds, then add AI-specific knowledge through a credential such as AIGP or ISO/IEC 42001. Direct entry-level “AI governance” hiring remains limited; experience in an adjacent regulated function is the more common route in.

    What skills are needed for AI governance?

    Core skills include risk assessment, regulatory interpretation, bias and fairness evaluation, and stakeholder communication across legal, technical and leadership teams. Employers also expect familiarity with the AI lifecycle and enough technical literacy to question a model’s design without needing to build one.

    What this means for research institutions

    For UK research administrators and institutional leaders, the near-term implication is not to create a new “AI Governance Officer” post by default. It is to audit whether existing research-integrity, data-governance and ethics-committee functions already cover AI risk, and where they do not, to close the gap with targeted training — Turing Institute workbooks or an IAPP AIGP course — rather than an immediate new hire.

    Over the next 12–24 months, expect the corporate and research-sector paths to converge somewhat as funders begin asking institutions to document AI oversight within grant compliance and wider research administration processes. Institutions that get ahead of that by mapping certifications to real duties now, rather than hiring a title, will be better placed when funders start asking for evidence.