CASRAI Dictionary

Author: MCP Service

  • GAO’s 2026 Public Access Report: Budget Impact on Universities

    The GAO federal research public access report 2026 (GAO-26-107738, published 21 May 2026) finds that most federal agencies have not analysed how rising publication fees will affect their research budgets, and warns that government-wide public access publishing costs could reach $1 billion a year and could triple if current fee-increase trends continue. The report, formally titled Federal Research: Agencies Should Better Manage Anticipated Publishing Cost Increases Amid Shift to Public Access, is the U.S. Government Accountability Office’s first detailed cost audit of the 2022 zero-embargo public access mandate, and it carries direct budget-planning implications for every university and hospital research office managing federally funded output.

    GAO-26-107738 is a Government Accountability Office report examining whether nine federal funding agencies have adequately planned for the publication costs created by the 2022 White House Office of Science and Technology Policy (OSTP) directive requiring immediate, free public access to federally funded research.

    What did GAO’s 2026 public access report find?

    GAO reviewed nine federal agencies — the National Institutes of Health (NIH), the Departments of Defense, Energy, Transportation and Agriculture, NASA, the National Science Foundation (NSF), the Social Security Administration, and the Nuclear Regulatory Commission (NRC) — against the 2022 OSTP public access guidance. The audit found that only NIH has developed a plan to manage anticipated publishing cost increases; every other agency reviewed had not analysed how rising fees could affect its research programmes or budgets.

    GAO also examined OSTP’s own 2024 economic analysis of the public access shift and found it did not fully address all five elements GAO requires of a sound federal economic analysis. Critically, OSTP’s analysis did not estimate the policy’s potential costs — the same gap the agency-level reviews found individually. GAO issued 11 recommendations across the nine agencies and OSTP; as of publication, all 11 remained open. Four agencies concurred with GAO’s recommendations and five offered no comment.

    Why are public access publishing costs rising now?

    The 2022 OSTP guidance (commonly known as the Nelson Memo) ended the option of a 12-month embargo, requiring immediate free access to federally funded research from 2026 onward. Under a subscription model, libraries paid publishers for access after the fact; under a zero-embargo, article-processing-charge (APC) model, someone must pay before publication, and that cost has shifted onto authors, their institutions, or the funding agency itself.

    GAO projects that public access publishing costs could reach up to $1 billion a year for the federal government, rising to roughly triple that figure if historical APC inflation patterns persist. The Scholarly Publishing and Academic Resources Coalition (SPARC), responding to the report, separately estimated the shift could add $3-4.5 billion in publisher fees over the next five years if current market structures are left unaddressed. GAO’s report also flags an integrity concern raised by publishers and universities it interviewed: because pay-to-publish models reward publishers per accepted article, they can create incentives to lower acceptance thresholds — a dynamic GAO links to the proliferation of paper mills and to at least one major publisher’s retraction of more than 11,000 articles after systematic fraud was traced to its APC-funded workflow.

    Which federal agencies are prepared for the cost increase?

    Compliance was uneven. Seven of the nine agencies reviewed had issued updated public access plans or policies at the time of the audit; the Department of Transportation and the NRC were still drafting theirs. Of the seven completed plans, only five fully met OSTP’s guidance — NSF and USDA fell short specifically on reuse rights, meaning their policies did not adequately specify how others may share, adapt, or build on the published research.

    Agency Updated public access plan Fully meets OSTP guidance Cost-increase management plan
    NIH Yes Yes Yes — the only agency reviewed
    Defense (DOD) Yes Yes No
    Energy (DOE) Yes Yes No
    NASA Yes Yes No
    Social Security Administration Yes Yes No
    NSF Yes No — reuse-rights gap No
    USDA Yes No — reuse-rights gap No
    Transportation (DOT) Drafting N/A No
    Nuclear Regulatory Commission Drafting N/A No

    This table is a first-party synthesis of GAO-26-107738’s findings; it does not appear in this form in the underlying report or in current news coverage, and it is the fastest way for a research office to see where its primary funders stand.

    What should university research offices do now?

    Research administrators should treat GAO’s findings as an early-warning signal, not a distant risk. Federal agencies without a cost-management plan have no committed strategy for absorbing APC increases — which means the exposure defaults to grant budgets and, ultimately, to institutional funds when awards do not cover rising fees.

    • Audit APC exposure per funder. Map which of your institution’s federal awards come from agencies that, per the table above, still lack a cost-management plan — that is where budget risk is least mitigated centrally.
    • Build APC lines into grant budgets explicitly. Do not assume publication costs are a rounding error; NIH’s own recognition of this risk (the one agency with a management plan) is itself a signal of expected magnitude.
    • Track reuse-rights language in funder policies. NSF and USDA’s reuse-rights gap flagged by GAO affects how grantees may license and redistribute outputs — confirm your compliance office is not relying on outdated funder guidance.
    • Monitor agency-designated repository requirements. Public access compliance depends on depositing accepted manuscripts or data in the correct agency-designated repository, not merely publishing open access — confirm current repository mappings before submission, as these can change alongside policy updates.
    • Watch for OSTP’s revised economic analysis. GAO directed OSTP to redo its 2022 cost analysis; any resulting guidance update could change compliance timelines or funding formulas across all federally funded programmes.

    Common questions about GAO-26-107738

    What is GAO-26-107738?

    GAO-26-107738 is a Government Accountability Office report, published 21 May 2026, examining whether nine federal research-funding agencies have adequately planned for the publication cost increases created by the 2022 zero-embargo public access mandate.

    How much could public access publishing costs reach for federal agencies?

    GAO estimates costs could reach up to $1 billion a year government-wide, and could roughly triple if historical publication-fee inflation continues. SPARC separately projects $3-4.5 billion in cumulative publisher fees over five years under current market conditions.

    Which federal agencies have public access cost plans in place?

    Of the nine agencies GAO reviewed, only the National Institutes of Health has developed a plan specifically to manage anticipated publishing cost increases; the other eight — including DOD, NASA, NSF and USDA — had not analysed the budget impact at the time of the review.

    Does the GAO report to Congress?

    Yes. GAO is a non-partisan legislative-branch agency that conducts audits at the request of congressional committees; GAO-26-107738 was produced for Congress and its 11 recommendations direct specific corrective actions by named federal agencies and OSTP.

    What happens next?

    All 11 of GAO’s recommendations remain open, which means implementation now depends on individual agency action and on OSTP producing a more rigorous economic analysis of its 2022 guidance. For research offices, the practical implication is that funder-side cost absorption cannot be assumed — budget lines, subaward terms, and library transformative-agreement negotiations should be reviewed against each funder’s current readiness, not against the mandate’s original 2022 intent.

    Institutions that build APC forecasting into their research administration workflows now — before agencies finalise cost-management plans — will be better positioned than those waiting for federal guidance to catch up with the mandate it created.

  • Certificates of Confidentiality NIH: Admin Guide to the Automatic Rule

    Certificates of Confidentiality (CoCs) for NIH-funded human subjects research have been issued automatically since 1 October 2017 — no application, no physical document, and no opt-out. The protection attaches as a term and condition of the award itself, documented in the Notice of Award and the NIH Grants Policy Statement, not in a separate certificate. Research administrators and IRB staff who still search for “the certificate” to upload, or assume the rule only covers clinical trials, are working from an outdated model of how the policy actually functions.

    A certificate of confidentiality is a federal legal protection, issued under 42 U.S.C. § 241(d), that prohibits investigators and institutions from being compelled to disclose identifiable, sensitive research information in any federal, state, local, civil, criminal, administrative, or legislative proceeding.

    This article clarifies four areas where institutional practice most often lags the 2017 policy change: automatic scope, IRB documentation, disclosure exceptions, and the perpetual-versus-expiring duration rules that trip up administrators managing no-cost extensions and renewals.

    What changed in 2017, and why

    Before October 2017, investigators had to apply for a Certificate of Confidentiality through NIH’s Certificate Kiosk, a discretionary process that left gaps whenever an application was late, denied, or forgotten. Section 2012 of the 21st Century Cures Act (Public Law 114-255) amended 42 U.S.C. § 241(d) to make issuance mandatory, not discretionary, for federally funded research meeting the statutory criteria.

    NIH implemented this through policy notice NOT-OD-17-109, effective for grants, cooperative agreements, contracts, and intramural projects ongoing on or after 13 December 2016 — a retroactive-to-ongoing-award detail that research administrators auditing older, still-active awards frequently overlook.

    The practical effect: eligibility determination shifted from NIH’s grants management staff to the institution. NIH no longer decides who qualifies; the principal investigator and the institutional signing official must determine whether a project meets the statutory definition and act accordingly.

    What research is actually covered

    The automatic CoC covers any NIH-funded project — grant, cooperative agreement, contract, or intramural study — that collects or uses “identifiable, sensitive information,” a term defined jointly by the CoC policy and 42 U.S.C. § 241(d) itself. This is broader than most institutional research offices initially communicated.

    Coverage extends to:

    • All human subjects research, including exempt categories where participants remain identifiable
    • Biospecimens that are identifiable, or carry even a small re-identification risk when combined with other data sources
    • Individual-level human genomic data, generated or used, regardless of whether the data is nominally de-identified
    • Any other information where current statistical or scientific methods create a non-trivial re-identification risk

    The recurring error is administrative: many IRB offices historically told investigators that CoCs only applied to “sensitive” topics such as substance use or HIV status. Those remain paradigm examples, but the trigger is the nature of the identifiable data, not the subject matter alone — a genomic dataset from an otherwise low-risk survey study can independently trigger coverage.

    What counts as IRB documentation now

    This is the most common source of confusion research administrators report: there is no artifact called “the certificate” to file. Under the automatic policy, the Notice of Award and the NIH Grants Policy Statement are the documentation. IRB offices that continue to ask investigators to “upload the CoC” are asking for something that no longer exists in that form.

    What IRBs should instead verify and record:

    Documentation era What served as proof Where it lived
    Pre-October 2017 A signed certificate document from NIH’s Certificate Kiosk Uploaded to IRB protocol file
    Post-October 2017 (NIH-funded) Notice of Award + NIH Grants Policy Statement terms Grants management record, referenced in IRB protocol
    Non-NIH-funded research Application submitted via the eRA Commons CoC request system NIH confirmation email, uploaded to IRB protocol

    Institutions such as the University of North Carolina and the University of Pittsburgh have updated their standard operating procedures to shift the PI’s documentation burden toward confirming applicability and updating consent language, not chasing a certificate. Auditors should check for a documented applicability determination and updated consent form, not a missing PDF.

    Informed consent forms must describe the CoC’s protections and its limits. NIH provides suggested consent language, but inserting it is the institution’s responsibility — omission is a genuine, auditable compliance gap distinct from the (non-existent) missing certificate.

    The disclosure exceptions everyone forgets

    A Certificate of Confidentiality is frequently — and incorrectly — described to research participants and IRB panels as an absolute shield. It is not. The CoC protects only against legally compelled disclosure; it does not restrict voluntary disclosure by investigators or by participants themselves.

    Recognised exceptions to CoC non-disclosure protection include:

    • Disclosure required by other federal, state, or local law (for example, mandatory reporting of communicable disease or child abuse)
    • Disclosure with the research participant’s voluntary, written consent
    • Disclosure for the participant’s medical treatment, with consent
    • Requests from authorised HHS personnel for audit, program evaluation, or investigation of grantees
    • Release required under the federal Food, Drug, and Cosmetic Act
    • Disclosure to other researchers conducting research that complies with applicable human subjects regulations

    A second, less-discussed obligation concerns sub-recipients: institutions must ensure any sub-recipient handling covered information, even one not directly NIH-funded, adheres to the same disclosure restrictions. Multi-site studies with subcontracted data-collection sites are a common place this flow-down documentation is missed during subaward setup.

    Duration: perpetual protection, expiring eligibility

    Two distinct clocks run simultaneously, and conflating them is a frequent administrative error. Protection for data already collected during the NIH funding period is permanent — it does not lapse when the grant ends, and it extends to all copies of that data held anywhere.

    What does lapse is eligibility for new coverage. If NIH funding ends but the study continues collecting new identifiable, sensitive data, that new data is not automatically protected — the institution must obtain a fresh CoC via the non-NIH-funded application route. Protection continues uninterrupted through an approved no-cost extension, since the award remains active NIH funding throughout.

    Research administrators managing awards approaching their project period end date should treat “does data collection continue past the award end date” as a standing checklist item, distinct from any other closeout task.

    Common questions research administrators ask

    What is an NIH Certificate of Confidentiality?

    A Certificate of Confidentiality is a federal protection under 42 U.S.C. § 241(d) that prevents investigators from being compelled to disclose identifiable, sensitive research participant information in legal proceedings. Since October 2017, NIH issues it automatically as a condition of funding rather than as a separate application-based document for grants meeting the statutory criteria.

    How is a Certificate of Confidentiality obtained for non-NIH-funded research?

    Investigators without NIH funding must apply through the eRA Commons online CoC request system, after their IRB has approved a protocol containing the required consent language. NIH verifies eligibility and institutional details, typically within 48 hours of submission, before granting coverage for that specific project.

    When must a new Certificate of Confidentiality be obtained?

    A new CoC is required whenever identifiable, sensitive data collection continues after NIH funding ends, since automatic protection only covers data gathered during the active funding period. Existing collected data remains protected permanently; only newly collected information after the funding lapse falls outside the original automatic grant.

    Can a subpoena override a Certificate of Confidentiality?

    No — a valid Certificate of Confidentiality legally bars compelled disclosure even in response to a subpoena, court order, or other legal demand, unless one of the statutory exceptions applies. Institutions typically require researchers to notify university counsel immediately upon receiving any such demand rather than responding directly.

    Implications for research administration offices

    The shift from application-based to automatic issuance moved compliance risk from “did we remember to apply” to “did we correctly determine applicability and document it.” CoC compliance now belongs in the same review lane as data management plans and protocol amendments, not a one-off grants-office task completed at award setup and forgotten.

    Institutions that have not updated consent-form templates, subaward agreements, and IRB checklists since 2017 carry latent audit exposure, particularly for long-running, multi-site, or genomic-data studies where the scope of “covered information” is easy to underestimate.

    Looking ahead

    As NIH-funded research increasingly generates genomic and biospecimen data with independent re-identification risk, the automatic CoC’s broad statutory scope — not the narrower “sensitive topics” heuristic many offices still apply — will matter more, not less. Research administrators who treat CoC compliance as a documentation and consent-language exercise, rather than a certificate to file away, will be better positioned as NIH and other funders continue tightening human subjects data protection expectations.

  • European Research Area Act 2026: The 3% R&D Investment Target Explained

    The European Research Area Act 2026 is a planned EU regulation that will attach binding legal mechanisms to the long-standing target of investing 3% of GDP in research and development. Announced in the Competitiveness Compass for the EU (COM(2025) 30, 29 January 2025) and built on the ERA Policy Agenda 2025–2027, the Act moves the EU’s R&D investment ambition from a voluntary benchmark to a governed, monitored commitment. A Commission proposal is expected before summer 2026, following a Call for Evidence, a public consultation, and a European Parliament resolution adopted on 10 March 2026.

    The European Research Area (ERA) is the European Commission’s framework for a single, borderless market for research, innovation and technology across the EU, in which Member States align research policies, funding, and researcher mobility. The ERA Act is the first attempt to give this framework binding legal force.

    What is the European Research Area Act?

    The European Research Area Act is the European Commission’s forthcoming legislative instrument to give the ERA — previously a policy framework built on non-binding recommendations — a coherent, enforceable legal basis. It follows the Pact for Research and Innovation in Europe, a Council Recommendation adopted in November 2021 that set common values and priority areas but carried no binding obligations.

    According to the Commission’s own ERA Act platform, the initiative responds to “fragmented regulatory frameworks, uneven R&D investment, and barriers to knowledge sharing” across the EU research and innovation ecosystem. Reporting from Science|Business and civil-society coalitions describes the emerging proposal around four pillars:

    • Safeguarding the freedom of scientific research through dedicated legislation
    • Establishing a strong, binding and coherent ERA governance structure
    • Embedding the 3% R&D investment target and improving alignment of public and private funding with EU strategic priorities
    • Enhancing researcher circulation, careers and working conditions, including mobility, gender equality and knowledge security

    The Act is explicitly linked to the parallel European Innovation Act, which will address market-side barriers to commercialising research, and to the Commission’s “Choose Europe for Science” agenda aimed at attracting global research talent.

    Why is the Commission legislating in 2026, and what is the timeline?

    The Commission originally scheduled the ERA Act for 2027 but brought it forward after the Competitiveness Compass identified research and innovation fragmentation as a drag on EU competitiveness. Ekaterina Zaharieva, the EU Commissioner for Startups, Research and Innovation, described the planned Act in September 2025 as “ambitious but realistic,” signalling that the Commission intends genuine legal obligations rather than another voluntary agenda.

    The process has moved through several concrete, dated milestones:

    Milestone Date
    Competitiveness Compass for the EU, COM(2025) 30 29 January 2025
    ERA Act Call for Evidence opens 6 August 2025
    Call for Evidence closes (178 contributions, 29 countries) 10 September 2025
    Public consultation questionnaire closes 23 January 2026
    Commission publishes Call for Evidence analysis report 4 February 2026
    European Parliament resolution on the upcoming ERA Act 10 March 2026
    Commission legislative proposal (expected) Before summer 2026

    The Call for Evidence alone drew 178 contributions from 29 countries, according to the Commission’s published analysis — a scale of stakeholder engagement that indicates the Act is being treated as a substantive legislative undertaking, not a policy communication.

    How will the Act attach legal mechanisms to the 3% GDP R&D target?

    The 3%-of-GDP R&D investment target is not new. It dates to the Barcelona European Council of March 2002, which set the goal of raising EU R&D spending to 3% of GDP by 2010, with two-thirds expected from private investment and one-third from public funding. The target was carried forward through the Europe 2020 strategy and, most recently, the ERA Policy Agenda 2025–2027, but EU average R&D intensity has persistently undershot it for two decades.

    What changes under the ERA Act is enforceability. Rather than restating the 3% ambition as an aspiration, the Act is expected to embed it within binding governance mechanisms — monitoring obligations, alignment requirements between EU and national funding instruments, and reporting duties tied to Member States’ national reform and investment plans. This shifts the target from a statistic tracked in Commission reports to a legal reference point Member States must account against.

    This is a materially different approach from the Pact for Research and Innovation in Europe, which asked Member States to “endeavour” toward the target with no compliance architecture. Research administrators tracking national R&D budget lines should expect the ERA Act to introduce the kind of structured reporting cycle already familiar from Horizon Europe’s own performance monitoring.

    What does this mean for Horizon Europe associated countries?

    Horizon Europe associated countries — including Norway, Iceland, Israel, Ukraine, and the United Kingdom (associated from 1 January 2024) — participate in EU framework programme funding without being EU Member States. The ERA Act, as an EU legislative act, is expected to bind Member States directly; association agreements do not automatically extend domestic investment-target obligations to associated third countries.

    This creates a practical asymmetry research offices should track: associated countries’ researchers and institutions can compete for Horizon Europe funding and access ERA-linked infrastructure and mobility schemes, but their governments are unlikely to face the same binding 3% reporting duties as EU Member States. Institutions in associated countries should monitor whether the eventual Act text extends any governance or reporting provisions to association agreements, as this has not yet been confirmed in any published Commission text.

    Answer-first Q&A

    What is the European Research Area?

    The European Research Area (ERA) is the European Commission’s framework for a single, borderless market for research, innovation and technology across the EU. It coordinates national research policies and systems and supports free movement of researchers, scientific knowledge, and innovation between Member States.

    What are the priorities of the European Research Area?

    ERA priorities include more effective national research systems, optimal transnational cooperation, an open labour market for researchers, gender equality in research, and improved circulation of scientific knowledge. The ERA Policy Agenda 2025–2027 operationalises these priorities into time-bound actions for Member States.

    What is the 3% GDP research and development investment target?

    The 3% GDP R&D target commits the EU to raising combined public and private research spending to 3% of GDP, split roughly two-thirds private and one-third public. Set at the 2002 Barcelona European Council, it remains unmet EU-wide and is the ERA Act’s central binding-mechanism focus.

    Will the ERA Act apply to Horizon Europe associated countries?

    The ERA Act is expected to bind EU Member States as an EU legislative act; Horizon Europe association agreements do not automatically extend national 3% investment-target obligations to associated countries such as Norway or the UK. Scope for associated countries has not yet been confirmed in a published legal text.

    Implications for research administrators and institutions

    For institutional research offices, funders, and national research administration bodies, the ERA Act signals a shift toward auditable, comparable national R&D investment reporting. Research administration teams should expect closer alignment between EU-level ERA governance and domestic funding-agency reporting cycles, similar to how Horizon Europe already requires structured performance data from participating institutions.

    Practical preparation steps include:

    • Mapping current national R&D investment reporting against the ERA Policy Agenda 2025–2027 actions to identify gaps before binding obligations take effect
    • Tracking the Commission’s legislative proposal, expected before summer 2026, for confirmed governance and monitoring mechanisms
    • Reviewing whether institutional funding applications reference ERA priorities such as researcher mobility, open science, and gender equality, since these are likely compliance touchpoints under the Act

    Institutions with dedicated research administration capacity are better positioned to respond quickly once the proposal text and accompanying governance requirements are published.

    Outlook: what happens next

    The Commission’s legislative proposal is expected before summer 2026, after which the ERA Act will follow the ordinary EU legislative procedure through the European Parliament and Council — a process that typically takes 18 to 24 months before final adoption and Member State transposition. Research administrators, funders, and institutional leaders should treat the current pre-proposal period as the window to influence scope, particularly regarding associated-country coverage and the specific reporting mechanisms attached to the 3% target, rather than waiting for a finalised text to begin preparation.

  • NIHR Open Access Policy 2026: What’s Required and What’s Under Review

    The NIHR open access policy requires that peer-reviewed research articles funded in whole or in part by the National Institute for Health and Care Research be made freely available immediately on publication, deposited in Europe PMC, and published under a CC BY licence. The policy took effect for articles submitted on or after 1 June 2022. NIHR has since reviewed the policy to confirm it remains fit for purpose across its portfolio, and the review process — not just the original mandate — is what research offices now need to track.

    The NIHR open access policy is the set of rules issued by the National Institute for Health and Care Research requiring that research articles it funds be published with no access barrier and no embargo, on terms that permit free reuse. It sits alongside, but is not identical to, the UK Research and Innovation (UKRI) open access policy and the Wellcome open access policy — three UK funder mandates that are frequently confused with one another despite meaningful differences in scope, deposit routes and licensing flexibility.

    What does the NIHR open access policy actually require?

    NIHR’s policy applies to peer-reviewed research articles — including unsolicited reviews and conference papers — funded wholly or partly through NIHR Programmes, Personal Awards, or Infrastructure. Monographs, book chapters and edited collections fall outside scope. For any in-scope article submitted on or after 1 June 2022, NIHR’s own compliance form confirms the article must be deposited in Europe PMC and made immediately, permanently available with no embargo period.

    Three conditions apply together, not as alternatives:

    • Immediate deposit. The version of record or the author’s accepted manuscript must appear in Europe PMC on the day of formal publication — there is no allowance for a delayed or embargoed release.
    • CC BY licensing. Articles must carry a Creative Commons Attribution (CC BY) licence, permitting reuse and adaptation — including commercial reuse — provided the original authors are credited. A more restrictive CC BY-ND (no-derivatives) licence is permitted only with prior NIHR approval, and Crown Copyright outputs instead use the Open Government Licence.
    • Data access statement. Every publication must state how the underlying research data can be accessed, or explain clearly why access is restricted (for example, patient confidentiality or commercial sensitivity).

    Authors submitting to a subscription journal without a compliant route must also include a rights-retention statement in the funding acknowledgement and cover letter, asserting the right to deposit the accepted manuscript under CC BY regardless of the publisher’s standard licence terms.

    What is the NIHR Open Access policy review?

    Separately from the 2022 mandate itself, NIHR maintains an active Open Access policy review — a standing process to check the policy is “fit for the future” across the full breadth of NIHR’s research portfolio, which spans clinical trials, applied health research, infrastructure awards and early-career fellowships with very different publication norms. NIHR has stated that public feedback directly informed revisions to the published policy, indicating the review is a live governance mechanism rather than a one-off launch document.

    For research offices, this distinction matters. A policy under active review can change scope, licensing exceptions, or compliance deadlines with comparatively short notice — unlike a funder mandate that has been static for several years. Institutions that treat the 2022 text as permanently fixed risk missing amendments that emerge from the review cycle.

    How does NIHR’s policy compare with UKRI and Wellcome?

    NIHR, UKRI and Wellcome each mandate immediate open access with a CC BY licence as the default, but they diverge on effective dates, scope and flexibility. This is the single most common point of confusion for multi-funder research offices.

    Funder Effective date (journal articles) Deposit location Default licence Notable flexibility
    NIHR 1 June 2022 (in-scope submissions) Europe PMC CC BY (CC BY-ND with approval) Dedicated open access funding envelope for eligible awards; policy under ongoing review
    UKRI 1 April 2022 (journal articles); 1 January 2024 (monographs, book chapters, edited collections) Europe PMC or an institutional/subject repository CC BY (CC BY-ND permitted in limited cases) Phased rollout separating journal articles from long-form outputs
    Wellcome 1 January 2021 Europe PMC CC BY (no CC BY-ND route) No embargo tolerance; preprint deposit actively encouraged alongside the final article

    The practical effect: an NIHR- and UKRI-co-funded article must satisfy the earlier of the two applicable deadlines and the stricter of the two licensing conditions, while a Wellcome co-funded article has no CC BY-ND fallback at all. Research administrators managing co-funded grants should map compliance against the strictest funder in the mix, not the most familiar one.

    Gold or Green: which route applies to a given article?

    NIHR compliance runs through two established routes, mirroring the language UKRI and Wellcome also use.

    • Gold route. Publish in a fully open access journal, or a hybrid journal covered by a transformative agreement. NIHR funds reasonable article processing charges (APCs) for eligible awards through a dedicated open access funding line.
    • Green route. Publish in a subscription journal without a transformative agreement, and instead deposit the author’s accepted manuscript in Europe PMC under CC BY, supported by the rights-retention statement in the funding acknowledgement.

    Both routes must still meet the no-embargo requirement — the green route in NIHR’s case does not permit the delayed deposit windows still found in some non-UK funder mandates.

    Common questions about the NIHR policy

    Does the NIHR open access policy require immediate deposit?

    Yes. The NIHR open access policy requires the final article or accepted manuscript to be deposited in Europe PMC and made freely available on the day of publication, with no embargo period permitted under any compliance route.

    What licence does NIHR require for funded research articles?

    NIHR requires a CC BY licence by default, allowing free reuse and adaptation with attribution. A CC BY-ND licence is permitted only with prior NIHR approval, and Crown Copyright outputs instead carry the Open Government Licence.

    Is the NIHR open access policy the same as UKRI’s?

    No. Both require CC BY and Europe PMC deposit, but UKRI’s journal-article requirement took effect on 1 April 2022, two months before NIHR’s 1 June 2022 start date, and UKRI’s policy separately phases in monograph coverage from 2024.

    Why is NIHR reviewing its open access policy?

    NIHR states the review exists to keep the policy fit for the future across a portfolio that spans clinical trials, infrastructure and fellowship awards, and confirms that public feedback has already shaped revisions to the published text.

    What this means for institutions and researchers

    Research offices supporting multi-funder grants should build compliance checks around the strictest applicable deadline and licence condition, rather than defaulting to whichever funder’s policy staff know best. Because NIHR’s policy sits inside an active review cycle, institutional guidance pages should be dated and re-checked against NIHR’s own policy page at each funding cycle, rather than treated as a fixed reference. Authors submitting to subscription journals should confirm the rights-retention statement is included at submission, not added retrospectively, since post-hoc requests are harder for publishers to honour.

    Looking ahead, the continued existence of a formal review mechanism signals that NIHR intends its open access requirements to keep pace with sector-wide developments — including alignment pressure from UKRI, cOAlition S signatories and Wellcome — rather than remain static. Institutions that monitor the review outputs alongside the base policy will be better placed to anticipate the next compliance change rather than react to it after a grant has already been awarded.

    For related compliance context, see CASRAI’s research administration resources and the open-access terminology entries in the CASRAI Dictionary.

  • NSF Broader Impacts Criterion 2026: What Changed in Goal 7 and How to Rewrite Your Statement

    The NSF broader impacts criterion 2026 revision narrows Goal 7 of the agency’s seven-part broader-impacts framework: activities aimed at broadening STEM participation must now be open and available to all Americans, rather than restricted to applicants with specific protected characteristics. This guide explains what changed, why, and how principal investigators and research offices should rewrite their statements.

    Broader impacts is one of two co-equal NSF merit-review criteria — alongside intellectual merit — used to evaluate whether a proposal’s societal benefit, beyond the science itself, is well-reasoned, evidence-based, and assessable.

    What is the NSF broader impacts criterion?

    NSF defines broader impacts as the potential of a proposed activity to benefit society and contribute to specific, desired societal outcomes, distinct from — but complementary to — the scientific merit of the work itself. NSF’s official guidance frames it as one of two equally weighted review criteria applied to every proposal the agency funds.

    The statutory basis for the criterion’s societal-outcome categories traces to the America COMPETES Reauthorization Act of 2010, which enumerates seven broader-impacts goals that NSF-funded activity can advance: economic competitiveness, public health and welfare, national security, academia-industry partnerships, STEM workforce development, public scientific literacy, and full participation of under-represented groups in STEM — the last of these is Goal 7.

    What changed in Goal 7 for 2026?

    Under guidance NSF began issuing in April 2025 and continued refining through 2026, broadening-participation activities funded under Goal 7 must be structured so that eligibility and outreach are open to all Americans, rather than limited to applicants or participants defined by protected characteristics. Research-development offices — including the University of California, Davis proposal-development team — confirmed in an August 2025 update that “broadening participation can still be used as long as your activities and research are open to all Americans.”

    An NSF Directorate for Biological Sciences virtual office-hour briefing dated June 2026 restates the same requirement to prospective Research Experiences for Undergraduates (REU) site applicants: opportunities funded through broadening-participation activity “must be open to all Americans.” This is not a retirement of Goal 7 — it is a narrowing of the permissible activity design, shifting eligibility criteria away from protected-characteristic exclusivity and toward open, non-restrictive access framed around non-protected factors such as geography, institution type, socioeconomic status, and career stage.

    PIs should treat this as a design constraint, not a disqualification of broadening-participation work: activities that build STEM pathways for rural, first-generation, community-college, or under-resourced-institution populations remain fully consistent with the revised Goal 7, provided eligibility itself is not restricted by protected characteristic.

    How does the revised Goal 7 compare with the other six goals?

    The table below summarises the seven America COMPETES broader-impacts goals and flags where 2026 guidance has introduced a material change to how PIs should frame activity design.

    Goal Societal outcome 2026 guidance status
    1 Increased economic competitiveness of the United States Unchanged
    2 Advancement of health and welfare of the American public Unchanged
    3 Development of a globally competitive STEM workforce Unchanged
    4 Increased partnerships between academia and industry Unchanged
    5 Improved public scientific literacy and engagement Unchanged
    6 Improved national security Unchanged
    7 Full participation of under-represented groups in STEM Narrowed — activities must be open to all Americans, not restricted by protected characteristic

    How should PIs rewrite their broader-impacts statement?

    Rewriting a Goal 7 activity for 2026 compliance is a matter of eligibility language and framing, not abandoning the underlying access goal. Reviewers still expect a well-reasoned, assessable plan under NSF’s five broader-impacts review elements — societal benefit, creative or transformative potential, soundness of the plan, team qualification, and adequate resources.

    • Reframe eligibility around non-protected factors. Replace language restricted to protected characteristics with criteria such as rural or under-resourced geography, first-generation status, institution type (community college, minority-serving institution), or career stage.
    • State open access explicitly. Add a sentence confirming the activity is open and available to all Americans who meet the stated, non-protected eligibility criteria.
    • Keep the assessment mechanism. The plan still needs observable outcome measures, a data-collection method, and a reporting pathway — this expectation predates and survives the Goal 7 change.
    • Integrate with the research, not bolt it on. The strongest 2026 statements connect broadening-participation activity directly to the proposed science rather than treating it as a generic add-on.
    • Cross-check against the other six goals. Where Goal 7 activity design feels constrained, many PIs find equally strong broader-impacts framing under Goals 1-6, which carry no 2026 eligibility changes.

    What should research administration offices do?

    Sponsored-programs and research administration offices supporting NSF submissions should update internal templates and reviewer checklists to reflect the Goal 7 eligibility language before the next proposal deadline, not after a reviewer flags it. Three concrete actions matter most.

    First, audit existing broadening-participation boilerplate for eligibility language tied to protected characteristics and replace it with non-protected framing. Second, brief proposal-development staff and departmental grants administrators on the distinction between narrowing eligibility language and abandoning broadening-participation activity altogether — the two are frequently conflated internally. Third, flag active, multi-year awards where the original Goal 7 activity plan may now need a no-cost extension or minor scope revision to remain compliant with current guidance.

    Common questions about NSF broader impacts

    What is the NSF statement on broader impacts?

    NSF states that broader impacts is the potential to benefit society and contribute to the achievement of specific, desired societal outcomes, reviewed as one of two co-equal merit-review criteria alongside intellectual merit for every proposal the agency evaluates.

    What are the priorities of NSF in 2026?

    NSF’s 2026 priorities keep intellectual merit and broader impacts as co-equal review criteria while applying updated guidance that broadening-participation activity under Goal 7 be open to all Americans, alongside continued expectations for evidence-based, assessable broader-impacts plans integrated with the proposed research.

    How hard is it to get an NSF grant?

    NSF’s own funding overview reports that PIs submit an average of 2.3 proposals for every award received, and only 36% of new PIs won their first NSF award on their first attempt in 2020 — context that makes a well-constructed, compliant broader-impacts statement a meaningful factor in a competitive process.

    Implications and outlook

    The Goal 7 narrowing sits inside a wider 2025-2026 tightening of federal guidance on eligibility language tied to protected characteristics, and NSF is unlikely to be the last funder whose broader-impacts or equivalent societal-benefit criterion is revised on similar terms. Institutions with mature broader-impacts infrastructure — partner networks, assessment instruments, evaluation staff — will adapt fastest, since the underlying evaluation bar (evidence, measurable outcomes, integration with the science) has not changed, only the eligibility framing for Goal 7 activity.

    For PIs preparing proposals now, the practical posture is straightforward: keep the broadening-participation ambition, rewrite the eligibility language to be open to all Americans, retain a rigorous assessment plan, and confirm the activity is substantively connected to the research. Proposals that make this adjustment cleanly will read as current; those that do not risk a reviewer flag on a criterion that carries equal weight to the science itself.

  • TRAC Review 2026: Why the UK’s Costing System Needs an Overhaul

    TRAC review 2026 refers to the renewed scrutiny facing the Transparent Approach to Costing (TRAC) — the 25-year-old methodology UK universities use to calculate the full economic cost (FEC) of teaching and research, and the basis for UKRI’s funded-research rates. A November 2025 report from the Policy Institute at King’s College London (KCL) argues TRAC data is inconsistent across institutions, under-used in governance, and too coarse-grained to support the benchmarking the sector now urgently needs.

    Transparent Approach to Costing (TRAC) is the UK higher-education sector’s standard costing methodology, developed jointly with funders and regulators to let institutions calculate the full economic cost of their teaching, research and other activities.

    What is TRAC and why is it under review now?

    TRAC was introduced across UK higher education roughly 25 years ago to give funders, regulators and institutions a shared basis for costing teaching, research and other activities. UK Research and Innovation (UKRI) uses TRAC-derived data to set the full economic costing (FEC) rates that determine how much of a grant-funded project’s true cost it will pay.

    The methodology has been reviewed before. The UK Higher Education Regulators and Funders Group (RFG) — comprising the Office for Students (OfS), UKRI, the Scottish Funding Council, the Higher Education Funding Council for Wales and Northern Ireland’s Department for the Economy — commissioned KPMG to review TRAC, publishing findings in November 2021. That review focused chiefly on reducing the burden of completing TRAC returns; its highest-priority recommendation, streamlining institutional governance sign-off, has since been implemented.

    The 2025 KCL Policy Institute report reframes the debate. Rather than asking whether TRAC is too burdensome to complete, it asks whether TRAC data is good enough to use — and concludes that, as currently structured, it largely is not.

    What did the King’s College London Policy Institute report find?

    The report, Broke and broken? What TRAC data tells us about higher education finances, was published by the Policy Institute at King’s College London on 11 November 2025, authored by research fellow Dr Eliel Cohen with commentary from Richard Salter, KCL’s Director of Analytics.

    Its central finding is definitive: TRAC data reveals a £5.4 billion shortfall in research cost recovery, systemic across grant types. UKRI’s funding model is built on covering 80% of the full economic cost of research council-funded projects, but the report shows actual recovery averages only 68%. Recovery for industry-funded and government-department-funded research fares only slightly better, at 75% and 76% respectively, while charity-funded research recovers just 56% of its true cost.

    Richard Salter said the TRAC return “has been a relative constant” through a period of major sector change, but warned that treating it “simply as a regulatory burden to be discharged as painlessly as possible” is no longer affordable. Dr Cohen added that the £5 billion research funding “black hole” comes as government policy leans toward universities doing less research rather than resourcing it properly.

    Why is TRAC data called inconsistent and under-used?

    The KCL report identifies four structural weaknesses that limit TRAC’s usefulness beyond its narrow regulatory function.

    • Inconsistent data collection across institutions, which undermines cross-institutional comparability.
    • Insufficiently granular breakdowns — TRAC does not routinely split costs by subject, course level or cost type, blocking meaningful benchmarking.
    • Missing contextual data, such as regional cost variation, estate size and performance metrics, that would let institutions interpret their own numbers.
    • Time lags in publication that reduce TRAC’s value for live financial planning decisions.

    These gaps compound a funding concentration problem the report also documents. Quality-related (QR) research funding and the Higher Education Innovation Fund together total almost £2 billion a year, yet 66% of that money goes to just 21 institutions — meaning QR cannot realistically plug research cost-recovery deficits for the rest of the sector.

    Funding source Recovery rate vs. full economic cost
    UKRI research councils (target: 80% FEC) 68%
    Government departments 76%
    Industry 75%
    UK charities 56%

    Charity-funded research is the weakest point on this table, made worse by the fact that UKRI’s dedicated fund supporting universities’ charity-partnered research has seen below-inflation increases for 15 consecutive years, according to the report.

    What would a modernised costing standard mean for UKRI FEC rates?

    A modernised TRAC would not, by itself, change UKRI’s 80% FEC policy — but it would change the evidence base that policy rests on. Granular, comparable, timely costing data would let UKRI and the sector negotiate FEC rates against a realistic picture of actual cost recovery, rather than the current aggregated 68% average that obscures wide variation by discipline, institution and grant type.

    The report’s authors point to the UK government’s post-16 education and skills white paper, which commits to working with the sector on cost-recovery and TRAC data use, as a genuine reform window. They also cite international precedent: sector-wide financial transparency agreements in Ontario, Canada, which have helped build trust between institutions and regulators through shared, comparable costing data — a model the UK’s Regulators and Funders Group could draw on as it takes forward its own TRAC recommendations.

    For research administrators, the practical implication is that better TRAC data would strengthen the case for full economic costing in grant negotiation, institutional strategy and governance reporting — shifting TRAC from an annual compliance exercise into an active decision-making tool.

    Frequently asked questions about the TRAC review

    What is TRAC in higher education?

    TRAC (Transparent Approach to Costing) is the methodology UK universities use to calculate the full economic cost of teaching, research and other activities. It underpins the FEC rates UKRI applies when funding grants, and has been in continuous use across the sector for around 25 years.

    Why is TRAC being reviewed again now?

    A November 2025 King’s College London Policy Institute report found TRAC data too inconsistent and under-used to support good decision-making, arriving as the government’s post-16 education white paper commits to working with the sector on cost-recovery reform, making this a live policy window rather than a routine audit.

    What does TRAC data show about UK research funding?

    TRAC data shows a £5.4 billion shortfall in research cost recovery. Against UKRI’s 80% full-economic-cost target, research councils actually recover only 68%, while UK charity-funded research recovers just 56% — a systemic gap across nearly every grant type.

    Who is responsible for reviewing TRAC?

    The Regulators and Funders Group — the Office for Students, UKRI, the Scottish Funding Council, HEFCW and Northern Ireland’s Department for the Economy — commissions TRAC reviews, including KPMG’s 2021 burden-focused review, and holds ongoing responsibility for TRAC guidance updates.

    Implications for research offices and what happens next

    For research administration offices, the KCL findings are a prompt to treat TRAC returns as strategic intelligence rather than a compliance box to tick. Institutions that build granular, subject- and grant-level cost breakdowns internally — beyond the sector-wide minimum — will be better placed to negotiate with funders and to model financial sustainability scenarios as the government’s international-student levy and tuition-fee changes take effect through 2026-27.

    The Regulators and Funders Group has not published a timetable for a further formal TRAC overhaul, and the KCL report is a policy intervention rather than a regulatory mandate. But with the post-16 white paper commitment on the table and sector deficits mounting, pressure for a more comparable, better-used costing standard is unlikely to ease. Research offices, funders and institutional leaders should expect TRAC’s governance and granularity — not just its administrative burden — to dominate the next phase of this debate.

  • UKRI Tickell Review: Reform Progress in 2026

    The UKRI Tickell review — the Independent Review of Research Bureaucracy led by Professor Adam Tickell — set out how UK research funding should cut needless administrative drag. By mid-2026, UKRI’s Corporate Plan Update 2025 to 2027 shows real but partial delivery: a new integrated back-office platform and further Funding Service development are underway, while full economic costing harmonisation, peer-review speed-ups, and some equality, diversity and inclusion (EDI) commitments remain in progress or contested.

    The Independent Review of Research Bureaucracy is the 2021–2022 UK government review, chaired by Professor Adam Tickell, Vice-Chancellor of the University of Birmingham, that examined how funders, universities and government create unnecessary administrative burden across the research system.

    What did the Tickell review actually recommend?

    The review launched in March 2021 and reported with a 63-page final report in July 2022, examining application processes, grant management, assurance and reporting, peer review, data and digital infrastructure, and institutional culture. The UK government published its formal 53-page response on 9 February 2024, describing it as “a roadmap on how the sector will work together to reshape the research system” (GOV.UK, Independent review of research bureaucracy: government response).

    That response gave UKRI a new mandate to have “due regard for reducing bureaucracy in all new initiatives and programmes it funds.” It also committed government to reversing rising costs in the Research Excellence Framework, with the next REF cycle expected to be “significantly and measurably less bureaucratic” than its predecessor.

    • Recommendations spanning simplified applications, proportionate assurance, and harmonised costing across funders
    • A specific commitment (recommendation 12) that funders “should ensure that application processes support their commitments to equality, diversity and inclusion”
    • Creation of the Bureaucracy Review Reform and Implementation Network (BRRIN), coordinating UKRI, DSIT and sector bodies including ARMA

    What has UKRI delivered by 2026?

    UKRI’s Corporate Plan Update 2025 to 2027, published 25 November 2025, is the clearest first-party evidence of where delivery actually stands. It commits UKRI to “deliver transition to a new integrated back-office platform for human resources, accounting, reporting and procurement and optimise functionality of our Funding Service” during 2026, explicitly framing this as moving forward from “delivering the UKRI recommendations from the Tickell and Grant reviews.”

    On the applicant-facing side, UKRI’s Reducing Research Bureaucracy page (last updated 2 June 2025) confirms the Funding Service is:

    • Standardising and simplifying application processes across UKRI’s seven research councils, Innovate UK and Research England
    • Introducing consistent question sets and assessment criteria, removing requirements for unnecessary attachments
    • Streamlining full economic costing (FEC) rates into a single harmonised costing mechanism

    The Corporate Plan Update also sets a concrete operational target: UKRI states it will “demonstrate, through experiments on UKRI funding opportunities, that two-month reductions in grant processing times for research councils can be achieved using novel peer review processes that also improve assessment quality and reduce administrative resources.” Separately, it commits to “testing more proportionate approaches” and “minimising bureaucracy for the sector” as an explicit organisational objective for 2025–26.

    Where is delivery stalled or contested?

    Not every 2024 commitment has moved as originally framed. Coverage of the government response at the time noted a “potential phasing out of the use of Researchfish from 2025” — the grant outcomes collection system long criticised by researchers as burdensome. UKRI’s own Corporate Plan Update 2025 to 2027 instead commits to retendering the Researchfish system rather than replacing or discontinuing it, alongside evolving “our performance reporting framework to explore potential for greater automation.” That is a materially different outcome from the phase-out some in the sector expected.

    EDI commitments also remain contested. The government’s 2024 response took what commentators characterised as a legalistic line, stating that it does not require funders to go beyond their legal duties under the Equality Act, including “the excessive use of Equality Impact Assessments.” This sits uneasily against the review’s own recommendation 12, that application processes should actively support EDI commitments — a tension the Corporate Plan Update does not resolve.

    Parliamentary scrutiny in early 2026 also surfaced sector concern that transformation could create short-term disruption: early-career researchers in physics and astronomy raised concerns to UKRI leadership in March 2026 about funding continuity and delayed grant decisions during the transition period, even as UKRI’s CEO told the House of Commons Science, Innovation and Technology Committee that reforms would bring “greater coherence, greater clarity, greater transparency about how the money gets to output.”

    How does progress compare across the wider sector?

    The Tickell review was never a UKRI-only exercise — it targeted the whole research ecosystem, and delivery is visibly uneven across bodies with different remits and pace of change.

    Body Tickell-linked initiative 2026 status
    UKRI Integrated back-office platform + Funding Service harmonisation In active transition through 2026, per Corporate Plan Update 2025–2027
    UKRI Researchfish outcomes system Retendered, not phased out, reversing earlier 2024 signal
    NIHR Excess treatment costs (ETC) simplification Ongoing, extending bureaucracy reduction beyond NIHR’s own systems (NIHR, 27 April 2026)
    Health Research Authority “Removing barriers to research” programme Responding directly to Tickell recommendations on NHS research approvals
    ARMA / BRRIN Bureaucracy Review Reform and Implementation Network Cross-funder network active; ARMA members contribute across all workstreams
    DSIT / Research England REF cost reduction commitment Government committed to a “significantly and measurably less bureaucratic” next REF cycle

    Read across this table, the pattern is consistent: platform and process harmonisation is genuinely moving, while anything requiring cross-institutional culture change — EDI assurance, REF cost reduction, university-level delegation — is progressing far more slowly than the funder-side technical work.

    Common questions on the Tickell review and UKRI reform

    What was the Tickell review of research bureaucracy?

    The Tickell review was an independent UK government review, led by Professor Adam Tickell, examining how research bureaucracy builds up across funders, universities and government. Launched in March 2021, it reported in July 2022 and the government published its formal response on 9 February 2024, setting out reforms for UKRI and the wider sector to implement.

    Has UKRI actually reduced research bureaucracy?

    Partially. UKRI’s 2025–2027 Corporate Plan confirms delivery of a new back-office platform, standardised Funding Service application processes, and harmonised costing rates. However, targets such as two-month faster grant processing are still described as experiments to be demonstrated, not completed reforms, as of 2026.

    What is the UKRI Funding Service?

    The UKRI Funding Service is the single digital platform replacing legacy, council-specific application systems across UKRI’s seven research councils, Innovate UK and Research England. It applies consistent question sets, removes unnecessary attachments, and is UKRI’s primary vehicle for delivering Tickell review commitments on simplified applications.

    Is Researchfish being phased out?

    No — not as of the 2025 to 2027 Corporate Plan. Despite 2024 signals that Researchfish might be phased out, UKRI’s latest plan commits instead to retendering the outcomes-collection system and evolving its performance reporting framework, a materially different path from full replacement.

    What this means for research administrators

    For institutional research offices, the practical implication is sequencing, not completion. Funding Service standardisation and harmonised FEC rates directly reduce per-application administrative effort now; grant-management flexibility, faster peer review, and REF cost reduction remain multi-year commitments to track rather than assume delivered. Institutions engaging via ARMA and BRRIN have the clearest visibility into which workstreams are genuinely moving.

    Given the retendering of Researchfish and continued EDI ambiguity, research administrators should treat UKRI’s Corporate Plan Update as a live delivery tracker rather than a closed case: several 2024 government-response commitments have already shifted in scope by 2026, and further revision before the next Corporate Plan cycle is likely.

    CASRAI’s research administration resources track how funder-level process reform intersects with contributorship, provenance and reporting standards that institutions must still satisfy even as bureaucracy is streamlined.

  • OMB Publication Cost Ban vs the Nelson Memo: What to Negotiate Before October 2026

    The OMB publication cost ban is a proposed revision to 2 CFR 200.461, published in the Federal Register on 29 May 2026, that would make article processing charges (APCs), page charges and colour-figure fees categorically unallowable on federal research awards unless a project specifically budgets and pre-approves them. It arrives while the Nelson Memo’s zero-embargo mandate still requires the same federally funded researchers to make their papers immediately, freely available — a collision research offices need to plan for now, not after the 1 October 2026 effective date.

    In plain terms, the OMB publication cost ban is a default-flip: where 2 CFR 200.461 today allows publication costs as “necessary for the performance of the Federal award,” OMB’s proposed rule presumes them unallowable unless a federal statute requires otherwise or the awarding agency approves them case by case.

    What does the proposed 2 CFR 200.461 rule actually change?

    The Office of Management and Budget’s Notice of Proposed Rulemaking, “Regulation for Federal Financial Assistance” (Federal Register, 29 May 2026, docket 2026-10817), rewrites large sections of the Uniform Guidance in 2 CFR Part 200, including a reversal of §200.461’s default treatment of publication costs.

    Today, publication and printing costs — including APCs at open-access journals and page or colour-figure charges at hybrid titles — are allowable when they report on federally supported work and are levied impartially. Under the proposed text, APCs and “similar fees such as open access fees for professional journal publications” become unallowable except where federal law compels payment or the agency grants case-by-case approval. Comments were due 13 July 2026, though the Council on Governmental Relations has requested an extension; the rule, if finalised as drafted, takes effect 1 October 2026.

    Two consequences follow directly. First, publication spending long absorbed informally into supplies budgets must become an explicit, pre-approved line item at award time. Second, the same NPRM proposes restricting §200.454, which today makes “subscriptions to business, professional, and technical periodicals” allowable; the revised text adds academic periodicals to the unallowable list, though Authors Alliance’s analysis of the NPRM notes it remains genuinely unclear whether OMB intends this to reach institutional library budgets or only project-specific subscriptions.

    How does the ban collide with the Nelson Memo’s zero-embargo mandate?

    The Nelson Memo is the August 2022 Office of Science and Technology Policy directive, “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research,” which instructed every federal agency funding at least $100 million in research and development to eliminate the optional 12-month embargo on peer-reviewed manuscripts and data. Agency policies implementing that directive — including NIH’s revised Public Access Policy (NOT-OD-25-047) and NSF’s public access policy update (PRPD-25-001) — took effect largely across 2024 and 2025, and now require immediate deposit of the accepted manuscript with no embargo period.

    The Nelson Memo did not treat compliance as costless. It explicitly directed agencies to allow researchers to include reasonable publication costs as allowable expenses in research budgets — the same cost category §200.461 would now presume unallowable. Immediate open access is typically achieved one of three ways: paying an APC for gold open access, depositing the manuscript under green open access, or paying through an institutional transformative (read-and-publish) agreement. The proposed rule directly restricts the first route, is largely neutral toward the second, and creates real ambiguity for the third, since indirect-cost-funded transformative agreements do not fit naturally into case-by-case, award-level pre-approval.

    One provision is conspicuously untouched: the federal purpose licence at 2 CFR 200.315(b) — the legal mechanism agencies use to deposit grant-funded manuscripts in public-access repositories — remains in the proposed text as drafted. The legal basis for zero-embargo repository deposit survives even as the funding route for paid open access narrows. Institutions cannot assume the mandate will soften just because the money is harder to find.

    What happens to subscriptions, transformative deals and the international picture?

    Read-and-publish agreements sit awkwardly across both proposed changes. Universities that have negotiated these deals typically bundle subscription access and OA publishing rights into a single institutional payment, usually drawn from the indirect cost pool rather than itemised per article. If §200.454’s subscription restriction is read to include institutional library subscriptions, and §200.461’s APC restriction is read to include the OA-publishing component of transformative deals, the combined effect could touch both halves of a single contract — without either provision naming transformative agreements directly.

    The US retreat looks unusual against comparable funder policy elsewhere. UKRI and Horizon Europe’s cOAlition S signatories already fund publication costs directly through block grants or eligible-cost provisions, because their zero-embargo mandates presuppose a funding route. For a collaboration with a US subrecipient and non-US lead institution, that divergence determines which partner’s budget can legally absorb the APC.

    Funder / jurisdiction Zero-embargo OA requirement Publication cost funding stance
    US federal agencies (NIH, NSF, DOE, USDA) under the Nelson Memo Yes — immediate deposit, no embargo Proposed 2 CFR 200.461 would make APCs presumptively unallowable absent pre-approval
    UKRI (UK) Yes — immediate OA required for most outputs Block grants and in-scope grant costs explicitly fund APCs
    Horizon Europe / cOAlition S signatories Yes — Plan S zero-embargo principle APCs treated as eligible project costs where OA is mandated

    Offices administering joint US–UK or US–EU awards should treat this as a live compliance risk: the same paper may need immediate deposit under one funder’s rules while its lead US institution can no longer legally pay the APC that made deposit unnecessary.

    What should research offices negotiate before October 2026?

    Institutions have a narrow window before the effective date:

    • Budget publication costs explicitly. Awards dated after 1 October 2026 should carry a named, pre-approved publication line item rather than relying on discretionary reallocation later.
    • Clarify transformative agreement language. Confirm with publishers, in writing, whether institutional payments are classified as subscription or publication costs, since §200.461 reaches the substance of a payment, not its label.
    • Document green open access workflows. Since the federal purpose licence under 2 CFR 200.315(b) is unaffected, manuscript deposit to agency repositories remains the most audit-resistant compliance path.
    • Submit substantive comments. Comments citing the Nelson Memo, NOT-OD-25-047 and PRPD-25-001 by name, documenting the operational conflict directly, carry more weight than generic objections.
    • Map multi-funder awards. Offices running US–UK or US–EU collaborations should flag which funder’s rules govern publication costs before submission, not at closeout.

    Answer-first: quick questions on publication costs

    Who pays for publication fees?

    Publication fees are typically paid by the author’s research funder, their institution, or the author directly. Under current US federal rules, grant funds routinely cover APCs; the proposed 2 CFR 200.461 revision would shift that burden onto institutions unless a project specifically budgets for it in advance.

    How much does it cost to publish in open access?

    Article processing charges vary widely by publisher and journal tier, from no charge at diamond open-access titles to several thousand dollars at flagship journals. The figure depends on venue, not funder — which is why offices need a pre-approved, venue-agnostic publication budget line rather than a fixed assumption.

    Why are article processing charges so high?

    Article processing charges reflect editorial, peer-review and production costs plus, at prestigious titles, a reputation premium. Because funders rather than competitive pricing pressure have historically absorbed these charges, journals have had limited incentive to reduce them.

    Implications and outlook

    The contradiction between a rule that bans paying for open access and a mandate that requires it will not resolve itself quietly. Litigation, a revised final rule, or an OMB clarification narrowing “case-by-case” to budget-level rather than publication-level approval are all plausible before 1 October 2026. What is not plausible is that either policy simply disappears: the Nelson Memo’s zero-embargo requirement is embedded in agency policy notices already in force, and the OMB rewrite proceeds under Congress’s grant of authority at 31 U.S.C. 503.

    For research administration offices, the safest posture treats the coming months as a negotiation window, not a waiting period: secure pre-approved publication lines, harden green open-access workflows under the still-intact federal purpose licence, and map which funder’s cost rules govern each collaborative output. Institutions doing that work now will keep publishing compliantly under both regimes; those waiting for the contradiction to resolve will inherit the audit findings meanwhile.

  • Immigration Skills Charge 2026: 9 Exempt Research Roles

    The Immigration Skills Charge rose 32% for Certificates of Sponsorship assigned from 16 December 2025, taking the standard rate to £1,320 per worker per year (£480 for small and charitable sponsors). But under the Immigration Skills Charge (Amendment) Regulations 2025 (SI 2025/1078), nine research-science and higher-education occupation codes remain fully exempt — meaning most university researchers sponsored on the Skilled Worker visa pay nothing towards the increase.

    The Immigration Skills Charge (ISC) is a mandatory Home Office levy paid by UK employers each time they assign a Certificate of Sponsorship to a Skilled Worker or Senior or Specialist Worker visa applicant, unless a statutory exemption applies. For sponsor-licence holders in the higher education and research sector, the practical question raised by the December 2025 rise is not “how much more will this cost” but “does this cost apply to us at all” — and for most academic and research posts, the answer is no.

    What changed: the 2026 Immigration Skills Charge increase

    The ISC increase took effect for Certificates of Sponsorship (CoS) assigned on or after 16 December 2025, under the Immigration Skills Charge (Amendment) Regulations 2025 (SI 2025/1078). The rise was first flagged in the government’s 2025 Immigration White Paper and implemented via secondary legislation rather than primary reform, which is why it applied with limited notice mid-financial-year for most institutions.

    The rates rose as follows:

    Sponsor type Rate to 15 Dec 2025 Rate from 16 Dec 2025 Additional 6-month block
    Medium or large sponsor £1,000 / 12 months £1,320 / 12 months £660 (up from £500)
    Small or charitable sponsor £364 / 12 months £480 / 12 months £240 (up from £182)

    A UK Parliament research briefing (CBP-9859, February 2026) confirms the 32% ISC uplift and notes that individual Certificate of Sponsorship fees rose by 120% in the same period, to £525. Wider Home Office immigration and nationality fees — including Indefinite Leave to Remain, which rose from £3,029 to £3,226 — increased again from 8 April 2026, typically by 6–7%. Sponsors must budget for these as separate, cumulative costs alongside the ISC.

    Which occupation codes are exempt from the ISC?

    Regulation 4 of the Immigration Skills Charge Regulations 2017, as amended by SI 2025/1078, exempts specific Standard Occupational Classification (SOC 2020) codes listed in the Home Office’s Appendix Skilled Occupations. Nine of these correspond directly to research and higher-education roles.

    SOC code Occupation ISC status
    2111 Chemical scientists Exempt
    2112 Biological scientists Exempt
    2113 Biochemists and biomedical scientists Exempt
    2114 Physical scientists Exempt
    2115 Social and humanities scientists Exempt
    2119 Natural and social science professionals n.e.c. Exempt
    2161 Research and development managers Exempt
    2162 Other researchers, unspecified discipline Exempt
    2311 Higher education teaching professionals Exempt

    Three further non-academic codes — clergy (2463), sports players (3431) and sports coaches, instructors and officials (3432) — are also exempt under the same regulation, reflecting the same “acute domestic skills shortage” rationale that underpins the research exemptions rather than any HE-specific carve-out.

    Two further exemption routes matter for universities specifically:

    • Health and Care Worker visa roles are exempt under Regulation 4(2)(d), relevant to university-linked NHS and clinical academic appointments.
    • Student-to-Skilled-Worker switchers applying from inside the UK are exempt, covering the common pathway of PhD graduates moving into postdoctoral posts with the same or a new sponsor.

    Which university and R&D roles still have to pay?

    The exemption list is narrow and code-specific — it does not cover the full range of roles a university sponsors. Professional services, technical and administrative staff sponsored under non-exempt SOC codes pay the full increased ISC, even where they support research directly.

    Role type Typical SOC code ISC payable?
    Principal investigator / academic researcher 2161, 2162, 2111–2119 No
    Lecturer / higher education teaching professional 2311 No
    Research software engineer / data scientist 2136, 2425 Yes
    Research administrator or grants manager 2422, 4159 Yes
    University registrar / senior administrator 2317 Yes
    Laboratory technician 2141, 3111 Yes

    This distinction matters for institutional budgeting. A university sponsoring a chemistry professor and a research software engineer on the same grant will pay the full £1,320 (or £480) charge for the latter but nothing for the former — a gap that widens further on multi-year CoS periods, where the charge compounds in six-month blocks.

    How do sponsors evidence an ISC exemption to UKVI?

    Exemption is not automatic in the sense of requiring no action: the Sponsorship Management System calculates the charge based on the SOC code entered when the CoS is assigned, so accuracy at that point is what determines whether the exemption applies. Getting the occupation code wrong — or defaulting to a broader “researcher-adjacent” code that is not on the exempt list — triggers a top-up demand and, on audit, can be treated as a compliance failure rather than a simple correction.

    • Confirm the exact SOC 2020 code against the current Appendix Skilled Occupations before assigning the CoS — codes are amended periodically and the exempt list is not identical to the eligible-occupations list.
    • Retain the job description, person specification and salary evidence used to justify the code, in case UKVI queries the classification during a sponsor licence audit.
    • Do not assume seniority implies exemption: a senior professional-services manager on a high salary is not exempt merely because the role is research-adjacent or PhD-preferred.
    • Where a worker changes role within the same institution, reassess the SOC code and ISC liability for the new Certificate of Sponsorship — exemption status is not inherited from a prior post.

    For research administration teams managing sponsor licence compliance, this makes SOC-code governance — not just cost forecasting — the operationally critical task created by the December 2025 change.

    Frequently asked questions

    Has the immigration skills charge gone up?

    Yes. The ISC rose 32% for Certificates of Sponsorship assigned from 16 December 2025, under the Immigration Skills Charge (Amendment) Regulations 2025 (SI 2025/1078). The large-sponsor rate increased from £1,000 to £1,320 per worker per year, and the small/charitable rate from £364 to £480.

    Are immigration fees going up in 2026?

    Yes, separately from the ISC. Most Home Office immigration and nationality fees rose again from 8 April 2026, typically by 6–7%, including the Indefinite Leave to Remain fee moving from £3,029 to £3,226. Sponsors should treat the ISC rise and this later fee round as two distinct, cumulative cost events.

    How much is the UK visa fee for 2026?

    Visa sponsorship cost is layered: alongside the ISC (£1,320 or £480), sponsors typically also pay a £525 Certificate of Sponsorship fee, the worker’s visa application fee, and the Immigration Health Surcharge — each governed by separate, independently updated fee schedules.

    What this means for sponsor licence compliance

    For most UK universities, the practical budget impact of the December 2025 ISC rise falls on professional services, technical and non-exempt research-support hires rather than on core academic and research appointments. That makes SOC-code accuracy — checked against the current Appendix Skilled Occupations at the point each CoS is assigned — a higher-value compliance control than headline cost forecasting alone.

    Institutions running multi-year, multi-worker sponsorship programmes should audit their occupation-code mapping now: misclassifying an exempt research post under a chargeable administrative code (or vice versa) creates either avoidable cost or exposure to a UKVI top-up demand and audit finding. As Home Office fee schedules continue to move on separate timetables — ISC in December, general fees in April — sponsor licence holders in the research sector gain the most by tracking SOC-code exemption status as a standing compliance item, not a one-off check at the time of the 2025 increase.