CASRAI Dictionary

Author: MCP Service

  • cOAlition S Funders: Who’s In, Who Has Left

    cOAlition S funders are the roughly two-dozen national research funders, charitable foundations and international bodies — including UKRI, Wellcome Trust, the Swiss National Science Foundation and the European Commission — that publicly endorsed Plan S in 2018 and continue to require immediate, CC BY open access from their grant recipients. Not every major funder stayed the course: the Gates Foundation has diverged toward a preprint-first model, and the European Research Council, Sweden’s Riksbankens Jubileumsfond and India’s national funders withdrew or declined to join outright.

    cOAlition S is the funder consortium — not a legal entity but a voluntary alliance of research-funding and research-performing organisations — that created and continues to steward Plan S, the 2018 open-access mandate requiring full and immediate public access to publications arising from the funding it provides. This guide sets out exactly who is in that coalition today, who has left, and what that split means for grants administrators trying to work out which awards trigger Plan S compliance obligations.

    What is cOAlition S and who funds it?

    cOAlition S launched on 4 September 2018 when a group of eleven national research funding organisations, coordinated through Science Europe, announced a “collective declaration of commitment” to mandate open access from 1 January 2020. The coalition has since grown to include national funders across Europe, Africa and the Middle East, several of the world’s largest biomedical and scientific charities, and formal support from the European Commission and the World Health Organization.

    Membership is not static. Funders join, adjust their policies, or step away as their own institutional priorities and legal constraints evolve — which is exactly why a periodically-updated reference list, rather than a single static claim, is the useful format for this question.

    Which funders currently back Plan S?

    cOAlition S’s own organisations page groups its supporters into national funders, charitable and international funders, and European funders (including the European Commission). Based on cOAlition S’s published membership record and the sourced Wikipedia membership history, the coalition’s core currently includes the following.

    • National research funders: UK Research and Innovation (UKRI); Austrian Science Fund (FWF); France’s Agence Nationale de la Recherche (ANR); Science Foundation Ireland (SFI); Istituto Nazionale di Fisica Nucleare (INFN, Italy); Luxembourg National Research Fund (FNR); Netherlands Organisation for Scientific Research (NWO); Research Council of Norway (RCN); National Science Centre, Poland (NCN); Fundação para a Ciência e a Tecnologia (FCT, Portugal); Slovenian Research Agency (ARRS); Swedish Research Council for Sustainable Development (Formas), Forte and Vinnova; Swiss National Science Foundation (SNSF); Academy of Finland; National Health and Medical Research Council (NHMRC, Australia); South African Medical Research Council (SAMRC); Jordan’s Higher Council for Science and Technology; and Zambia’s National Science and Technology Council.
    • Charitable and international funders: Wellcome Trust; the Bill & Melinda Gates Foundation (with a materially diverged policy — see below); the Howard Hughes Medical Institute (HHMI); Templeton World Charity Foundation; and Aligning Science Across Parkinson’s (ASAP).
    • Institutional and multilateral support: the European Commission, which funds Horizon Europe on Plan S-aligned open-access terms, and the World Health Organization.

    cOAlition S publishes this list as a live, JavaScript-rendered directory rather than a static page, so administrators verifying a specific funder’s status should cross-check coalition-s.org/organisations directly rather than relying solely on any single secondary source, including this one.

    Which funders have left or diverged from Plan S?

    Three organisations have formally withdrawn from or declined to join cOAlition S, and one major member has substantially diverged from the original Plan S model while remaining nominally affiliated.

    Funder Status What changed
    Bill & Melinda Gates Foundation Member, policy diverged 2024 “preprint-centric” policy took effect January 2025; the foundation stopped paying article processing charges (APCs) and instead requires a preprint at or before formal publication, rather than mandating immediate open access to the accepted manuscript itself.
    European Research Council (ERC) Withdrew, July 2020 Supported the initiative from 2018 but its Scientific Council withdrew, citing concerns that Plan S’s implementation was too restrictive for early-career researchers and limited publication-venue choice.
    Riksbankens Jubileumsfond (RJ), Sweden Left, 2019 An early signatory that withdrew citing concerns over the implementation timeline.
    India (national funders) Declined to join, October 2019 Principal Scientific Adviser Vijay Raghavan announced India would pursue its own national open-access policy rather than sign on to cOAlition S.

    The Gates Foundation case is the one administrators most often ask about, because Gates remains publicly associated with the open-access movement while its funding terms have moved furthest from the original Plan S template. Its 2024 policy refresh, reported by Nature in April 2024, replaced APC funding with a preprint-first requirement — a shift toward green, repository-based access rather than the gold, journal-published-and-APC-funded model Plan S initially popularised. Wellcome Trust, by contrast, has kept its CC BY, zero-embargo requirement fully aligned with Plan S principles and remains a full cOAlition S member.

    How does this affect grant compliance for administrators?

    For research administrators, the practical question is rarely “is my institution generally Plan S-aligned” — it is “does this specific grant trigger Plan S obligations.” That depends entirely on the funder listed on the award, not on the institution or the discipline.

    • A UKRI, Wellcome, SNSF, NWO or European Commission (Horizon Europe) grant carries a live Plan S-style requirement: immediate, CC BY, zero-embargo open access to the peer-reviewed manuscript, with rights retention where the funder has adopted that strategy.
    • A Gates Foundation grant awarded or renewed after January 2025 requires a preprint at or before publication, but no longer carries a guaranteed APC payment — so budgeting APCs into a Gates-funded proposal on the old assumption will leave a funding gap.
    • An ERC (Horizon Europe) grant sits in a genuinely mixed position: the ERC itself withdrew cOAlition S support in 2020, but ERC grants are still funded under Horizon Europe, which the European Commission administers on Plan S-aligned terms — so the operative obligation traces to the Commission’s rules, not the ERC’s own institutional stance.
    • A grant from a funder never affiliated with cOAlition S (most US federal agencies, most Indian national funders) should be checked against that funder’s own policy rather than assumed to follow Plan S at all.

    The single most reliable compliance step is to check the specific funder named on the award letter against cOAlition S’s current organisations list and that funder’s own most recent policy document, rather than relying on institutional memory of what a funder required in 2019 or 2020.

    Frequently asked questions

    Has the Gates Foundation left cOAlition S?

    No. The Gates Foundation remains formally affiliated with cOAlition S, but its 2024 policy refresh — effective January 2025 — dropped APC funding in favour of a preprint-first requirement, moving its practical terms away from the original Plan S model without a formal exit.

    Is Wellcome Trust still part of Plan S?

    Wellcome Trust is a founding cOAlition S member and remains fully aligned with Plan S: its open-access policy requires immediate deposit of the peer-reviewed manuscript under a CC BY licence with no embargo, matching the original 2018 mandate.

    Why did the European Research Council withdraw from cOAlition S?

    The European Research Council backed the initiative in 2018 but its Scientific Council withdrew support in July 2020, stating that Plan S’s implementation guidance was too restrictive, particularly for early-career researchers‘ choice of publication venue.

    Where can I find the full, current list of cOAlition S funders?

    cOAlition S publishes its authoritative, continuously updated member list at coalition-s.org/organisations, grouped into national funders, charitable and international funders, and European funders — administrators should treat that page, not older news coverage, as the source of record.

    Implications and outlook

    cOAlition S was never designed as a fixed, closed membership — it is a voluntary coalition that funders join and leave as their institutional strategies evolve. The Gates Foundation’s shift toward a preprint-centric model is the most consequential recent change because it signals that even committed founding-era supporters are questioning APC-funded gold open access as the default route, in favour of greener, lower-cost alternatives. For institutions with active research administration functions, the practical takeaway is to treat “is this funder in cOAlition S” as a per-grant lookup rather than a one-time institutional assumption, and to revisit that lookup whenever a funder announces a policy refresh.

  • Plan S Green Open Access: Zero-Embargo Deposit Rules

    Plan S green open access is the compliance route that lets a researcher publish in the journal of their choice — including a subscription journal — and still meet their funder’s open access mandate, provided the Author’s Accepted Manuscript (AAM) or Version of Record (VoR) is deposited in a qualifying repository immediately on publication, with no embargo period and under a CC BY licence.

    Green open access is repository-based open access: the author (or their institution) self-archives a copy of the peer-reviewed article in an online repository, independently of whatever access model the publishing journal itself uses. Under cOAlition S’s implementation guidance, this route is one of three recognised paths to Plan S compliance, alongside publishing in a fully open access journal/platform and publishing under a transformative arrangement.

    What is green open access under Plan S?

    Green open access under Plan S is the “repository route” to compliance: a researcher publishes in a subscription journal and separately makes a copy freely available in an Open Access repository. It requires no article processing charge (APC), and does not depend on the publisher’s own access model — why research offices generally advise it as the lowest-cost compliance path.

    cOAlition S’s Principles and Implementation guidance states: “all scholarly articles that result from research funded by members of cOAlition S must be openly available immediately upon publication without any embargo period.” The green route is one of three ways to satisfy this.

    What are the zero-embargo deposit rules?

    The defining feature of Plan S green open access is that no embargo period is permitted — not the traditional 6- or 12-month delay still common elsewhere. Deposit and public availability must coincide with the publication date, including for early-view versions published online ahead of an issue.

    • Version deposited: either the Author’s Accepted Manuscript (the peer-reviewed, post-review text before publisher copy-editing and typesetting) or the Version of Record, at the publisher’s discretion.
    • Timing: immediate — deposit “no later than” publication date; retrospective or embargoed deposit does not satisfy Plan S.
    • Licence: the deposited copy must carry a Creative Commons Attribution (CC BY) 4.0 licence by default. cOAlition S accepts CC BY-SA 4.0 or CC0 as secondary alternatives, and will approve CC BY-ND only where a grantee explicitly requests and justifies it.
    • Rights basis: the author or their institution must retain sufficient rights — via copyright retention or a compliant licence to publish — to authorise the deposit themselves, rather than relying on publisher permission after the fact.

    This zero-embargo condition is what separates Plan S green OA from “traditional” green OA policies used by many institutional mandates (e.g. REF-linked UK policies), which commonly tolerate a delay before the AAM is made public.

    Which repositories qualify?

    Plan S does not publish a fixed whitelist of approved repositories. Instead, cOAlition S sets published technical criteria that any repository — institutional, subject-based, or general-purpose — must meet, and expects the repository to be listed in the Directory of Open Access Repositories (OpenDOAR) or in the process of registering.

    Under Part III of cOAlition S’s technical guidance, mandatory repository criteria include:

    • Persistent identifiers (PIDs) for deposited versions, such as a DOI.
    • High-quality, interoperable article-level metadata released under a CC0 public domain dedication, including complete funder and grant-number information.
    • Machine-readable open access status and licence information embedded in the article record.
    • Continuous availability, with uptime of at least 99.7% (excluding scheduled maintenance).
    • A functioning helpdesk — at minimum an email address — with a response time of no more than one business day.

    In practice, this means most well-run institutional repositories qualify, alongside subject repositories such as PubMed Central and Europe PMC for the life sciences, and general-purpose repositories such as Zenodo (which is itself referenced elsewhere in cOAlition S’s own guidance materials). Research offices should verify a specific repository’s registration status directly via OpenDOAR rather than assuming compliance from reputation alone.

    How does the green route differ from the Rights Retention Strategy?

    The green route and the Rights Retention Strategy (RRS) are related but distinct mechanisms, and conflating them is a common source of confusion in author-facing guidance. The green route is the compliance pathway — publish anywhere, deposit with zero embargo. RRS is the legal mechanism cOAlition S introduced to make that pathway enforceable even when a publisher’s standard licence-to-publish would otherwise block it.

    Under RRS, an author applies a CC BY licence to their AAM at the point of submission — before any publishing agreement is signed — via a standard rights-retention statement in the manuscript or cover letter. This pre-empts publisher terms that would otherwise impose an embargo, because the author’s declaration takes precedence. RRS is the tool that keeps zero-embargo green deposit available even in journals with no proactive compliant route.

    How does green compare with gold and hybrid (APC) routes?

    Gold open access means publishing directly in a fully open access journal or platform, where the article is freely available from the publisher at the point of publication — usually funded by an APC, which cOAlition S members will financially support. Hybrid — publishing open access within an otherwise subscription journal — is explicitly not supported by cOAlition S funding except within pre-approved transformative arrangements.

    Dimension Green (zero-embargo repository) Gold / OA journal Rights Retention Strategy
    Where you publish Any subscription journal Fully open access journal/platform Any journal (RRS is a licensing overlay, not a venue choice)
    Typical cost to author/funder No APC APC, funder-supported No APC
    Embargo permitted None None (immediate by definition) None
    Version deposited/published AAM or VoR, in a repository VoR, on publisher platform AAM, in a repository, licensed at submission
    Licence CC BY (default) CC BY (default) CC BY, asserted before any publisher agreement

    For research-office staff advising authors, the practical guidance is: green zero-embargo deposit is generally the cheapest compliant route, RRS is the safeguard that keeps it available when a publisher resists, and gold/APC remains appropriate where funder policy or discipline norms favour immediate publisher-side open access.

    Frequently asked questions

    What does green open access mean?

    Green open access means self-archiving a copy of a peer-reviewed article in an online repository — institutional, subject-based, or general-purpose — independently of the journal’s own access model. The author retains the ability to publish in any journal, including subscription titles, while separately making a version openly available at no cost to readers.

    What is the difference between gold and green open access?

    Gold open access means the publisher itself makes the article freely available immediately, typically funded by an APC. Green open access means the author self-archives a copy in a repository, which can apply even when the journal itself remains subscription-based, and normally carries no publication fee.

    Is green open access free?

    Yes. The green route generally involves no article processing charge to the author, funder, or institution. The only ongoing costs are the repository’s own infrastructure, which is typically funded institutionally rather than per-deposit, making green the lowest-cost Plan S compliance path for most authors.

    What is Plan S in open access?

    Plan S is an open access policy initiative launched by cOAlition S in September 2018, requiring that scholarly publications from research funded by its members be made immediately and openly available, with effect from 2021, via open access journals, platforms, or zero-embargo repository deposit.

    What this means for research offices

    Advising authors correctly requires distinguishing three separate questions: is the venue itself compliant (checked via cOAlition S’s Journal Checker Tool), does the author need Rights Retention to secure deposit rights, and is the target repository actually OpenDOAR-registered and criteria-compliant. Treating these as one question is the most common cause of authors believing they have complied when they have not — and it should be confirmed at submission, not after acceptance, since retrofitting a CC BY declaration onto a signed publisher agreement is frequently unenforceable.

    Outlook

    cOAlition S committed to a formal review of Plan S’s requirements, including the role of repository-based compliance, with several “strongly recommended” repository criteria (such as JATS XML full text and open citation data) flagged for possible upgrade to mandatory status. Research offices should expect repository technical requirements to tighten rather than relax, making early alignment with OpenDOAR criteria and RRS-based submission workflows a durable investment. For institutions building broader compliance workflows, see CASRAI’s research administration resources.

  • What Was a Transformative Journal? (2021-2024)

    A transformative journal was a subscription or hybrid journal that formally committed to increasing its open-access (OA) content year-on-year and to flipping fully to OA once a set threshold was reached. cOAlition S, the international funder consortium behind Plan S, ran the framework from 2021 to 2024 as a bridge for legacy subscription titles, then withdrew financial support after most titles failed to hit their compliance targets. This article explains what qualified, why the model was retired, and what cOAlition S funds in its place.

    A transformative journal (TJ) is best defined in cOAlition S’s own terms: “a subscription/hybrid journal that is actively committed to transitioning to a fully Open Access journal,” required to grow its OA share annually and to offset subscription income against publishing fees so institutions were not charged twice.

    What was a Transformative Journal, exactly?

    A Transformative Journal was a formally recognised category within Plan S compliance, distinct from an ordinary hybrid title. To qualify and retain status, a journal had to meet three binding conditions set out in cOAlition S’s published criteria:

    • Grow its OA share by at least 5 percentage points in absolute terms and 15% in relative terms every year, measured on Version of Record articles published under a CC BY licence.
    • Commit to flip to full and immediate OA once its content reached a 75% open-access threshold, with no fixed flip date required after 2020 revisions to the criteria.
    • Publish transparent pricing and offset subscription income against publication fees, to avoid “double-dipping” — charging both a subscription and an article processing charge (APC) for the same content.

    Journals that missed their annual target were removed from the programme the following January, at which point the Journal Checker Tool (JCT) — the tool researchers used to verify a compliant publishing route — stopped listing them as a valid Plan S option.

    How did Transformative Journals differ from hybrid journals?

    cOAlition S drew a sharp line between an ordinary hybrid journal and a Transformative Journal because ordinary hybrid titles had, in its own analysis, failed as a transition mechanism. The table below sets out the practical distinctions.

    Feature Ordinary hybrid journal Transformative Journal (2021-2024) Transformative Agreement (Read & Publish)
    OA growth obligation None ≥5 pts absolute / ≥15% relative, yearly Negotiated institution-by-institution
    Flip commitment None Full OA once 75% threshold reached Varies by contract term
    Plan S compliant route No Yes, while status held Yes, for covered institutions
    Negotiated by N/A Publisher, applying to cOAlition S Library consortia / country bodies
    Funder financial support N/A Ended 31 December 2024 Ended 31 Dec 2024 for cOAlition S centrally; some national exceptions continue

    The distrust of hybrid publishing was rooted in hard flip data cOAlition S cited when justifying the Transformative Journal criteria: of Wiley’s roughly 1,600 journals, only eight had converted from subscription to full OA; of Elsevier’s stable of more than 2,200 titles, only seven had flipped. That track record is why the Transformative Journal framework layered binding annual KPIs and a hard funding deadline onto what had, for hybrid titles, been a voluntary and largely unfulfilled promise.

    Why did cOAlition S withdraw support in 2024?

    cOAlition S always treated Transformative Journal funding as temporary. The Plan S Implementation Guidance set 31 December 2024 as the outer limit from the outset, but the decisive announcement came on 26 January 2023, when cOAlition S confirmed it would end financial support for all transformative arrangements — both Transformative Journals and Transformative Agreements — after 2024, and would stop accepting new TJ applications from 30 June 2023.

    The compliance data behind that decision was stark. On 20 June 2023, cOAlition S removed 1,589 of 2,326 Transformative Journal titles — 68% of the entire programme — for failing their annual OA growth targets, as reported by Times Higher Education and Science. The same reporting found that only around 1% of TJ titles had flipped to full open access by January 2023, and just 695 titles (30%) had met or exceeded their growth KPI. A follow-up cOAlition S analysis of the 2023 reporting round found that 56% of the titles that survived the first cull still failed to hit their growth targets the following year.

    cOAlition S’s own explanation, published alongside the withdrawal announcement, is unambiguous: continuing to fund transformative arrangements beyond 2024 would “significantly increase the risk that these arrangements will become permanent and perpetuate hybrid Open Access, which cOAlition S has always firmly opposed.” In other words, the model was retired not because open access growth stalled everywhere, but because the transitional bridge itself was at risk of becoming the destination.

    What replaced the Transformative Journal model?

    cOAlition S did not simply stop funding transitional routes; it redirected support toward mechanisms it judged more likely to deliver full and immediate OA. Three strands now dominate its compliance thinking:

    • Full-OA Publishing Agreements — a newer category of institution/consortium contract that funds publication only in venues making all peer-reviewed articles immediately open access, rather than a mixed subscription-plus-APC model.
    • Diamond and community-led OA — journals and platforms that charge neither authors nor readers, which cOAlition S now frames as the preferred long-term structural fix rather than a market-mediated transition.
    • Transparency tooling — continued use of the Journal Comparison Service for price transparency and the cOAlition S Rights Retention Strategy, which lets authors retain enough rights to deposit the Author Accepted Manuscript under CC BY regardless of a journal’s OA status.

    Transformative Agreements (Read & Publish deals negotiated by library consortia, such as the Jisc-Wiley and Bibsam-Elsevier deals) are treated differently from Transformative Journals: cOAlition S ended its own central financial backing after 2024 but explicitly left room for individual national funders to keep supporting Read & Publish agreements as part of domestic strategy, and library consortia retain the mandate to negotiate them.

    Answer-first Q&A

    What are transformative journals?

    Transformative journals were subscription or hybrid titles formally recognised by cOAlition S between 2021 and 2024 as a Plan S-compliant publishing route, conditional on hitting binding annual open-access growth targets and eventually flipping to full OA.

    How do transformative journals differ from hybrid journals?

    Unlike ordinary hybrid journals, which had no obligation to grow their OA share, Transformative Journals had to demonstrate measurable annual progress, avoid double payments through offsetting, and commit to a full OA flip — conditions enforced by removal from the Journal Checker Tool if missed.

    Why did cOAlition S withdraw support for transformative journals?

    cOAlition S withdrew support because most titles missed their targets — 68% were removed in June 2023 alone — and because continued funding risked making the “transitional” hybrid model permanent, contradicting Plan S’s core opposition to hybrid open access.

    What replaced the transformative journal model?

    cOAlition S redirected support toward Full-OA Publishing Agreements, diamond and community-led open-access publishing, and existing transparency tools such as the Journal Comparison Service and the Rights Retention Strategy, all aimed at immediate rather than gradual open access.

    What this means for institutions and researchers now

    For research administrators and library staff, the practical consequence is that Transformative Journal status is no longer a live Plan S compliance route: any title still listed as a former TJ in older guidance should be re-checked against the current Journal Checker Tool, since post-2024 publication fees for former TJ titles are not funder-covered unless the journal qualifies through another route, such as a live Transformative Agreement or full OA status.

    For authors funded by cOAlition S members, the safest compliance paths going forward are: publishing in a fully OA journal, publishing via an active Transformative Agreement negotiated by their institution or consortium, or depositing the Author Accepted Manuscript under the Rights Retention Strategy when neither applies. The retirement of the Transformative Journal category is a useful case study in how funder mandates evolve once evidence of a policy’s underperformance becomes clear — a pattern research administrators should expect to see repeated as other transitional open-access mechanisms face similar reviews before the end of the decade.

  • Read and Publish Agreements: Meeting Plan S

    A read and publish agreement is a single institutional contract that bundles a library’s journal-subscription payments with its authors’ open-access publishing fees, so researchers publish open access without paying an individual Article Processing Charge (APC). It is one of several mechanisms institutions use to satisfy funder open-access mandates such as Plan S, alongside publish-and-read deals, transformative journals, and APC waivers.

    A read and publish agreement is defined by having two payment components in one contract: a fee for reading (subscription access) and a fee for publishing (open-access output) from the same institution to the same publisher.

    What is a read and publish agreement?

    A read and publish (RAP) agreement is a contract between a library or consortium and a publisher that consolidates two previously separate payment streams — subscription access and per-article open-access fees — into one negotiated sum. Corresponding authors affiliated with the subscribing institution can then publish open access in the publisher’s eligible journals without submitting an individual APC invoice.

    RAP contracts emerged from the broader category of transformative agreements: deals designed to shift a publisher’s revenue away from subscription reading and towards open-access publishing over a defined term. The Scholarly Kitchen’s 2019 primer on transformative agreements, still the reference framework cited across library literature, formalised the RAP/PAR distinction that libraries and publishers use today.

    • Eligibility is normally restricted to the corresponding author at a subscribing institution.
    • Coverage typically spans a publisher’s hybrid and fully open-access journal portfolio, though scope varies by contract.
    • Most agreements carry an annual article quota or budget cap; once exhausted, further OA publishing may require a separate APC or wait until the next contract year.

    How the model satisfies Plan S without per-article APCs

    Plan S, the policy coordinated by the funder consortium cOAlition S, requires that research outputs from participating funders be made immediately open access, either in a fully OA journal or platform, or via a compliant route within a subscription journal. A read and publish agreement satisfies this by making every eligible article OA on publication as a contractual default, removing the author’s need to source separate APC funding.

    Because the institution has already paid for publishing rights as part of the bundled fee, the author’s compliance obligation is met automatically at acceptance, provided the article falls within the agreement’s scope and quota. This is the core mechanic that distinguishes RAP deals from a standard hybrid-journal APC waiver, which still requires a case-by-case funding decision.

    cOAlition S’s Guidance on the Implementation of Plan S treats transformative agreements as a transitional compliance route, not a permanent end state. Under that guidance, newly negotiated transformative contracts concluded from 2020 were capped at a maximum three-year term and required a defined scenario for full conversion to open access once the contract expired — meaning agreements negotiated in this window needed a stated end date for reliance on the subscription-plus-publishing model, generally landing around 2024.

    Read-and-publish vs publish-and-read vs transformative journals

    Institutions encounter several related mechanisms that all aim at Plan S compliance but differ in who pays, for what, and how the cost falls across a consortium.

    Mechanism Payment structure Who bears cost in a consortium Typical compliance route
    Read-and-publish (RAP) Reading fee + publishing fee, bundled All member libraries share read-access cost Transformative agreement
    Publish-and-read (PAR) Publishing fee only; reading included Cost falls mainly on institutions whose authors publish Transformative agreement
    Transformative journal Per-article APC, but journal commits to OA growth targets Individual author/funder pays per article Direct Plan S-compliant route (time-limited by cOAlition S)
    APC waiver No payment; fee reduced or removed case-by-case Publisher absorbs cost, often for LMIC authors Discretionary, publisher- or policy-specific

    The Scholarly Kitchen’s framework draws the RAP/PAR line precisely: a Read-and-Publish agreement charges the publisher for both reading and publishing in one contract, while a Publish-and-Read agreement charges only for publishing, with reading access included at no further cost. Germany’s DEAL consortium agreement with Wiley illustrates the PAR variant concretely: the negotiated Publish&Read fee for hybrid open-access articles was set at €2,750 per article, fixed for the three-year term of the contract, with legacy subscription payments folded into that single per-article rate.

    Transformative journals are a distinct, narrower mechanism: individual hybrid journals commit to year-on-year OA growth targets in exchange for continued Plan S eligibility, but authors (or their funders) still pay a per-article APC — the mechanism a general RAP deal is specifically designed to avoid.

    Cost-recovery mechanics for libraries

    Libraries typically negotiate RAP and PAR deals with a cost-neutrality target: the new bundled fee should approximate prior subscription spend, redirected rather than added to. In practice, outcomes vary. Some negotiated agreements land close to cost-neutral; others increase total spend once publishing volume is factored in, particularly where no article-volume cap or price ceiling is agreed.

    The ESAC Initiative (Efficiency and Standards for Article Charges), coordinated by the Max Planck Digital Library, maintains a public registry of signed transformative agreements and a set of negotiation principles — cost transparency, author copyright retention (typically via a CC BY licence), and a defined transition pathway — that most library consortia now use as a negotiating baseline. In the UK, Jisc Collections’ Requirements for Transformative Open Access Agreements sets equivalent expectations for higher-education institutions negotiating on a national basis.

    Article Processing Charges outside a RAP contract remain the counterfactual libraries are trying to avoid. Analyses of Directory of Open Access Journals (DOAJ)-listed gold OA titles have found APCs ranging from roughly $500 to $6,000, with an average close to $2,000 per article — a cost that scales directly with an institution’s publication volume when paid individually rather than bundled.

    • Cambridge University Press states its global transformative agreements let authors at over 1,000 institutions publish OA at no direct cost to the author.
    • UK consortium deals are negotiated centrally by Jisc; Australian and New Zealand deals are negotiated by the Council of Australian University Librarians (CAUL).
    • Consortium-level PAR deals shift more of the cost burden onto institutions with higher publishing output, unlike RAP deals where read-access cost is shared more evenly.

    Frequently asked questions

    What is a read and publish agreement?

    A read and publish agreement is a contract in which a publisher receives a single bundled payment from a library or consortium covering both subscription reading access and open-access publishing fees for the institution’s corresponding authors. It replaces individual APC invoicing with one negotiated, institution-level cost.

    What is the meaning of “read and publish” versus “publish and read”?

    “Read and publish” means the publisher is paid separately for reading and publishing within one contract, whereas “publish and read” (PAR) means the publisher is paid only for publishing, with reading access supplied at no additional cost. The distinction affects how cost is apportioned across a library consortium.

    How much does the average APC cost?

    Gold open-access APCs typically range from around $500 to $6,000 per article, with studies of DOAJ-listed journals putting the average close to $2,000. A read and publish agreement absorbs this variable, per-article cost into one predictable annual institutional fee.

    Implications and outlook

    For research administrators, RAP and PAR agreements simplify Plan S compliance tracking: instead of monitoring individual APC waiver requests, the compliance question becomes whether a given journal and author fall within an already-signed contract’s scope and remaining quota. This shifts administrative effort from transaction-level approval to portfolio-level negotiation and monitoring.

    cOAlition S has consistently framed transformative agreements as transitional rather than terminal, with time-limited terms built into its Plan S guidance. Institutions relying on RAP or PAR deals should treat quota caps, contract renewal dates, and each publisher’s stated conversion pathway to full open access as the operational details that determine whether Plan S compliance holds for the full contract term — not an assumption that any signed agreement guarantees indefinite coverage.

    Research administrators evaluating a publisher’s OA agreement should check it against the institution’s affiliated research administration policy and confirm how corresponding-author eligibility is determined, since eligibility criteria are central to whether an individual article is actually covered — a determination closely tied to authorship and corresponding-author status on the submitted manuscript.

  • APC Waiver Guide: How 7 Major Publishers Compare

    An APC waiver is a full or partial cancellation of the article processing charge that fully open-access journals normally require, granted to corresponding authors based on their institution’s country income classification, financial hardship, or funder agreement. Under Plan S, cOAlition S funders require publishers to offer automatic waivers for authors in low-income countries and discounts for those in lower-middle-income countries, closing one of the most cited equity gaps in gold open access.

    An APC waiver is best understood as a scheme, not a single policy: each publisher sets its own eligibility list, discount tier, and application process. This guide compares the schemes run by Wiley, Elsevier, Springer Nature, SAGE, PLOS, Frontiers and IEEE Access, explains how they interact with Plan S’s equity commitments, and sets out the Global South critique of APC-funded gold open access that waivers only partly answer.

    What Is an APC Waiver Under Plan S?

    An article processing charge (APC) is the fee a fully open-access journal charges to make a manuscript freely available on publication, typically covering peer-review administration, copyediting, typesetting and hosting. An APC waiver removes or reduces that fee, usually by 50% or 100%, so an author’s ability to pay does not determine whether their research is published open access.

    Plan S, the funder-driven open-access mandate coordinated by cOAlition S, makes waiver provision an explicit publisher obligation rather than a discretionary courtesy. cOAlition S’s implementation guidance requires publishers hosting Plan S-compliant journals or platforms to offer automatic APC waivers for authors from low-income countries and discounts for authors from lower-middle-income countries, aligned to World Bank income classifications. This sits alongside cOAlition S’s Price and Service Transparency Framework, which requires publishers to disclose what an APC funds — a precondition for judging whether a waiver genuinely offsets cost rather than masks an inflated headline price.

    How Do APC Waiver Schemes Compare Across Major Publishers?

    Most large publishers anchor eligibility to two reference points — World Bank income classifications and Research4Life country groupings (Group A: low-income; Group B: lower-middle-income) — but discount tiers, journal scope, and exclusions vary considerably.

    Publisher Waiver mechanism Typical discount tiers Scope
    Wiley Research4Life-aligned, automatic 100% (Group A), 50% (Group B) Fully open-access journals only
    Elsevier Geographic Pricing for Open Access (GPOA) pilot Full waiver where all authors are in low-income countries; scaled by GNI per capita 142 gold OA journals in the pilot
    Springer Nature World Bank income classification, requested at submission 100% (low-income), 50% (lower-middle-income, GDP under $200bn) Fully OA journals; excludes hybrid/transformative titles
    SAGE Country-tier list, requested at submission Full and partial waivers by income tier SAGE’s open-access journal portfolio
    PLOS Global Participation Initiative (GPI) Tiered flat fee by national income group, replacing case-by-case requests All PLOS journals
    Frontiers Fee Support Programme Full and partial support reviewed against income and hardship criteria Frontiers’ journal portfolio
    IEEE Access Discretionary, confirmed with editorial office No published country-tier schedule comparable to the above IEEE Access only

    Wiley, Elsevier and Springer Nature

    These three run the most heavily documented schemes. Wiley applies its waiver automatically through a Research4Life-based eligibility check at submission: Group A countries receive a full APC waiver on fully open-access journals, Group B authors a 50% discount. Wiley has reported that in 2022 this programme supported 1,850 open-access articles from low- and middle-income countries, representing around $4.6 million in waived fees.

    Elsevier moved beyond a flat waiver/no-waiver split in January 2024 with its Geographic Pricing for Open Access (GPOA) pilot, covering 142 gold OA journals. It scales the APC to a country’s Gross National Income per capita rather than a single discount step, and grants a full waiver where every author on a paper is in a World Bank-classified low-income country.

    Springer Nature waives the APC in full for corresponding authors in World Bank low-income economies (classification dated July 2023) and offers a 50% discount for lower-middle-income economies with 2022 GDP below $200 billion. Ukraine’s discount was temporarily raised to 100% following the Russian invasion. Waivers must be requested at submission, do not apply to hybrid or transformative journals, and are superseded by Springer Nature’s separate country-tiered pricing pilot for a subset of titles.

    SAGE, PLOS, Frontiers and IEEE Access

    SAGE operates a country-tier waiver list across its open-access journals, requested at submission. PLOS replaced case-by-case waiver requests with its Global Participation Initiative, sorting authors’ countries into income-based groups with a flat, discounted per-tier fee rather than a binary full-price-or-waived split — reducing the stigma and friction of individual applications. Frontiers runs a Fee Support Programme assessed against national income and hardship. IEEE Access is the narrowest case: every article carries an APC, and IEEE publishes no country-tier waiver schedule comparable to Wiley, Elsevier or Springer Nature — any fee reduction must be confirmed directly with the editorial office, a documented friction point for under-resourced authors.

    How Do You Apply for an APC Waiver?

    Application mechanics differ by publisher, but the workflow is consistent enough to plan around:

    • Confirm the corresponding author’s country against the publisher’s current income-tier list — lists move periodically against World Bank data.
    • Check the target journal is fully open access; most schemes exclude hybrid and transformative journals.
    • Request the waiver at the point of submission, not after acceptance — several publishers treat this as a hard requirement.
    • Where a scheme is discretionary (hardship review, or IEEE Access-style editorial confirmation), prepare a short justification and expect manual review.
    • Keep the waiver confirmation on file, since funders increasingly audit open-access spend and waiver use together.

    Do APC Waivers Resolve the Global South Critique of Gold OA?

    Waiver schemes address the most visible barrier — an author who cannot pay is not automatically excluded — but they do not resolve the structural critique of APC-based gold open access. UNESCO’s 2021 Recommendation on Open Science, adopted by its General Conference, explicitly cautions that APC-funded models risk reproducing global inequalities in research communication rather than removing them, since publishing capacity remains gated by a fee mechanism even when that fee is occasionally waived.

    Three gaps persist. Country-tier eligibility is coarse-grained, so researchers in middle-income countries with limited institutional funding can fall outside any discount band. Waiver schemes typically exclude hybrid and transformative journals, which still hold prestige in many disciplines, leaving authors to weigh a subscription route against a discounted fully-OA option. And discretionary schemes — the IEEE Access pattern — impose administrative burden that automatic Research4Life-tier schemes avoid, so policy generosity on paper does not always translate into equal ease of access.

    For research administrators, the implication is that eligibility should be checked publisher-by-publisher and journal-by-journal, not assumed from a general “this publisher supports LMIC authors” reputation — an automatic tier-based waiver and a discretionary editorial request can produce very different outcomes for the same author. Tracking waiver terms alongside funder mandates is increasingly part of the compliance workload that research administration teams manage across the publication lifecycle.

    Common Questions About APC Waivers

    What is an APC waiver?

    An APC waiver is a full or partial cancellation of an article processing charge, granted to authors — most often based in low- or middle-income countries — so that inability to pay does not prevent open-access publication. Publishers set their own eligibility criteria, usually tied to World Bank income classifications or Research4Life country groupings; related open-access terminology is catalogued in CASRAI’s research-administration dictionary.

    How do you apply for an APC waiver?

    Authors request a waiver or discount at the point of manuscript submission, before acceptance, by declaring the corresponding author’s institutional country. Automatic schemes (Wiley, Springer Nature, Elsevier’s GPOA pilot) apply the discount via a system check; discretionary schemes require a written justification reviewed by the editorial office.

    How much does an APC typically cost?

    Article processing charges in fully open-access journals commonly range from roughly $500 to $6,000, with a 2022 study of DOAJ-indexed titles finding an average APC near $1,997 among journals that charge a fee. Costs vary by publisher prestige, discipline and journal impact factor.

    How can authors avoid article processing charges entirely?

    Beyond waivers, authors can publish in diamond open-access journals that charge no APC to author or reader, use institutional funds or transformative agreements that bundle subscription and OA costs, or submit to hybrid journals under a subscription route without paying an OA fee.

    As Plan S’s Price and Service Transparency Framework matures and more publishers pilot income-scaled pricing over binary waivers, eligibility criteria will keep shifting — institutions should track each publisher’s current tier list rather than rely on a summary that may already be out of date.

  • Wellcome Trust Open Access Policy Explained: Requirements, APC Funding and the Plan S Link

    Wellcome Trust’s open access policy requires that original research articles arising, in whole or in part, from Wellcome funding be made freely available in Europe PMC immediately on publication, licensed CC BY, with no embargo permitted — a rule that has applied to all qualifying submissions since 1 January 2021 and is backed by direct grant-linked funding for publication costs.

    The Wellcome Trust open access policy is the funder’s mandatory requirement that peer-reviewed research articles, monographs and book chapters supported by its grants be deposited in Europe PMC (and NCBI Bookshelf, for long-form works) and openly licensed at the point of publication, with compliance routes and funding administered directly by Wellcome rather than through a separate national mandate.

    What Wellcome’s open access policy requires

    Wellcome’s current policy took effect for articles submitted from 1 January 2021. It applies to all original peer-reviewed research articles supported wholly or partly by Wellcome funding, and requires immediate, unembargoed open access with a CC BY licence (CC BY-ND only by case-by-case exception, requested before submission).

    Three routes satisfy the policy:

    • Gold route — publish in a fully open access journal or platform; the publisher deposits the version of record in PubMed Central and Europe PMC.
    • Green route — publish in a subscription journal and make the author accepted manuscript (AAM) open in Europe PMC immediately, under CC BY, via Wellcome’s rights retention clause.
    • Transformative-agreement route — publish through an institutional transformative agreement that makes the version of record open access.

    Scholarly monographs and book chapters carry a separate provision: they may be deposited up to six months after publication and are not required to use CC BY if another Creative Commons licence is more appropriate.

    How Wellcome funds APC and open access costs

    Wellcome funds open access directly rather than relying solely on national block-grant schemes. In the 2021/22 grant year, Wellcome awarded £7.2 million in open access block grants to 38 institutions, and 92% of individually reported articles complied with the policy, according to Wellcome’s own published guidance.

    The funding rules tightened materially from 1 January 2025: Wellcome now funds article processing charges only for research articles published in fully open access journals or platforms. Hybrid (“paywall-plus-OA-option”) subscription journals are no longer eligible for Wellcome APC funding, even where an institution holds a transformative agreement with the publisher — a stricter position than Wellcome held during 2021–2024, when transformative-agreement “publish” fees were still fundable.

    This mirrors the broader Plan S trajectory away from hybrid subsidy, but Wellcome reached the fully-OA-only funding line on its own timetable, separate from any coalition-wide deadline.

    Rights retention: the automatic CC BY clause

    Wellcome’s rights retention mechanism is built into its grant conditions rather than delivered through a separate author addendum. Since 1 January 2021, Wellcome grant terms automatically apply a CC BY licence to the author accepted manuscript of any original research article the grant supports, in whole or in part — meaning the author retains sufficient rights to make the AAM open immediately, regardless of a publisher’s default embargo.

    This differs in mechanism, though not in intent, from UKRI’s parallel approach. UKRI’s own open access policy, which took effect for journal articles submitted from 1 April 2022, established a comparable zero-embargo, CC BY-on-AAM route roughly fifteen months after Wellcome’s clause had already been in force.

    Funder Zero-embargo Green route Automatic CC BY on AAM effective from cOAlition S / Plan S status
    Wellcome Trust Yes 1 January 2021 Founding member
    UKRI Yes 1 April 2022 Founding member
    cOAlition S baseline (Plan S) Required for Green route Recommended coalition-wide via the Rights Retention Strategy Coalition framework itself

    Where an author cannot secure rights retention on the AAM and the article is not published Gold, several UK institutions — including UCL — accept a CC BY-licensed preprint deposited in a Europe PMC-indexed preprint server before publication as an alternative compliance path.

    Wellcome is a founding member of cOAlition S, the funder consortium that launched Plan S in September 2018 alongside Science Europe and the European Commission, and that now counts roughly two dozen funder organisations among its members. Wellcome’s current policy is deliberately aligned with Plan S’s core principles: immediate access, open licensing, and author choice of venue.

    But the relationship runs the other way chronologically. Wellcome introduced one of the world’s first funder open access mandates in 2006 — over a decade before Plan S existed — requiring deposit of funded research in PubMed Central. The 2021 policy update did not create Wellcome’s open access commitment; it tightened an existing mandate (removing the embargo Wellcome had previously permitted) specifically to bring it into line with Plan S’s stricter, zero-embargo standard. Wellcome-funded researchers can check which compliance route a given journal supports using the Journal Checker Tool, built jointly by cOAlition S and its funder members.

    Common questions about Wellcome’s policy

    Does Wellcome Trust pay for open access publishing?

    Yes. Wellcome funds APCs directly for articles in fully open access journals and platforms, distributes annual open access block grants to grant-holding institutions, and separately funds compliant open access publication of monographs and book chapters on request.

    What licence does Wellcome require for open access articles?

    CC BY is the default requirement for all research articles made open under the policy. A more restrictive CC BY-ND licence is permitted only by prior, case-by-case exception, requested through Wellcome’s dedicated request form before submission.

    Is Wellcome Trust part of Plan S?

    Yes. Wellcome is a founding member of cOAlition S, the funder coalition behind Plan S. Its own open access policy is fully aligned with Plan S principles, though Wellcome’s underlying open access mandate predates Plan S by more than ten years.

    What happens if a Wellcome-funded paper doesn’t comply?

    Non-compliant articles are not automatically penalised per se, but Wellcome tracks compliance rates at institutional level, ties future open access block grant funding to institutional performance, and expects grant-holding organisations to actively support researchers in meeting the policy’s routes.

    Implications for institutions and researchers

    For research administrators managing Wellcome grant portfolios, the practical shift is the narrowing of fundable routes since January 2025: budgeting for hybrid-journal APCs against Wellcome funds is no longer viable outside a qualifying transformative agreement’s non-hybrid terms, so pre-submission journal checking has become a compliance necessity rather than a courtesy.

    Researchers publishing in subscription journals should treat rights retention as the default fallback, since it requires no publisher fee and no embargo negotiation — the CC BY licence on the accepted manuscript is already secured by the grant terms before the paper is ever submitted.

    Outlook

    Wellcome’s trajectory — mandate first, coalition alignment second, funding restriction third — has become a template other funders are following at their own pace. As UKRI, NIHR and other cOAlition S members continue tightening hybrid-journal funding eligibility, institutions that already built Wellcome-compliant workflows around zero-embargo Green routes are better placed to absorb the next round of funder-specific restrictions.

  • Gates Foundation Open Access Policy: No More APCs for cOAlition S Funders

    The Gates Foundation open access policy was refreshed for 2025, taking effect on 1 January 2025: the foundation stopped paying article processing charges (APCs) for individual manuscripts, added a mandatory preprint-deposit requirement, and expanded the policy’s scope to cover every funded manuscript and its underlying data.

    The Gates Foundation open access policy is the Bill & Melinda Gates Foundation’s mandatory framework requiring that all peer-reviewed research and data arising from its funding be made freely available, openly licensed, and reusable without embargo. As a founding member of cOAlition S, the funder that co-created and popularised Plan S in 2018, the foundation’s 2025 refresh is being watched closely as a signal of where other research funders may be heading on APC costs.

    What Changed in the 2025 Policy Refresh?

    The 2025 policy is framed as a “refresh” of the 2021 policy, not a wholesale replacement — the core repository mandate survives intact. What changes is scope and support. It now applies to “all published research funded, in whole or in part, by the foundation” — termed Funded Manuscripts — and to “any data underlying the Funded Manuscripts,” a broader remit than the 2021 text.

    Three elements define the refresh:

    • Mandatory preprint deposit for every funded manuscript, in addition to the existing accepted-manuscript deposit requirement.
    • An earlier trigger for open data: data must now be accessible as soon as the preprint is available, not only once the accepted article is published.
    • Withdrawal of financial support for individual APC payments, shifting that cost onto grantees and co-authors.

    Why Did the Foundation Stop Paying APCs?

    The 2025 policy is unambiguous on this point: “The Foundation Will Not Pay Article Processing Charges (APC). Any publication fees are the responsibility of the grantees and their co-authors.” This is a change to support, not to what is mandated — grantees were never obliged to use the foundation’s APC funds under the 2021 policy, but many did, particularly for publishing in fully open-access journals listed in the Directory of Open Access Journals (DOAJ).

    The foundation frames this as part of a wider push against the gold-OA/APC model, which critics argue rewards well-resourced authors while pricing out others. Rather than underwriting per-article fees, it says it will back non-APC routes to open publishing, including its own Gates Open Research platform and select publisher partnerships covering Gates-funded authors outside the standard APC mechanism.

    The practical effect falls unevenly. Per an analysis by Lisa Janicke Hinchliffe in The Scholarly Kitchen (15 April 2024), Gates grantees publish roughly 4,000 papers a year — about 0.07% of articles published globally — so the aggregate revenue impact on any single open-access publisher is likely modest, even though the effect on individual grantees lacking alternative funding can be significant.

    What Does the New Preprint-First Mandate Require?

    Every Funded Manuscript must now be “published as a preprint in a preprint server recognized by the foundation” that applies sufficient scrutiny, carrying a CC BY 4.0 licence or equivalent. This sits alongside — not instead of — the existing requirement that the accepted manuscript be deposited “immediately upon publication in PubMed Central (PMC), or in another openly accessible repository, with proper metadata tagging identifying Gates funding.”

    Two details matter for compliance teams:

    • Grantees can self-exempt from the preprint requirement where they determine “a preprint is not appropriate due to ethical, safety or other legitimate concerns” — the foundation has not yet published criteria for what counts.
    • The foundation is not mandating a single preprint server. It has said it will point grantees to ASAPbio’s preprint server directory rather than maintain its own list, though it separately partnered with Taylor & Francis/F1000 to launch VeriXiv, a verified preprint platform grantees may optionally use.

    Copyright-retention language is essentially unchanged: grantees must retain enough copyright to deposit and licence the manuscript CC BY 4.0, and include a foundation-mandated acknowledgement and rights-retention statement.

    How Does Gates Compare With Other cOAlition S Funders?

    The Gates Foundation is not the only cOAlition S member re-examining its terms, but it is the first founding funder to formally withdraw central APC funding. Wellcome Trust and UK Research and Innovation (UKRI), the two other funders most closely associated with Plan S’s origins, still fund publication fees through institutional block-grant mechanisms rather than the pay-per-article support the Gates Foundation has now dropped.

    Funder Current policy effective date Pays APCs? Preprint requirement
    Gates Foundation 1 January 2025 (refresh) No — discontinued for individual manuscripts Mandatory, narrow ethical/safety exemption
    Wellcome Trust 1 January 2021 Yes — via institutional block grants Encouraged, not mandated
    UKRI 1 April 2022 (journal articles); 1 January 2024 (monographs) Yes — via block grant to research organisations Not mandated
    cOAlition S / Plan S baseline Founding principles from 2018 Funder-dependent; no central APC cap post-2024 Not centrally mandated; Rights Retention Strategy supported

    cOAlition S has been diplomatic about the change. Responding to the refresh, Executive Director Johan Rooryck said: “Five years on since Plan S was first published, it is entirely appropriate that funders are reviewing their OA policies to ensure they are effectively meeting their goals… Our collective dedication to making full and immediate OA a reality remains the driving force behind our collaboration.” Separately, Rooryck told Nature the refreshed policy is not “entirely in line” with cOAlition S guidance, while noting member funders retain “a lot of leeway” in how they implement shared principles. The Scholarly Kitchen nonetheless judges the policy relatively well aligned with Plan S’s repository route, since the accepted-manuscript deposit mandate — the mechanism that satisfies Plan S compliance — is retained, not replaced.

    Common Questions About the Gates Foundation Open Access Policy

    Does the Gates Foundation still pay APCs?

    No. Since the 2025 Open Access Policy took effect on 1 January 2025, the Bill & Melinda Gates Foundation no longer pays article processing charges for individual manuscripts. Publication fees are now the responsibility of grantees and co-authors, though the foundation continues to fund open infrastructure and select publisher arrangements.

    Does the Gates Foundation require preprints?

    Yes. Under the 2025 policy, every funded manuscript must be posted as a preprint on a foundation-recognised server carrying a CC BY 4.0 licence, in addition to the existing requirement to deposit the accepted manuscript in PubMed Central or another open repository. Grantees may seek an exemption only for documented ethical or safety concerns.

    Is the Gates Foundation still aligned with Plan S?

    Largely, yes. cOAlition S publicly welcomed the 2025 refresh, and analysts judge the policy broadly consistent with Plan S‘s repository route despite the APC-funding withdrawal. Executive Director Johan Rooryck said the update reflects funders “reviewing their OA policies,” while stopping short of declaring it fully in line with coalition guidance.

    What are the Gates Foundation’s data-sharing requirements?

    The 2025 policy requires underlying data to be openly accessible immediately once the funded manuscript becomes available — including at the preprint stage. This is earlier than the 2021 policy, which triggered the data-sharing mandate only once the accepted article was formally published in a journal.

    Implications and What to Watch Next

    For grantees without alternative funding, the squeeze is real: authors who relied on Gates APC support for DOAJ-listed open-access journals must now find a fee waiver, an institutional agreement, or a non-APC venue, while still meeting deposit and rights-retention requirements some publishers only accommodate via paid gold-OA routes. Research administrators managing multi-funder compliance will need to track this alongside UKRI and Wellcome Trust obligations, since the three funders no longer follow a uniform APC-support model despite shared Plan S origins.

    For publishers, immediate revenue exposure looks limited given the modest volume of Gates-funded output, but the policy adds pressure toward non-APC business models — waiver programmes, “pure publish” institutional agreements, and preprint-native platforms — that cOAlition S’s own “Beyond Article-Based Charges” working group, established with Jisc and PLOS, is separately examining.

    The signal for other funders is the more consequential story. Gates is the first cOAlition S founding member to formally withdraw central APC funding while retaining a Plan S-compatible repository mandate. Whether Wellcome Trust, UKRI, or other coalition funders follow with funding recalibrations — rather than eligibility or embargo changes — is the development worth monitoring as institutions plan multi-year compliance budgets.

    Research administrators managing multi-funder open access compliance can find related standards context in CASRAI’s research administration resources.

  • AI Regulations Around the World: A 4-Jurisdiction Comparison for Research Consortia

    AI regulations around the world diverge sharply in 2026: the EU AI Act is a binding, risk-tiered statute with extraterritorial reach; US oversight is a fragmented state-law patchwork with no federal statute; China runs a registration-and-content-control regime; and the Council of Europe treaty sets shared principles without direct enforcement. No single checklist covers every consortium partner.

    AI regulation is the set of binding statutes, administrative measures and international instruments that govern how artificial intelligence systems may be developed, deployed and used within a given jurisdiction. For a multi-country research consortium, that matters practically: the same AI-assisted analysis tool or generative writing aid can be lawful for one partner and non-compliant for another, purely because of where each institution sits.

    This article maps the four regimes that most often collide in international data-sharing agreements — the EU AI Act, US state AI laws, China’s AI measures, and the Council of Europe’s AI treaty — and identifies where the friction actually occurs, not just what each law says in isolation.

    Contents

    What are the main AI regulatory regimes research consortia must track?

    Four regimes dominate cross-border research collaboration in 2026: the EU’s binding AI Act, a growing set of US state statutes, China’s registration-led administrative measures, and the Council of Europe’s rights-based treaty. Each uses a different legal mechanism, a different geographic trigger, and a different enforcement model, which is precisely why a consortium cannot rely on one partner’s compliance work to cover the group.

    Regime Legal status Geographic reach Compliance approach Relevance to research consortia
    EU AI Act (Regulation (EU) 2024/1689) Binding regulation, directly applicable in all EU member states Extraterritorial: covers providers and deployers outside the EU where an AI system’s output is used within the EU Risk-tiered (unacceptable / high / limited / minimal); high-risk obligations broadly apply from 2 August 2026 A non-EU partner can still be caught if any consortium member deploys the tool’s output in the EU; grant-review and admissions-style AI can fall into Annex III high-risk categories
    US state AI laws No binding federal AI statute; state statutes such as the Colorado AI Act and California’s AI Transparency Act Applies within the enacting state; a December 2025 executive order pushes federal preemption of “burdensome” state rules, but this is contested and unsettled as of mid-2026 Sector- and harm-specific (algorithmic discrimination, transparency, deepfakes) rather than one risk taxonomy A single US institution can trigger several inconsistent duties depending on which state its staff, servers or subcontractors sit in
    China’s AI measures Binding administrative measures enforced by the Cyberspace Administration of China (CAC), now folded into the amended Cybersecurity Law from January 2026 Applies to AI services offered within China; requires algorithm registration with the CAC before deployment Registration- and content-control-led: mandatory labelling of AI-generated content, security assessments, real-name verification Chinese partner institutions typically cannot lawfully run an unregistered foreign AI tool against shared data, creating a hard blocker for joint analysis pipelines
    Council of Europe AI treaty First legally binding international AI treaty (Framework Convention on Artificial Intelligence, Human Rights, Democracy and the Rule of Law) Open to Council of Europe members and non-member signatories, including the US, UK, Canada and Japan; needs ratification by five signatories, including three Council of Europe states, to enter into force Principles-based: human rights, democracy and rule-of-law safeguards for public- and private-sector AI Offers shared language consortia can cite in data-sharing agreements, but is not self-executing and needs domestic implementing law in each signatory state

    How does the EU AI Act apply to multi-country research?

    The EU AI Act entered into force on 1 August 2024, with obligations phased in over several years. Bans on unacceptable-risk systems and AI-literacy duties applied from 2 February 2025; general-purpose AI obligations followed on 2 August 2025; and high-risk system obligations broadly apply from 2 August 2026, with penalties reaching €35 million or 7% of global annual turnover.

    What consortium leads consistently underestimate is scope. Like the GDPR before it, the Act reaches beyond EU borders: it applies to providers and deployers established outside the Union whenever the output of their AI system is used within it. A US or Asia-based partner running an AI-assisted screening tool that feeds results into an EU-led work package can be pulled into EU obligations even without an EU office. Annex III’s high-risk categories — including systems used in education, employment and essential services — also reach some AI-assisted grant-review and research-integrity screening tools.

    What do US state AI laws mean for consortium partners?

    The United States has no comprehensive federal AI statute in 2026. Instead, regulation is set state by state: Colorado’s AI Act (SB 24-205), the first comprehensive US state AI law, requires reasonable care to prevent algorithmic discrimination in high-risk systems, with implementation delayed to 30 June 2026. California has separately enacted an AI Transparency Act and a frontier-model safety statute.

    A December 2025 executive order directed federal agencies to challenge state AI laws viewed as inconsistent with a lighter-touch national standard, but as of mid-2026 that preemption push is unsettled and existing state statutes remain in force. For a consortium, a single US institution’s obligations can shift depending on which state its staff, infrastructure or subcontractors sit in — and may change again if preemption litigation succeeds.

    How does China regulate AI differently?

    China’s approach is registration-led and content-focused rather than risk-tiered. The Cyberspace Administration of China requires algorithm registration and security assessment before many AI services can be deployed. The Measures for Labelling AI-Generated and Synthetic Content took effect in September 2025, three national standards on generative AI security took effect on 1 November 2025, and AI governance obligations were folded into the amended Cybersecurity Law from January 2026.

    For research consortia, this is a structurally different problem from the EU or US: it is not primarily about disclosure or risk assessment, but whether a given AI tool may operate against Chinese-held data at all. An unregistered foreign analysis tool cannot lawfully be applied to a Chinese partner’s data set, regardless of how compliant it is elsewhere.

    What does the Council of Europe AI treaty add?

    The Council of Europe’s Framework Convention on Artificial Intelligence, Human Rights, Democracy and the Rule of Law is the first legally binding international treaty on AI. It opened for signature in September 2024, and early signatories include the European Union, the United States, the United Kingdom, Canada and Japan. It requires ratification by five signatories, including three Council of Europe member states, to enter into force.

    Unlike the EU AI Act, the treaty does not create a detailed compliance regime of its own; it sets human-rights and rule-of-law principles that signatory states must implement through domestic law. For a consortium, it functions less as a rulebook and more as shared vocabulary — a reference point agreements can cite when partners disagree on baseline AI safeguards, even where no national statute yet covers a given use case.

    Where do multi-jurisdiction consortia hit compliance friction?

    The practical friction is rarely about any one regime being stricter than another — it is about the regimes using incompatible triggers. The EU AI Act asks “where is the output used?” US state law asks “which state is the deployer in?” China asks “is this algorithm registered?” The Council of Europe treaty asks “has this state ratified and implemented it?”

    • Data-sharing agreements drafted for one jurisdiction’s risk taxonomy often fail to address another partner’s registration or transparency duties.
    • AI-assisted research tools — plagiarism and integrity screening, generative drafting aids, automated peer-review triage — can simultaneously be “limited risk” in the EU, unregulated in one US state, and require CAC registration in China.
    • Consent and disclosure language for AI use in participant-facing materials rarely satisfies all four regimes’ transparency requirements at once.
    • Governing-law clauses in consortium agreements need to specify which partner’s AI-use obligations apply to shared infrastructure, not just which partner “owns” the data.

    UKRI, Horizon Europe consortia and cOAlition S-aligned funders increasingly expect applicants to describe how AI tools are governed across all partner sites, not only the lead institution’s — making this mapping exercise a funding-eligibility question, not only a legal one.

    Answer-first Q&A

    Are there any global AI regulations?

    No single binding global AI law exists. The Council of Europe’s Framework Convention on Artificial Intelligence, Human Rights, Democracy and the Rule of Law, opened for signature in September 2024, is the first legally binding international AI treaty, but it needs ratification by five signatories, including three Council of Europe states, before it takes effect.

    Which countries have the most AI regulations?

    The European Union has the most comprehensive statutory AI framework via the EU AI Act, while the United States has the largest volume of measures once state activity is counted. In the 2025 legislative session, all 50 states introduced AI bills and 38 enacted measures, per the National Conference of State Legislatures.

    Which countries have no AI-specific restrictions?

    Several jurisdictions, including the United Arab Emirates and Saudi Arabia, rely on voluntary principles and sector guidance rather than a dedicated AI statute, though both run active national AI strategies and are expected to formalise binding rules as adoption accelerates. Partners based there face fewer AI-specific duties, but other data laws still apply.

    What should multi-country consortia do next?

    No convergence toward a single global AI standard is likely before 2027. The EU AI Act’s high-risk obligations continue phasing in through 2026 and 2027, US preemption litigation remains unresolved, China’s registration regime keeps expanding, and Council of Europe ratifications will accumulate gradually. Consortium agreements that hard-code today’s rules will need scheduled review clauses, not one-off sign-off.

    Research administration teams should treat AI-use disclosure as a standing agenda item in consortium governance, map each partner institution against the table above at project start, and build AI-tool review into existing data-sharing and research administration workflows rather than a separate compliance track.

  • Text and Data Mining Copyright Exception: The UK’s 2026 Decision

    The UK’s text and data mining copyright exception currently permits copying protected works for computational analysis only where the purpose is non-commercial research, under Section 29A of the Copyright, Designs and Patents Act 1988. In March 2026, the UK government confirmed it will not introduce a broader, opt-out-based exception for commercial AI training, leaving that narrow research carve-out unchanged while commercial text and data mining continues to require a licence.

    Text and data mining (TDM) is the automated analytical process of extracting patterns, structured data, and statistical relationships from digital text, images, and other content — typically the first stage in assembling a corpus to train a machine-learning or generative AI model.

    What is the UK’s text and data mining copyright exception?

    Section 29A of the Copyright, Designs and Patents Act 1988 allows a person with lawful access to a copyright work — for example through a subscription, a library licence, or open web access — to make a copy of that work for the purpose of computational analysis, provided the resulting copy is used solely for non-commercial research. The exception was introduced in 2014, making the UK one of the earliest jurisdictions to legislate specifically for TDM.

    Two features make Section 29A unusually workable for universities. First, it extends to individual researchers, not only to the institutions that employ them. Second, under section 29A(5), any contract term that purports to prevent or restrict this lawful copying is unenforceable — a publisher cannot use its licence terms to override the statutory right. What the exception does not do is authorise commercial use: a university spin-out or an industry-funded lab training a model for eventual commercial deployment sits outside its protection.

    What broader exception did the government propose?

    The UK Intellectual Property Office first floated a much wider TDM exception in 2022, permitting data mining for any purpose, including commercial AI training, with no opt-out for rights holders. That proposal was abandoned in 2023 after sustained opposition from publishers, musicians, and other creative-industry rights holders, who argued it would let AI developers use copyrighted work without consent or payment.

    The government returned to the question in its December 2024 consultation, Copyright and Artificial Intelligence, which ran for ten weeks, from 17 December 2024 to 25 February 2025. This time the model differed: a rights-reservation (“opt-out”) mechanism paired with a broad exception covering unreserved material, alongside new transparency obligations requiring AI developers to disclose what content they use and how they acquire it. The design echoed Article 4 of the EU’s Digital Single Market (DSM) Directive, and the consultation set out three broad directions: strengthen licensing, introduce the opt-out exception, or make no legislative change.

    • Option A — status quo: retain Section 29A unchanged, relying on licensing markets to develop organically.
    • Option B — broad exception with opt-out: allow TDM for any purpose unless a rights holder actively reserves their rights.
    • Option C — licensing-led framework: mandate transparency and collective licensing infrastructure without a new statutory exception.

    What did the UK government decide in March 2026?

    The government confirmed in March 2026 that it will not proceed with a new text and data mining exception. According to The Ivors Academy, which represents songwriters and composers and was among the respondent organisations, 88% of consultation respondents called for stronger copyright protection and licensing rather than a broadened exception. Section 29A therefore remains the operative law: non-commercial research TDM is lawful without a licence, and everything outside that narrow purpose still requires rights-holder permission.

    Rather than legislating a new exception, the government is directing policy into four linked work programmes: digital replicas (deepfake-style AI recreations of a person’s voice or likeness), AI-output labelling, creator control and transparency obligations for AI developers, and support for independent creatives. Legislation on transparency — requiring AI developers to disclose training data provenance — remains under active consideration even though the exception itself has been shelved.

    How does the UK exception compare with the EU’s TDM rules?

    The UK operates a single, narrower exception than the EU, which — under the 2019 DSM Directive — runs two parallel TDM exceptions with different scopes and different rules on opting out.

    Feature UK — Section 29A, CDPA 1988 EU — Article 3, DSM Directive EU — Article 4, DSM Directive
    Permitted purpose Non-commercial research only Scientific research Any purpose, including commercial
    Eligible parties Research institutions and individual researchers Research organisations and cultural heritage institutions Any lawful user
    Opt-out for rights holders None — contract terms restricting it are unenforceable None Yes — rights holders may reserve rights via machine-readable means
    Extends to databases No — copyright works only Yes Yes
    Commercial research covered No Limited, in some readings Yes

    The UK’s December 2024 proposal effectively asked whether the country should import something resembling Article 4 — a broad, opt-out-based exception. Following the March 2026 decision, the UK still has no equivalent, leaving a materially narrower legal basis for commercial AI training than exists across the EU.

    What does this mean for research libraries and AI labs?

    For university libraries and text-mining labs conducting genuinely non-commercial research, the practical position is unchanged: Section 29A continues to authorise corpus-building from lawfully accessed material, and publisher licence terms cannot override that right. Institutions should still document lawful access and non-commercial purpose, since the boundary — not the existence — of the exception is what gets tested.

    For AI developers, commercial spin-outs, and industry-funded research partnerships, the position stays materially harder than under a broad opt-out exception. These organisations must continue to:

    • Secure licences from publishers, image libraries, and other rights holders before using material for training corpora with any commercial application.
    • Track the government’s forthcoming transparency obligations, which may require disclosure of training-data provenance even without a new exception.
    • Watch the EU comparison closely — jurisdictions with broader TDM rights may become more attractive for model training, a concern the government itself raised in 2024.
    • Distinguish clearly between non-commercial research activity (protected) and downstream commercial application of the same corpus (not protected).

    Research administrators managing institutional research administration functions will need to keep licensing and TDM-exception boundaries visible in data-management and AI-use policies, particularly where university-industry collaborations blur the line Section 29A treats as decisive.

    Frequently asked questions

    What is the text and data mining exception in UK copyright law?

    The text and data mining exception is a provision in Section 29A of the Copyright, Designs and Patents Act 1988 that allows lawful users to copy copyright works for computational analysis, but only for non-commercial research. It does not cover commercial AI training, and any contract term restricting this lawful use is unenforceable under section 29A(5).

    Does the UK allow AI companies to train models on copyrighted text without a licence?

    No. Outside the narrow non-commercial research exception, UK copyright law requires AI developers to obtain a licence from rights holders before using protected text, images, or data for training. The government confirmed in March 2026 it will not introduce a broader exception, so commercial text and data mining still needs permission.

    What was the UK government’s opt-out proposal for AI and copyright?

    In its December 2024 consultation, the government proposed letting rights holders reserve their rights (opt out) while introducing a wide exception permitting AI developers to mine unreserved material at scale — modelled loosely on the EU’s Article 4 DSM Directive exception. This proposal was not taken forward.

    How is the UK’s TDM exception different from the EU’s?

    The UK’s single exception (Section 29A) covers only non-commercial research but extends to individual researchers, not just institutions. The EU’s DSM Directive instead runs two exceptions: Article 3 for research organisations and cultural-heritage bodies, and Article 4, a broader opt-out exception the UK ultimately declined to replicate.

    Looking ahead

    The March 2026 decision closes one chapter of the UK’s AI-copyright debate but opens another: a licensing-led, transparency-driven framework built around four active work programmes rather than a single statutory fix. For research libraries, the immediate legal position is stable. For AI labs and commercial partnerships built on UK-hosted training data, the absence of a broad exception means licensing negotiations — not statute — will continue to determine what can lawfully be mined.

  • Deemed Export Rule and AI Research Compliance

    The deemed export rule treats the release of export-controlled technology or source code to a foreign national inside the United States as if it were an export to that person’s home country, even though nothing crosses a physical border. For AI research groups, this means that giving a foreign-national graduate student or postdoc access to certain model weights, training code, or restricted technical data can itself require a federal export licence.

    A deemed export is any release of “technology” or “technical data” — controlled under the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR) — to a foreign person physically present in the United States. The doctrine is old; its application to frontier AI systems is new, and it now collides with university research practice.

    What is the deemed export rule?

    Under 15 CFR 734.13(b) of the EAR, releasing controlled technology or source code to a foreign person in the United States is “deemed” to be an export to that person’s country of nationality. The Bureau of Industry and Security (BIS), the Commerce Department agency administering the EAR, names universities and high-technology research institutions as typical deemed-export-licence users, alongside biochemical, medical and computer-sector organisations.

    A “release” can occur through conversation, email, or lab access that lets a foreign national read or modify controlled source code — no shipment is required. Permanent residents, US citizens, and “protected individuals” under US immigration law are exempt; most international graduate students and postdocs on visas are not.

    How the fundamental research exclusion applies to AI research

    Most university AI research avoids deemed export licensing through the fundamental research exclusion at 15 CFR 734.8. Fundamental research is basic or applied research in science and engineering where the resulting information is ordinarily published and shared broadly, with no restrictions on foreign-national participation and no government-imposed access controls.

    The exclusion is conditional, not automatic. It fails where:

    • Results are restricted for proprietary or commercial reasons, such as a sponsorship agreement with a publication-delay clause.
    • The funding agreement imposes access or dissemination controls, which some defence-adjacent AI grants do.
    • The activity involves direct transfer of a controlled item — hardware, software, or source code — rather than an exchange of research information.

    Information already publicly available, including open-access papers and public code repositories, is separately exempt from EAR licensing.

    When AI models, weights and training infrastructure trigger a deemed export

    Using a publicly available AI chatbot or API is not, by itself, a release of controlled technology. Risk rises when a foreign national gains access to model architecture details, training methodologies, or model weights covered by an Export Control Classification Number (ECCN) on the Commerce Control List, or to advanced computing hardware BIS has specifically controlled.

    BIS tightened advanced-computing controls in its October 2022 Interim Final Rule, amended October 2023, then went further in January 2025 with a Framework for Artificial Intelligence Diffusion rule that, for the first time, extended export-control treatment to certain closed-weight AI model parameters, not only training hardware. Disclosing weights, architecture specifications, or training-cluster configuration for a covered model to a foreign-national researcher can itself be a release event.

    Much of this tightening is explicitly framed around china ai regulation concerns — restricting frontier compute and model know-how flowing to entities on the BIS Entity List. Nationality alone does not create liability; nationality plus access to a controlled item, combined with funding or sponsor restrictions, does.

    US deemed export rules vs the EU AI Act research exemption

    Institutions with EU partnerships increasingly ask how the US doctrine compares with the European approach. The EU AI Act — Regulation (EU) 2024/1689 — takes a structurally different route: rather than controlling technology transfer by nationality, it excludes AI systems and models developed and used exclusively for scientific research from most of the Act’s obligations, under Article 2(6) and Article 2(8).

    Aspect US deemed export rule EU AI Act research exemption
    Governing instrument EAR, 15 CFR 734.13(b) and 734.8 Regulation (EU) 2024/1689, Art. 2(6) & 2(8)
    What triggers the rule Release of controlled technology to a foreign person Placing an AI system on the market or into service
    Exclusion basis Fundamental research intended for open publication Research and development activity, prior to market placement
    Administering body Bureau of Industry and Security (Commerce Dept.) National market surveillance authorities / EU AI Office
    Nationality relevant? Yes — central to the rule No — exemption is activity-based, not person-based

    The distinction matters for compliance design: a US export control office manages deemed exports as a personnel and access-control question, while an EU research-exemption assessment is a product-lifecycle question. A model built for fundamental research at a US university may fall outside the AI Act exemption once deployed commercially — the two frameworks do not map onto each other cleanly.

    Compliance steps for universities with foreign national researchers

    Export control officers, research administrators, and AI lab principal investigators need a shared workflow before granting foreign nationals lab or system access:

    1. Screen every incoming foreign national against the BIS Entity List and the Treasury Denied Persons List before granting technical access.
    2. Classify the technology, dataset, or model against the Commerce Control List to determine whether an ECCN applies.
    3. Document the fundamental research exclusion in writing at project inception — funding terms, publication plans, and sponsor restrictions.
    4. Restrict access to controlled weights or training infrastructure until the export control office confirms licence status.
    5. Certify deemed export status accurately on Form I-129 for H-1B, H-1B1, L-1, and O-1A hires, as USCIS requires.
    6. Use the NIST AI Risk Management Framework to document AI system risk tiers internally — a defensible record, though not itself an export-control exemption.

    Treat this as distinct from state ai laws, such as Colorado’s and California’s AI transparency statutes, which govern AI deployment to end users, not technology transfer to foreign persons — a university can comply with one and still be exposed under the other. Guidance from the Center for AI Standards and Innovation (CAISI), the Commerce Department body that succeeded the original AI Security Institute at NIST, can inform risk-evaluation methodology, though it is not itself an export-control determination. See CASRAI’s research administration resources for broader governance context.

    Frequently asked questions

    What are the criteria for a deemed export?

    A deemed export occurs when controlled technology or source code is released to a foreign person inside the United States. The criteria: the item sits on the Commerce Control List or US Munitions List, the recipient is not a citizen, permanent resident, or protected individual, and no exclusion applies.

    How can a university determine whether an activity is a deemed export?

    A university’s export control office classifies the technology against its ECCN or USML category, checks whether the fundamental research exclusion applies, and confirms the researcher’s immigration status. If the technology is controlled, the researcher is a foreign person, and no exclusion fits, a licence is required before access.

    Who is exempt from the deemed export rule?

    US citizens, lawful permanent residents, and individuals granted protected individual status under US immigration law are exempt from deemed export licensing regardless of the technology involved. Most international students and postdocs on visas do not qualify for this exemption and depend instead on the fundamental research exclusion.

    Does using a publicly available AI model trigger a deemed export?

    No. Interacting with a publicly available AI model — a public API, chatbot, or open-weight release with no access restrictions — is not a controlled release under the EAR. Risk arises only when a foreign national gains access to restricted model weights, proprietary architecture details, or controlled training infrastructure not available to the public.

    Implications and outlook

    Export control offices built their playbooks around physical items and classified research; AI weights and training infrastructure do not fit that playbook cleanly. As BIS extends ECCN coverage into software and model parameters, universities running foreign-national-staffed AI labs face rising documentation burden even where no licence is ultimately required.

    Expect continued divergence between the deemed export regime, EU AI Act research-exemption practice, and state ai laws — three separate compliance tracks addressing different questions. Research administrators who map these tracks now, rather than after an incident, will be better placed as controls continue to tighten.