Seven years after cOAlition S launched Plan S, Plan S compliance has moved from a policy novelty to a routine administrative discipline — but “routine” does not mean simple. As institutions head into the 2026 reporting cycle, research offices are still fielding basic questions from principal investigators about which of the three compliance routes applies to a given grant, and grant management systems still struggle to capture licensing metadata in a form that survives an audit. This piece sets out a practical checklist for research administrators responsible for demonstrating Plan S compliance across UKRI, Wellcome, ERC and NWO-funded outputs.
The underlying policy has not changed dramatically since its 2018 launch, but its operational surface has. Publishers have consolidated transformative agreements, rights-retention strategies have become the default route for many UK institutions, and funders have tightened monitoring of self-archived manuscripts in approved repositories. The compliance burden has therefore shifted from “which journal did they publish in” to “can we produce the metadata trail to prove the route taken.”
The Three Plan S Compliance Routes
cOAlition S — the international consortium of research funders, including UKRI, Wellcome, the European Commission (via Horizon Europe), and several national funders — defines three routes by which a funded output can satisfy Plan S requirements. Every research administrator building a compliance workflow needs a clear internal definition of each.
- Gold open access route: publication in a fully open access journal or platform, or an open access article within a hybrid journal covered by a transformative agreement, with a compliant licence (typically CC BY) applied immediately on publication.
- Rights retention route: the author applies a prior licence — usually CC BY — to the accepted manuscript at submission, informing the publisher that a funder mandate requires this. This route has become the default mechanism recommended by UKRI and several other cOAlition S members precisely because it does not depend on publisher cooperation or subscription negotiations.
- Approved repository route: the author deposits the accepted manuscript (or, where permitted, the version of record) in an institutional or subject repository that meets cOAlition S technical requirements, with no embargo beyond what the funder allows — in most current cOAlition S policies, this means immediate deposit with a compliant licence, not a delayed embargo.
The critical administrative point is that these routes are not mutually exclusive fallbacks chosen in sequence; they are three parallel doors, and the appropriate one often depends on the venue the researcher has already selected, the transformative agreement coverage at the institution, and the specific funder’s guidance on acceptable embargo periods.
Funder-Specific Variations Research Offices Must Track
Although cOAlition S coordinates a shared framework, individual funders retain discretion over enforcement mechanisms, grace periods and sanctions — and these variations are where most non-compliance actually occurs.
UKRI
UKRI’s open access policy, which applies to research articles submitted for publication from awards made after its 2022 implementation date, requires immediate open access with a CC BY licence for journal articles, and has extended equivalent requirements to monographs, book chapters and edited collections from 2024. UKRI has been explicit that rights retention is an acceptable and encouraged mechanism, and it does not permit publisher embargoes on journal articles funded under its policy.
Wellcome
Wellcome operates one of the more prescriptive policies within cOAlition S: it requires immediate open access with a CC BY licence (or CC BY-ND in limited circumstances) for all research articles, and — notably — it will not pay article processing charges to journals that do not offer a compliant open access route, pushing many Wellcome-funded authors towards rights retention or fully open venues.
ERC (Horizon Europe)
The European Research Council, funding under Horizon Europe, requires immediate open access to peer-reviewed publications with no embargo, and mandates deposit of the underlying data in line with FAIR principles where feasible. ERC compliance monitoring is integrated into Horizon Europe’s broader open science requirements, meaning research offices supporting ERC grant holders must track both publication and data-deposit obligations together, not as separate workstreams.
NWO
The Dutch Research Council (NWO) aligns closely with the original Plan S text and has been an active proponent of rights retention across Dutch universities, working alongside national consortia to secure publisher acknowledgement of the strategy. Administrators supporting NWO-funded researchers should note that Dutch institutional agreements often pre-negotiate compliance at the consortium level, reducing the burden on individual grant holders but increasing the importance of confirming which agreements are actually in force for a given journal at the time of submission.
Recording Compliance in Grant Management Systems
The most persistent operational gap is not policy interpretation but data capture. Many grant management systems were built around financial and reporting milestones, not licensing metadata, and research offices frequently discover compliance gaps only at final report stage — too late to correct.
- Capture the compliance route at submission, not at publication. Ask researchers to record their intended route (gold, rights retention, or repository) when they submit a manuscript, not retrospectively when compiling a funder report.
- Store the rights-retention statement text used. If a researcher applies a rights-retention statement to a submitted manuscript, the exact wording and date should be logged against the grant record, since this is the evidence a funder will request.
- Link repository deposit records to grant identifiers. Persistent identifiers — ORCID for the researcher, DOI for the output, and a funder or grant reference — should be cross-referenced in both the institutional repository and the grant management system so a single query can reconstruct the compliance trail.
- Flag embargo periods against funder-specific rules. A generic “12-month embargo” field is not sufficient when UKRI and ERC require zero embargo on journal articles while other, non-cOAlition S funders may still permit longer delays; systems should record the applicable policy alongside the embargo value.
- Audit transformative agreement coverage separately from author self-report. Publisher-reported compliance data under transformative agreements does not always match what the researcher believes was agreed; reconciling the two periodically catches errors before final reporting.
What This Means for Research Administrators
The practical effect of seven years of Plan S implementation guidance is that compliance has become a metadata management problem as much as a policy one. Research offices that treat rights retention, repository deposit and licensing decisions as data to be captured at the point of submission — rather than reconstructed at reporting time — spend far less effort on remediation. Given that cOAlition S funders increasingly cross-reference ORCID records, repository metadata and publisher reporting, discrepancies are becoming easier to detect, which raises the cost of poor record-keeping.
Institutions should also expect continued divergence rather than convergence among individual funder policies. UKRI’s extension of open access requirements to long-form outputs, Wellcome’s refusal to fund non-compliant APCs, and the ERC’s integration of publication and data mandates all point towards funder-specific detail becoming more important, not less, even as the shared cOAlition S framework remains stable.
Looking Ahead
As the Plan S open access framework matures alongside broader European and UK open science policy, research administrators should treat compliance recording as core grants infrastructure rather than a compliance afterthought. Institutions that build ORCID-linked, funder-policy-aware metadata capture into their grant management systems now will be better placed to respond as funders sharpen enforcement and as monitoring increasingly relies on machine-readable evidence rather than self-declaration.