CASRAI Dictionary

Tag: horizon europe open access requirements

  • ACM Open Access vs Plan S: 2026 Compliance Check

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

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

    What is ACM open access?

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

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

    What does Plan S actually require?

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

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

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

    Does ACM Open satisfy cOAlition S requirements?

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

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

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

    What happened to ACM’s transformative agreements?

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

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

    What this means for institutions and researchers

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

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

    Frequently asked questions

    What is ACM open access?

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

    Is ACM open access free for readers?

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

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

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

    What licence does ACM Open use?

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

    Looking ahead

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

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

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

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

    What Is the PMC Open Access Subset?

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

    NLM groups the subset into three licence tiers:

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

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

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

    What Is Plan S?

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

    Under Plan S principles, compliant publication routes include:

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

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

    PMC Open Access Subset vs Plan S: Key Differences

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

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

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

    Does Plan S Compliance Require the PMC Open Access Subset?

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

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

    Common Questions

    What is PMC open access?

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

    Are PMC and PubMed the same?

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

    Is PMC free to use?

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

    Implications for Authors and Institutions

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

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

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

  • Rights Retention Strategy: Authors Keep Rights

    The Rights Retention Strategy (RRS) is the cOAlition S mechanism that lets an author apply a Creative Commons Attribution (CC BY) licence to their Author Accepted Manuscript (AAM) — the peer-reviewed, pre-typeset version of a paper — before any publisher copyright agreement is signed. Because the licence exists first, no later publishing contract can strip the author of the right to deposit and reuse that manuscript. It is not itself a route to open access; it is a rights-based safeguard that makes the Green route enforceable even when a publisher’s terms would otherwise block it.

    In one sentence: the Rights Retention Strategy is a funder-attached licensing condition, applied at the point of grant award, requiring a CC BY licence on the AAM so that no subsequent publisher agreement can override the author’s right to share it openly.

    What Is the Rights Retention Strategy?

    cOAlition S developed the Rights Retention Strategy and announced it on 15 July 2020, designed to ensure that scholarly publications arising from funded research could be made open access regardless of a publisher’s self-archiving embargo. Under the RRS, a cOAlition S funder’s grant conditions require that a CC BY licence is applied to the AAM before submission to a journal — the licence is a condition of the funding, not a request made to the publisher.

    Authors signal this by adding a rights retention statement to the manuscript’s acknowledgements section and cover letter at submission, typically worded along the lines of: “For the purposes of open access, the author has applied a CC BY public copyright licence to any Author Accepted Manuscript version arising from this submission.” This statement puts the publisher on notice before any copyright transfer agreement (CTA) is discussed, which is the legal mechanism that prevents a later CTA from overriding it.

    How Does Rights Retention Differ from Green and Gold Open Access?

    Green OA is a route: an author deposits a manuscript in a repository, often after an embargo the publisher sets. Gold OA is also a route: the publisher makes the version of record open immediately, usually funded by an article processing charge (APC). The Rights Retention Strategy is neither route on its own — it is a rights mechanism that removes the publisher’s ability to impose an embargo or demand exclusive rights over the AAM, which in practice enables no-embargo Green OA without requiring an APC.

    Mechanism When rights are secured Licence applied Embargo Typical cost to author
    Rights Retention Strategy At grant award, before submission CC BY on the AAM None None
    Green OA (standard) At deposit, after publication Publisher-defined, often more restrictive Often 6–24 months None
    Gold OA At publication Usually CC BY on the version of record None Article processing charge

    The practical distinction matters for compliance: an author can satisfy a funder’s immediate-CC-BY requirement through Rights Retention without paying an APC, which is why cOAlition S built the strategy — to decouple open access compliance from publisher paywalls and Gold OA pricing.

    What Do UKRI, cOAlition S and REF Require of Authors?

    UKRI’s open access policy, in effect from 1 April 2022, requires that in-scope peer-reviewed research articles be made immediately open access on publication, via the version of record or the AAM under a CC BY licence, with no embargo permitted. Rights Retention is the mechanism many UK institutions use to guarantee this for the AAM route when a journal will not offer immediate Gold OA on acceptable terms.

    Several UK universities embedded Rights Retention into institutional policy well ahead of REF deadlines: the University of Edinburgh introduced it in April 2022, the University of Cambridge in May 2022, and the University of St Andrews in December 2022, with the N8 Research Partnership universities committing to similar statements. King’s College London instituted its Rights Retention Strategy through a revised Research Publications Policy effective 1 March 2023, explicitly framed around meeting both funder and future REF eligibility requirements. Institutional rights retention is not a new idea — Harvard University adopted the first version of this approach in 2008, more than a decade before Plan S formalised it for European and UK funders.

    • Check whether your funder is a cOAlition S signatory or a UKRI council with an equivalent CC BY mandate.
    • Add the rights retention statement to your manuscript’s acknowledgements and cover letter at submission, not after acceptance.
    • Deposit the AAM in your institutional repository on acceptance, without waiting for an embargo to expire.
    • Keep a record of the statement and deposit date for REF output-eligibility evidence.

    Authors publishing multi-author, multi-funder papers should note that the corresponding author typically applies the statement on behalf of all co-authors when negotiating with the journal — clear, attributed authorship records make this easier to evidence, which is why institutions increasingly pair rights retention guidance with structured authorship documentation.

    Common Questions About Rights Retention

    What is the Rights Retention Strategy?

    The Rights Retention Strategy is cOAlition S’s mechanism requiring a CC BY licence on the Author Accepted Manuscript, applied as a funder grant condition before journal submission. It guarantees immediate, embargo-free open access to the peer-reviewed manuscript without requiring an article processing charge or publisher permission.

    What does it mean to retain rights under Plan S?

    Retaining rights means the author keeps sufficient non-exclusive rights over the AAM to deposit, share and licence it for reuse, even after signing a publisher’s copyright transfer agreement. The CC BY licence takes legal precedence because it was applied before that agreement existed.

    What is the Rights Retention Strategy statement wording?

    Institutions use variants of a standard sentence: the author has applied a CC BY licence to the AAM “for the purposes of open access,” included in the submission cover letter and manuscript acknowledgements. Several UK universities, including Edinburgh, publish translated versions of this exact statement for international co-authors.

    How do authors notify a publisher under the Rights Retention Strategy?

    Authors notify publishers by inserting the rights retention statement into the manuscript submission itself — typically the cover letter and acknowledgements — rather than negotiating separately. This creates a documented, timestamped notice that the CC BY licence predates any subsequent copyright transfer agreement.

    What This Means for Institutions and the Next REF

    For research administrators, Rights Retention converts open access compliance from a publisher-dependent negotiation into an institution-controlled process: the licence is secured at the point of funding, not the point of publication, so compliance no longer hinges on which journal an author chooses. This matters directly for REF output eligibility, where a documented deposit and licence trail is the evidence assessors and funders will check.

    Some publishers have pushed back against Rights Retention Strategy statements, occasionally asking authors to remove them or delaying decisions, though institutions with published policies — from Harvard onward — report continued publication success across their author base. As more UK institutions and cOAlition S funders align on CC BY-by-default AAM licensing, expect the strategy to become the default compliance route wherever Gold OA APCs are unaffordable or unavailable, with research administrators increasingly tracking deposit and licence records through structured research administration systems rather than manual follow-up.

  • Horizon Europe Open Access Policy: Gold vs Green

    Under Horizon Europe, gold open access lets grantees claim Article Processing Charges (APCs) as an eligible cost when publishing in a fully open access journal, while green open access requires no APC but demands immediate deposit of the accepted manuscript in a repository — Horizon Europe permits no embargo period on either route. The route chosen changes what a grant can reimburse, not whether the underlying obligation to provide open access is met.

    Horizon Europe open access policy is the European Commission’s mandate, set out in the Horizon Europe Model Grant Agreement, requiring immediate open access to peer-reviewed publications arising from EU-funded research, with no embargo and a Creative Commons Attribution (CC BY) licence as the default. This article resolves the specific pre-award question research administrators and principal investigators raise most often: which route — gold or green — is cheaper, faster to budget, and lower-risk to comply with.

    What does the gold open access route require and cost?

    Gold open access means publishing the final version of record directly in a journal or platform that is open access from the moment of publication. Under Horizon Europe, APCs for publishing in a fully open access journal are an eligible cost and can be charged to the grant budget, provided the journal is genuinely open access rather than a subscription title offering a paid open option.

    The European Commission’s Horizon Europe Annotated Grant Agreement draws a firm line here: APCs paid to hybrid journals — subscription journals that unlock a single article for a fee — are not an eligible cost unless the journal is covered by an institutional transformative agreement the funder recognises. Grantees who publish gold must still deposit a copy of the final published version, and its metadata, in a trusted repository at the time of publication; paying the APC does not remove the deposit obligation.

    A cost-free variant of the gold route exists: Open Research Europe (ORE), the European Commission’s own peer-reviewed publishing platform for Horizon Europe and Euratom beneficiaries. ORE carries no APC for eligible authors, publishes under CC BY, and satisfies the immediate-access requirement without a grant budget line at all.

    What does the green open access route require, and is there really no embargo?

    Green open access means publishing as normal — including in subscription or hybrid journals — and separately depositing a copy of the work in a trusted repository so readers can access it without a subscription. Because no APC is typically paid, the green route carries no direct cost to reimburse, which is its main budgetary appeal.

    The compliance burden shifts instead to timing and rights. Horizon Europe’s Model Grant Agreement requires the author’s accepted manuscript (AAM) — the final peer-reviewed text before typesetting — to be deposited and made publicly accessible immediately on publication, with no embargo permitted. This is stricter than many national funder policies, several of which still allow embargoes of six to twelve months for the green route. Grantees must also apply a CC BY licence to the deposited manuscript, which means notifying the publisher of their funder obligations at submission, since standard subscription-journal copyright transfer agreements do not grant this right automatically.

    Retaining the necessary rights is the single most common green-route compliance failure. Institutions increasingly rely on rights-retention strategies — asserting a CC BY licence on the AAM ahead of acceptance — to avoid publisher pushback after the fact.

    Gold vs green: how APC reimbursement actually differs

    The financial and compliance trade-offs are distinct enough that they warrant a direct route-by-route comparison rather than treating “open access compliance” as one undifferentiated obligation.

    Factor Gold open access Green open access
    APC reimbursement Eligible for fully open access journals and platforms; must be budgeted in the grant Not applicable — no APC in most cases
    Hybrid-journal APCs Not eligible, unless covered by a recognised transformative agreement Not relevant — publish anywhere, then self-archive
    Embargo allowed Not applicable — immediate by definition None permitted under Horizon Europe
    Version deposited Final published version (Version of Record) Author’s Accepted Manuscript
    Licence required CC BY (CC BY-NC/ND permitted for monographs) CC BY on the deposited manuscript
    Zero-cost option Open Research Europe (no APC) Always zero-cost by design

    For grant budgeting, this comparison has one practical consequence: a grantee who assumes any APC is reimbursable, or that green deposit can wait for a standard embargo, will fall out of compliance. Horizon Europe’s no-embargo rule on green deposit is stricter than UKRI’s REF-era transitional allowances and than several national mandates still permitting embargoes — a distinction that trips up researchers moving from a previous funder’s rules onto a Horizon Europe grant.

    Common questions on Horizon Europe open access requirements

    What are the open access requirements for Horizon Europe?

    Horizon Europe requires all peer-reviewed scientific publications resulting from funded work to be made immediately open access, with no embargo, under a CC BY licence (or CC BY-NC/ND for monographs). This applies whether the grantee chooses the gold or green route, and a repository deposit is required in both cases.

    What is the European Commission’s open access policy under Horizon Europe?

    The Commission’s policy treats open access as the default expected outcome of publicly funded research, not an optional extra. It requires immediate access, open licensing, and open metadata, and extends beyond publications to FAIR research data underpinning them, governed by the grant’s Data Management Plan.

    Is open access always free for the author?

    No. Gold open access typically involves an APC, which Horizon Europe treats as an eligible grant cost only for fully open access venues. Green open access is generally free, since it relies on self-archiving rather than a publication fee, making it the lower-cost default where budget is constrained.

    What is an open access policy, in funder terms?

    An open access policy is a funder’s binding condition that research outputs be made freely accessible and reusable, typically specifying the timing (immediate vs embargoed), licence type, and eligible cost treatment. Horizon Europe’s version is among the strictest in Europe because it removes the embargo option entirely.

    What this means for grant budgeting and compliance teams

    Research offices preparing a Horizon Europe proposal should budget APCs only against fully open access venues or confirmed transformative agreements, and should not assume hybrid-journal costs will be reimbursed. Where budget certainty matters more than journal choice, green open access or Open Research Europe removes APC risk entirely while still meeting the immediate-access mandate.

    Compliance teams should build rights-retention language into author guidance before submission, not after acceptance, since the no-embargo rule leaves no room to negotiate access timing with a publisher post hoc. Institutional repository workflows that trigger deposit reminders at the point of acceptance — rather than publication — reduce the risk of missing the immediate-deposit requirement.

    As the European Commission continues to expand Open Research Europe’s remit and cOAlition S partners refine rights-retention model policies, the practical gap between the two routes is likely to narrow further on cost but remain wide on process — gold trades money for simplicity, green trades cost for rights-management discipline.