The NIHR open access policy requires that peer-reviewed research articles funded in whole or in part by the National Institute for Health and Care Research be made freely available immediately on publication, deposited in Europe PMC, and published under a CC BY licence. The policy took effect for articles submitted on or after 1 June 2022. NIHR has since reviewed the policy to confirm it remains fit for purpose across its portfolio, and the review process — not just the original mandate — is what research offices now need to track.
The NIHR open access policy is the set of rules issued by the National Institute for Health and Care Research requiring that research articles it funds be published with no access barrier and no embargo, on terms that permit free reuse. It sits alongside, but is not identical to, the UK Research and Innovation (UKRI) open access policy and the Wellcome open access policy — three UK funder mandates that are frequently confused with one another despite meaningful differences in scope, deposit routes and licensing flexibility.
- What does the NIHR open access policy actually require?
- What is the NIHR Open Access policy review?
- How does NIHR’s policy compare with UKRI and Wellcome?
- Gold or Green: which route applies to a given article?
- Common questions about the NIHR policy
- What this means for institutions and researchers
What does the NIHR open access policy actually require?
NIHR’s policy applies to peer-reviewed research articles — including unsolicited reviews and conference papers — funded wholly or partly through NIHR Programmes, Personal Awards, or Infrastructure. Monographs, book chapters and edited collections fall outside scope. For any in-scope article submitted on or after 1 June 2022, NIHR’s own compliance form confirms the article must be deposited in Europe PMC and made immediately, permanently available with no embargo period.
Three conditions apply together, not as alternatives:
- Immediate deposit. The version of record or the author’s accepted manuscript must appear in Europe PMC on the day of formal publication — there is no allowance for a delayed or embargoed release.
- CC BY licensing. Articles must carry a Creative Commons Attribution (CC BY) licence, permitting reuse and adaptation — including commercial reuse — provided the original authors are credited. A more restrictive CC BY-ND (no-derivatives) licence is permitted only with prior NIHR approval, and Crown Copyright outputs instead use the Open Government Licence.
- Data access statement. Every publication must state how the underlying research data can be accessed, or explain clearly why access is restricted (for example, patient confidentiality or commercial sensitivity).
Authors submitting to a subscription journal without a compliant route must also include a rights-retention statement in the funding acknowledgement and cover letter, asserting the right to deposit the accepted manuscript under CC BY regardless of the publisher’s standard licence terms.
What is the NIHR Open Access policy review?
Separately from the 2022 mandate itself, NIHR maintains an active Open Access policy review — a standing process to check the policy is “fit for the future” across the full breadth of NIHR’s research portfolio, which spans clinical trials, applied health research, infrastructure awards and early-career fellowships with very different publication norms. NIHR has stated that public feedback directly informed revisions to the published policy, indicating the review is a live governance mechanism rather than a one-off launch document.
For research offices, this distinction matters. A policy under active review can change scope, licensing exceptions, or compliance deadlines with comparatively short notice — unlike a funder mandate that has been static for several years. Institutions that treat the 2022 text as permanently fixed risk missing amendments that emerge from the review cycle.
How does NIHR’s policy compare with UKRI and Wellcome?
NIHR, UKRI and Wellcome each mandate immediate open access with a CC BY licence as the default, but they diverge on effective dates, scope and flexibility. This is the single most common point of confusion for multi-funder research offices.
| Funder | Effective date (journal articles) | Deposit location | Default licence | Notable flexibility |
|---|---|---|---|---|
| NIHR | 1 June 2022 (in-scope submissions) | Europe PMC | CC BY (CC BY-ND with approval) | Dedicated open access funding envelope for eligible awards; policy under ongoing review |
| UKRI | 1 April 2022 (journal articles); 1 January 2024 (monographs, book chapters, edited collections) | Europe PMC or an institutional/subject repository | CC BY (CC BY-ND permitted in limited cases) | Phased rollout separating journal articles from long-form outputs |
| Wellcome | 1 January 2021 | Europe PMC | CC BY (no CC BY-ND route) | No embargo tolerance; preprint deposit actively encouraged alongside the final article |
The practical effect: an NIHR- and UKRI-co-funded article must satisfy the earlier of the two applicable deadlines and the stricter of the two licensing conditions, while a Wellcome co-funded article has no CC BY-ND fallback at all. Research administrators managing co-funded grants should map compliance against the strictest funder in the mix, not the most familiar one.
Gold or Green: which route applies to a given article?
NIHR compliance runs through two established routes, mirroring the language UKRI and Wellcome also use.
- Gold route. Publish in a fully open access journal, or a hybrid journal covered by a transformative agreement. NIHR funds reasonable article processing charges (APCs) for eligible awards through a dedicated open access funding line.
- Green route. Publish in a subscription journal without a transformative agreement, and instead deposit the author’s accepted manuscript in Europe PMC under CC BY, supported by the rights-retention statement in the funding acknowledgement.
Both routes must still meet the no-embargo requirement — the green route in NIHR’s case does not permit the delayed deposit windows still found in some non-UK funder mandates.
Common questions about the NIHR policy
Does the NIHR open access policy require immediate deposit?
Yes. The NIHR open access policy requires the final article or accepted manuscript to be deposited in Europe PMC and made freely available on the day of publication, with no embargo period permitted under any compliance route.
What licence does NIHR require for funded research articles?
NIHR requires a CC BY licence by default, allowing free reuse and adaptation with attribution. A CC BY-ND licence is permitted only with prior NIHR approval, and Crown Copyright outputs instead carry the Open Government Licence.
Is the NIHR open access policy the same as UKRI’s?
No. Both require CC BY and Europe PMC deposit, but UKRI’s journal-article requirement took effect on 1 April 2022, two months before NIHR’s 1 June 2022 start date, and UKRI’s policy separately phases in monograph coverage from 2024.
Why is NIHR reviewing its open access policy?
NIHR states the review exists to keep the policy fit for the future across a portfolio that spans clinical trials, infrastructure and fellowship awards, and confirms that public feedback has already shaped revisions to the published text.
What this means for institutions and researchers
Research offices supporting multi-funder grants should build compliance checks around the strictest applicable deadline and licence condition, rather than defaulting to whichever funder’s policy staff know best. Because NIHR’s policy sits inside an active review cycle, institutional guidance pages should be dated and re-checked against NIHR’s own policy page at each funding cycle, rather than treated as a fixed reference. Authors submitting to subscription journals should confirm the rights-retention statement is included at submission, not added retrospectively, since post-hoc requests are harder for publishers to honour.
Looking ahead, the continued existence of a formal review mechanism signals that NIHR intends its open access requirements to keep pace with sector-wide developments — including alignment pressure from UKRI, cOAlition S signatories and Wellcome — rather than remain static. Institutions that monitor the review outputs alongside the base policy will be better placed to anticipate the next compliance change rather than react to it after a grant has already been awarded.
For related compliance context, see CASRAI’s research administration resources and the open-access terminology entries in the CASRAI Dictionary.