CASRAI Dictionary

Tag: ref 2029 open access policy

  • REF 2029 Output Eligibility: OA Exceptions

    REF 2029 output eligibility does not require every journal article or conference paper to be immediately open access. The policy allows four exception categories — deposit, access, technical, and a catch-all “other” route covering staff circumstances, third-party rights and technical infeasibility — each keeping an otherwise non-compliant output eligible, provided the exception is identified, evidenced and stays within a unit’s five per cent non-compliance tolerance.

    The REF 2029 open access policy is the UK funding bodies’ requirement that in-scope journal articles and conference proceedings, published between 1 January 2021 and 31 December 2028, be deposited, discoverable and freely accessible to be eligible for the Research Excellence Framework 2029, subject to defined exceptions.

    Durham University’s Library Research Support service publishes a working exceptions log — updated as recently as 1 July 2026 — that maps each permitted exception to the evidence a research office should hold, offering a practical template for institutions building their own REF 2029 compliance file.

    Contents

    What counts as an REF 2029 output eligibility exception?

    An REF 2029 output eligibility exception is a recognised circumstance under which an in-scope journal article or conference contribution is exempt from some or all open access criteria while remaining eligible for submission. The REF 2029 open access policy, last updated 13 June 2025, groups these into deposit, access and technical exceptions plus a further “other” exception for circumstances beyond an institution’s control.

    Applying an exception correctly means the output is treated as no-detriment and does not count against a unit’s compliance tolerance. Misapplying one, or failing to evidence it, risks the output being reclassified as unclassified during audit.

    Two separate exception frameworks apply depending on when the output was first published:

    • Outputs published 1 January 2021 to 31 December 2025 follow the carried-forward REF 2021 exception categories, with one additional exception added for REF 2029.
    • Outputs published from 1 January 2026 follow a revised, consolidated exceptions framework of four categories, alongside tighter embargo maxima (six months for Main Panels A and B, twelve months for Main Panels C and D, down from twelve and twenty-four months respectively).

    Individual staff circumstances: who qualifies for an exception?

    Staff-circumstance exceptions cover authors whose personal, employment or contractual situation made compliance genuinely impossible. Under the “other” exception, this includes extenuating personal circumstances such as extended leave, industrial action, institutional closure days, and software problems not already covered by the technical category.

    A related technical exception applies where an output has a substantive connection to the submitting institution but was published after the author’s employment ended, and compliance could not be determined. A further exception, introduced for REF 2029, exempts outputs authored entirely by staff ineligible for the volume measure, since they had no expectation of needing compliance.

    One risk is flagged explicitly: institutions relying heavily on the “other” category are more likely to attract a higher audit risk score, though deposit, access or technical exceptions do not themselves raise risk. A researcher on long-term sick leave whose manuscript could not be deposited within the three-month window would typically be recorded under “other”, with leave dates and repository correspondence kept as evidence — the record Durham’s log recommends holding before, not after, submission.

    Third-party rights and technical infeasibility: the other routes

    Third-party rights exceptions apply where an output reproduces content — images, data extracts, previously published material — for which open licences could not be obtained at reasonable cost or within the required timescale. Here, deposit and discovery requirements still apply; only access and/or licensing conditions are waived.

    Technical infeasibility exceptions cover cases where the failure sits with infrastructure rather than the author: a repository’s short-term technical failure (excluding systemic issues), or an external service provider failure, such as a subject repository that did not lift an embargo on schedule or ceased operating altogether.

    Exception category What it exempts Typical qualifying scenario
    Deposit All open access criteria (deposit, discovery, access, licensing) Unlawful to deposit; publisher disallows repository deposit; delay securing final peer-reviewed text
    Access Access, embargo and/or licensing only — deposit and discovery still required Embargo exceeds policy maxima; third-party content licensing unavailable
    Technical All open access criteria Repository or external service provider failure; employment ended before publication
    Other All open access criteria Personal circumstances, industrial action, closure days, unlisted software issues

    Durham’s exceptions log as a working model

    Durham University’s Library Research Support service maintains a dedicated REF 2029 Open Access Exceptions guide, structured as four tabs: deposit, access, and technical/other exceptions for outputs published to 31 December 2025, plus a consolidated four-category framework for outputs from 1 January 2026. Each tab pairs the qualifying scenarios with how the exception is expected to be evidenced during any future audit.

    Two features make it a useful model: it separates outputs by publication date, since qualifying criteria and embargo maxima genuinely differ either side of 1 January 2026; and it is candid about what remains unresolved. As of its 1 July 2026 update, Durham states that “the internal process for applying exceptions is yet to be confirmed,” directing queries to its repository administration team meanwhile — a reminder that internal workflows keep evolving well after the REF policy text has stabilised.

    Documenting exceptions for audit: what research offices must keep

    REF 2029 audit will broadly mirror the risk-based approach used for REF 2021, per the funding bodies’ guidance, while final procedures remain under development. In REF 2021, ten institutions’ submissions were selected for second-stage audit on a risk basis, producing four data adjustments; three were separately selected for substantive sampling; one had to adjust its submission by a single output. For REF 2029, evidence may be required at individual-output level, including written justification for any use of the “other” category.

    A minimum evidence file for each exception should include:

    1. The exception category claimed and the REF 2029 guidance paragraph it falls under.
    2. Dates of acceptance, publication and deposit, plus any embargo end date.
    3. Correspondence documenting the barrier — a publisher refusal, or confirmation of a service outage.
    4. A short narrative justification, particularly for “most appropriate publication” or “other” claims.
    5. Confirmation the output falls within the unit’s five per cent, or one-output, tolerance.

    Institutions should also monitor exception mix over time: a submission weighted heavily toward “other”, rather than deposit, access or technical exceptions, is more likely to draw a higher audit risk score, even where every claim is legitimate.

    Answer-first Q&A

    What is the publication period for REF 2029?

    The output types in scope of the REF 2029 open access policy are journal articles and conference contributions with an International Standard Serial Number, first published between 1 January 2021 and 31 December 2028. Outputs published from 1 January 2026 follow revised deposit, embargo and licensing requirements, while earlier outputs follow REF 2021-derived rules carried forward for REF 2029.

    What publications are eligible for REF 2029?

    Eligible outputs include journal articles and conference proceedings with an ISSN, plus long-form outputs such as monographs, book chapters and scholarly editions, which carry no open access requirement. Datasets, code, protocols and artistic creations are also welcomed, though they sit outside the open access policy’s scope entirely.

    What does the REF output rating measure?

    REF output quality is measured against three fundamental dimensions: originality, the development of new concepts or techniques; significance, the capacity to influence scholarly thought, policy or practice; and rigour, the intellectual coherence and robustness of the methodology. Open access exceptions affect eligibility, not the quality score itself, which panels assess independently.

    What this means for research offices ahead of REF 2029

    For research administration teams, exception management is now a compliance workstream in its own right, not an afterthought bolted onto repository deposit. With a five per cent (or one-output) tolerance per unit of assessment, a handful of poorly evidenced exceptions can tip a submission over the threshold and trigger removal of otherwise strong outputs. Institutions should build an exceptions log now, using Durham’s date-segmented structure as a template: separate outputs to 31 December 2025 from those from 1 January 2026, record the exception paragraph relied upon, and retain evidence when the exception first arises, not retrospectively. Given that REF 2021 audits produced adjustments even at confident institutions, a living exceptions file — not a retrospective justification exercise — separates a smooth submission from a last-minute scramble.

  • REF 2029 Open Access Policy: Deposit & Embargo Rules Explained

    The REF 2029 open access policy requires journal articles and conference proceedings with an ISSN, published from 1 January 2026 to 31 December 2028, to be deposited within three months of publication, made available after an embargo of no more than six months (Main Panels A and B) or twelve months (Main Panels C and D), and shared under a licence that is at minimum CC BY-NC-ND, with CC BY strongly preferred. Monographs and other long-form outputs remain outside its scope.

    The REF 2029 open access policy is the funding bodies’ mandatory framework, set out by the four UK higher education funding bodies for the Research Excellence Framework, governing how eligible journal articles and conference outputs must be deposited, embargoed and licensed to count toward a university’s REF 2029 submission.

    What does the REF 2029 open access policy cover?

    The policy applies only to journal articles and conference contributions carrying an International Standard Serial Number (ISSN), published between 1 January 2021 and 31 December 2028. Outputs published before 1 January 2026 remain subject to the legacy REF 2021 requirements, while everything published from 1 January 2026 onward must meet the revised, tighter rules.

    Two publication windows therefore run in parallel for REF 2029 purposes:

    • 1 January 2021 – 31 December 2025: REF 2021-era requirements apply (deposit within three months of acceptance; 12/24-month embargo caps).
    • 1 January 2026 – 31 December 2028: revised REF 2029 requirements apply (deposit within three months of publication; 6/12-month embargo caps; open-licence preference).

    Datasets, code, protocols, artistic outputs and preprints without an ISSN fall outside the policy entirely, though the funding bodies encourage — but do not require — making them open where practical.

    What is the deposit window for REF 2029 outputs?

    For outputs published from 1 January 2026, the author’s accepted manuscript (AAM) — or, where the publication agreement permits, the version of record — must be deposited in an institutional repository, a shared repository service, a subject repository, or a compliant preprint server within three months of the date of publication, not the date of acceptance as under REF 2021.

    This is a meaningful procedural shift: under the REF 2029 guidance hub’s Section 5 policy, the trigger date moves later in the workflow, which library teams need to build into repository-ingest reminders rather than acceptance-stage checklists alone. Institutions that already deposit on acceptance can keep doing so “at no detriment” — the three-month-post-publication rule is a floor, not a ceiling.

    What are the REF 2029 embargo caps by panel?

    For outputs published from 1 January 2026, permitted embargo periods are halved relative to REF 2021: Main Panels A and B (medicine, health, life sciences, physical sciences, engineering, mathematics) fall to a maximum six-month embargo, and Main Panels C and D (social sciences, arts and humanities) fall to a maximum twelve-month embargo. Interdisciplinary outputs spanning A/B and C/D boundaries may use the longer of the two applicable caps.

    Requirement Outputs published 2021–2025 (REF 2021 rules) Outputs published 2026–2028 (REF 2029 rules)
    Deposit trigger Within 3 months of acceptance Within 3 months of publication
    Embargo cap, Panels A & B 12 months 6 months
    Embargo cap, Panels C & D 24 months 12 months
    Licence floor CC BY-NC-ND or equivalent CC BY-NC-ND or equivalent (CC BY preferred)
    Non-compliance tolerance 5% of in-scope outputs, or 1 output, whichever is higher Same 5%/1-output tolerance carried forward

    Outputs still under a compliant embargo at the REF submission deadline are treated as policy-compliant, provided the embargo length itself sits within the applicable cap.

    What licence does REF 2029 require?

    The funding bodies do not mandate a single licence but state a strong preference for CC BY “or other licence formats meeting this standard of openness.” CC BY-NC, CC BY-ND and CC BY-NC-ND remain acceptable for outputs published between 1 January 2026 and 31 December 2028, provided the AAM deposit route otherwise meets deposit, discovery and access requirements.

    That flexibility is time-limited. Under the same guidance, from 1 January 2029, all future in-scope outputs must fully meet the open-licensing standard (effectively CC BY or equivalent), regardless of whether the output is published gold/diamond or shared via green deposit — subject only to the standard policy exceptions. Research offices planning publication strategy now should treat 2026–2028 as a transition window, not a permanent settlement.

    Why are monographs excluded from REF 2029 open access rules?

    REF 2029 carries no open access requirement for long-form outputs — monographs, book chapters and scholarly editions — because the funding bodies judged the monograph publishing ecosystem (specialist university presses, third-party image rights, translation licensing) not yet ready for a mandatory equivalent to the journal-article regime. The REF 2029 Open Access Policy and Consultation summary, published 11 December 2024, confirms that any long-form open access mandate is deferred to the assessment cycle after REF 2029, with implementation “no earlier than 1 January 2029.” Datasets, code and artistic research outputs are similarly welcomed but not mandated.

    Frequently asked questions

    What outputs are eligible for REF 2029 open access requirements?

    Only journal articles and conference contributions with an ISSN, published between 1 January 2021 and 31 December 2028, are in scope. Preprints without an ISSN, monographs, book chapters, datasets, code and artistic outputs fall outside the policy, though open sharing of the latter is encouraged rather than mandatory.

    What are the key changes for REF 2029 open access policy?

    The three headline changes from REF 2021 are a later deposit trigger (publication, not acceptance), shorter embargo caps (6/12 months instead of 12/24), and a stated preference for CC BY licensing during 2026–2028, tightening to a full open-licence requirement from 2029 onward.

    What is an open access policy in the REF context?

    An open access policy in this context is a funder-mandated condition of eligibility: outputs must be deposited, discoverable and free to read and download for anyone with internet access before they can count in a unit’s REF submission, independent of any journal paywall.

    How can institutions check whether an output meets REF open access requirements?

    Institutions cross-reference the deposit date, publication date, embargo length and licence recorded in their repository or current research information system (CRIS) against the applicable policy window, then apply the REF 2029 audit’s risk-based sampling approach — modelled on REF 2021, where ten institutions faced second-stage audit and four required data adjustments.

    What this means for research administrators

    Repository workflows built around REF 2021’s acceptance-date trigger need re-sequencing for the publication-date trigger from 1 January 2026, and embargo-tracking systems must be updated to the new 6/12-month caps to avoid outputs drifting into the 5%-tolerance band unintentionally. Because the REF 2021 audit found four institutions required data adjustments out of ten sampled at the second stage, and one required an output removed after substantive sampling, administrators should expect comparable scrutiny under REF 2029’s “broadly mirrored” risk-based audit approach, as set out in the REF 2029 guidance hub.

    The policy aligns deliberately with UKRI’s Open Access Policy for journal articles and conference proceedings, in force since 1 April 2022, and with the wider push for openness associated with cOAlition S — meaning institutions already compliant with UKRI grant conditions have much of the REF 2029 groundwork in place. For research administrators tracking related contributor and provenance standards, see CASRAI’s research administration resources and the open research dictionary for definitions of terms such as author accepted manuscript and green/gold open access.

    Outlook: the run-up to 2029

    Guidance for REF 2029 is not yet fully finalised: the guidance hub itself notes that modules “will be formally finalised in 2026” and may see small revisions before then, with the last substantive change to Section 5 recorded on 13 June 2025. Institutions should treat the current 6/12-month embargo caps and CC BY-NC-ND licence floor as the operative rules for 2026–2028 outputs while watching for the 2029 tightening to full open-licensing standards and the separate monograph mandate expected for the cycle beyond REF 2029.

  • UKRI Open Access Policy vs Plan S: Differences

    UKRI’s open access policy requires immediate, zero-embargo access under a CC BY licence for research articles submitted from 1 April 2022 — a stricter, funder-specific implementation of the open access principles set out by cOAlition S in Plan S. Where Plan S sets the international baseline (immediate OA, CC BY, no hybrid-journal funding), UKRI applies it without exception for articles but allows a 12-month embargo for monographs, while the separate REF 2029 assessment policy permits embargoes of up to 12 months and non-CC-BY licences. The three frameworks are related but not identical, and conflating them is the single most common compliance error among UK grant holders.

    UKRI (UK Research and Innovation) is the umbrella body for the UK’s seven research councils, Research England and Innovate UK. UKRI’s open access policy is the funder mandate attached to grant terms and conditions; Plan S is the set of ten principles published by cOAlition S, the international funder coalition UKRI helped found in 2018; and the REF 2029 open access policy is a separate requirement tied to the UK’s national research assessment exercise, not to grant funding at all. Understanding which framework governs a given output is the first step to compliance.

    What is the UKRI open access policy?

    The UKRI open access policy applies to peer-reviewed research articles, reviews and conference proceedings with an ISSN that acknowledge UKRI funding and were submitted for publication on or after 1 April 2022. It requires immediate open access with no embargo period, under a CC BY licence, via one of two routes.

    • Route 1 (Gold OA): the publisher makes the final Version of Record open access on the journal platform.
    • Route 2 (Green OA): the author deposits the Author’s Accepted Manuscript (AAM) in a repository, with no publisher embargo, under UKRI’s Rights Retention Strategy.

    A separate strand of the policy covers monographs, book chapters and edited collections, which applies to long-form works published from 1 January 2024. Unlike articles, long-form outputs may carry an embargo of up to 12 months, and UKRI provides a dedicated fund to cover book and chapter processing charges. UKRI’s own guidance, UKRI open access policy (published 6 August 2021), sets out the block-grant terms that fund Route 1 and Route 2 compliance for eligible research organisations.

    How does Plan S set the global baseline?

    Plan S is not a single funder’s policy but a coordinated commitment adopted by cOAlition S, the international group of funders — including UKRI, Wellcome and the European Commission’s Horizon Europe programme — that agreed to a shared open access baseline. cOAlition S announced Plan S in September 2018 and moved full implementation to 1 January 2021 after an initial consultation period.

    Plan S’s core requirements are that funded research articles be made immediately open access, that CC BY be the default licence, and that funders will not pay article processing charges (APCs) for publication in hybrid subscription journals unless the journal is covered by a recognised transformative agreement with a defined sunset date. UKRI’s article policy is, in effect, the UK national implementation of these ten principles — which is why the two frameworks track each other closely on articles but diverge once monographs, long-form outputs and national assessment exercises enter the picture.

    Where UKRI rules are stricter than Plan S

    On research articles, UKRI does not soften Plan S — if anything it tightens the funding mechanics. Plan S allows transitional arrangements more broadly during a coalition-wide transition period; UKRI has set explicit end dates for some of these routes.

    • Transformative journal funding ended earlier than the coalition-wide norm: per Jisc’s UKRI compliance guidance, research organisations could no longer use UKRI open access block grants to pay for publication in Jisc-approved transformative journals after 31 December 2024, even though the underlying journal remained policy-compliant.
    • A mandatory data access statement is required in every UKRI-funded article, regardless of whether underlying data exists or is accessible — a specific administrative requirement that Plan S’s high-level principles do not spell out.
    • Rights Retention Strategy is codified into submission workflow: UKRI requires a standardised statement in the manuscript submission confirming the CC BY licence will apply to the author’s accepted manuscript, operationalising Plan S’s rights-retention principle into a specific, auditable author action.

    Where UKRI is looser than the strict Plan S ideal is long-form publications: Plan S principles were written primarily with journal articles in mind, and UKRI’s 12-month embargo allowance and trade-book, training-grant and third-party-permissions exemptions for monographs are UKRI-specific accommodations rather than direct Plan S requirements.

    REF 2029 vs UKRI vs Plan S: comparing the three frameworks

    The framework UK grant holders most often confuse with UKRI’s funder policy is the separate REF 2029 open access policy, which governs eligibility for the Research Excellence Framework rather than grant compliance. The two policies apply to overlapping but distinct sets of outputs, on different timelines, with different tolerances for embargoes and licensing.

    Requirement Plan S (cOAlition S baseline) UKRI open access policy REF 2029 open access policy
    Governs International funder mandate UKRI grant terms and conditions UK research assessment eligibility
    Applies from 1 January 2021 (full implementation) 1 April 2022 (articles); 1 January 2024 (long-form) 1 January 2026 (revised policy, outputs to 31 December 2028)
    Embargo permitted None, for articles None for articles; up to 12 months for monographs Up to 6 months (Panels A and B); up to 12 months (Panels C and D)
    Licence CC BY default CC BY mandatory for articles CC BY preferred; CC BY-NC, CC BY-ND and CC BY-NC-ND also accepted
    Deposit route Gold or Green, rights retention Gold (Route 1) or Green (Route 2) with rights retention statement AAM deposit within 3 months of first publication
    Hybrid-journal APC funding Not funded outside transformative agreements Not funded after 31 December 2024 even for former transformative journals Not applicable — REF assesses accessibility, not funding route

    The practical consequence is that an article can satisfy REF 2029’s eligibility bar with a 6- or 12-month embargo and a non-CC-BY licence, yet still fail UKRI’s own funder policy, which recognises no embargo at all. A grant holder publishing UKRI-funded work must therefore treat the two as separate compliance checks, not a single hurdle.

    Common questions on UKRI’s open access policy

    What is the UKRI open access review?

    The UKRI open access review was UKRI’s stakeholder consultation process to replace the individually varying open access policies of its constituent research councils with a single, unified policy. It ran through extensive sector engagement and produced the current policy that took effect for articles on 1 April 2022.

    Do authors have to pay for open access?

    Not necessarily. UKRI provides open access block grants to eligible institutions to cover article processing charges for Route 1 (Gold) publication, and Route 2 (Green, self-archiving the accepted manuscript) carries no publication charge at all. Authors should check institutional block-grant eligibility before assuming a charge applies.

    What outputs are eligible for REF 2029?

    REF 2029’s open access policy applies specifically to journal articles and conference proceedings with an ISSN published within the eligible window. Monographs and other long-form outputs remain out of scope for the 2029 exercise and are expected to be brought into REF’s open access requirements no earlier than the assessment cycle that follows.

    What is the open access policy?

    An open access policy is a funder, institutional or assessment-body requirement that research outputs be made freely available online, typically under a specified licence and within a defined embargo limit. UKRI’s, Plan S’s and REF’s versions differ in scope, licensing tolerance and embargo length, which is why grant holders must check each one separately.

    For institutions and grant holders, the practical implication is that UKRI open access compliance, Plan S alignment and REF 2029 eligibility require three separate checks rather than one — a single embargo-free, CC BY article will clear all three, but any deviation (a 12-month embargo, a non-CC-BY licence, a hybrid journal outside a transformative agreement) can pass one framework while failing another. As REF 2029’s transitional period runs alongside UKRI’s steady-state policy, research offices should track compliance against each framework independently through at least the 2026–2028 output window.

  • REF 2029 Open Access Policy vs Plan S Rules

    The REF 2029 open access policy requires journal articles and conference proceedings with an ISSN, published from 1 January 2026, to be deposited within three months of publication, made available within a 6-month embargo (Main Panels A and B) or 12-month embargo (Main Panels C and D), and licensed at least as openly as CC BY-NC-ND. This is markedly more permissive than Plan S, which bans embargoes outright and pushes for CC BY as the default licence. The two frameworks share a direction of travel but diverge on timing and licensing mechanics — this walkthrough maps exactly where.

    The REF 2029 open access policy is the open-access eligibility requirement set out in Section 5 of the Research Excellence Framework 2029 guidance, published by the four UK higher education funding bodies and administered by Research England on behalf of UKRI. It determines whether a journal article or conference paper can be submitted for assessment at all — non-compliant outputs, absent an exception, are excluded from a unit’s submission.

    What is the REF 2029 open access policy?

    The REF 2029 open access policy sets the minimum conditions a journal article or conference contribution must meet to be eligible for submission to the UK’s Research Excellence Framework. It applies only to in-scope outputs with an ISSN published between 1 January 2021 and 31 December 2028; monographs, book chapters and other long-form outputs remain out of scope for this cycle. According to the REF 2029 guidance hub, the policy was originally published on 11 December 2024 and last updated 13 June 2025, following a formal consultation.

    Two different rule-sets apply depending on publication date. Outputs published from 1 January 2021 to 31 December 2025 are assessed against a carried-over version of the REF 2021 requirements. Outputs published from 1 January 2026 onward fall under the revised, tighter requirements described below — this is the version that matters most for anyone publishing now.

    How do the REF 2029 eligibility requirements work?

    For outputs published from 1 January 2026, compliance rests on four linked conditions: deposit, discovery, access and licensing. Each must be satisfied unless a specific exception applies.

    • Deposit: the Author Accepted Manuscript (AAM), or the Version of Record where the publication agreement permits, must be deposited in an institutional repository, subject repository or preprint server within three months of publication — a shift from REF 2021, where the clock started at acceptance rather than publication.
    • Embargo: publishers may impose a closed-access period of up to 6 months for Main Panels A and B, and 12 months for Main Panels C and D, down from 12 and 24 months respectively under REF 2021.
    • Access: once the embargo lapses, the output must be free to search, read and download by anyone with an internet connection.
    • Licensing: the funding bodies’ stated preference is CC BY, but CC BY-NC, CC BY-ND and CC BY-NC-ND (or an equivalent standard of openness) are also accepted for outputs published between 1 January 2026 and 31 December 2028.

    A tolerance allowance softens strict enforcement: per the REF 2029 guidance, a unit of assessment may submit up to 5% non-compliant in-scope outputs, or one non-compliant output, whichever is higher, at no detriment. Compliance is checked through a risk-based audit process modelled on REF 2021, where 10 institutions’ submissions were selected for second-stage audit and four data adjustments resulted.

    What does Plan S require on embargoes and licensing?

    Plan S is the open-access mandate launched in 2018 by cOAlition S, an international consortium of public and private research funders. Its ten core principles require that funded research be published immediately open access, with no permitted embargo period, and that outputs carry a CC BY licence by default — CC BY-SA or CC0 are tolerated in limited cases, but more restrictive terms such as CC BY-NC or CC BY-ND are not considered compliant.

    Plan S also expects rights retention: authors, not publishers, should hold sufficient rights to make the accepted manuscript openly available regardless of any subscription-journal embargo a publisher tries to impose. This rights-retention strategy is the mechanism several UK funders — including UKRI — have adopted to enforce zero-embargo compliance without banning subscription-journal publication outright.

    REF 2029 vs Plan S: where the rules line up and diverge

    Both frameworks push toward the same destination — free, immediate, reusable access to publicly funded research — but REF 2029 gets there on a longer, more accommodating timetable than Plan S.

    Requirement REF 2029 (outputs published 2026–2028) Plan S (cOAlition S)
    Embargo period Up to 6 months (Panels A/B); up to 12 months (Panels C/D) None permitted — immediate OA required
    Licence floor CC BY-NC-ND or equivalent minimum; CC BY preferred CC BY required by default; CC BY-SA/CC0 tolerated exceptions
    Deposit deadline Within 3 months of publication Immediate, at time of publication
    Scope Journal articles and conference papers with an ISSN only All peer-reviewed outputs from funded research
    Full-openness deadline 1 January 2029 (CC BY-equivalent minimum becomes mandatory for all in-scope outputs) Already in force
    Enforcement 5% tolerance band; risk-based audit Funder-level grant compliance checks

    The convergence date is the detail most summaries of REF 2029 leave out. From 1 January 2029, the funding bodies require all future in-scope outputs to meet the full open-licensing standard — effectively the CC BY-equivalent floor Plan S has enforced since 2021 — “subject to any permissible exceptions.” Until then, outputs deposited under a restrictive publisher agreement are explicitly excused from the licensing standard provided they still meet deposit, discovery and access conditions, with no exception form required. That two-tier transition, not a flat comparison of embargo months, is the real story of how REF 2029 is closing the gap with Plan S.

    Answer-first Q&A

    What outputs are eligible for REF 2029?

    Only journal articles and conference contributions with an ISSN, published between 1 January 2021 and 31 December 2028, fall inside the REF 2029 open access policy. Monographs, book chapters, datasets and preprints without an ISSN are welcomed as REF submissions but are not subject to this policy’s open access requirements.

    What are the key changes for REF 2029?

    From 1 January 2026, the funding bodies cut permitted embargo periods in half (6/12 months instead of 12/24), shifted the deposit trigger from acceptance to publication, and introduced explicit licensing minima (CC BY-NC-ND or equivalent) that did not exist under REF 2021 rules.

    What period does REF 2029 cover?

    The open access policy spans outputs published from 1 January 2021 to 31 December 2028, split into two rule sets: a REF-2021-style regime for 2021–2025 outputs, and the revised, stricter regime for outputs published from 2026 onward.

    What is an open access policy?

    An open access policy is a funder or assessment body’s formal requirement that research outputs be deposited, made discoverable and made free to read within defined conditions. Compliance is typically a precondition of funding eligibility or, as with REF 2029, of assessment eligibility itself.

    Implications for institutions and researchers

    For research administration teams, the practical shift is procedural as much as substantive: tracking date of publication rather than date of acceptance resets every deposit-deadline calculation library and repository teams have built around REF 2021. Institutions that already comply with UKRI’s Open Access Policy — in force for grant-funded outputs since 1 April 2022 — are well placed, since UKRI’s zero-embargo, CC BY-preferred terms already exceed the REF 2029 minimum.

    Publishers negotiating UK author agreements should note the AAM carve-out: outputs deposited under a restrictive publication agreement escape licensing penalties until 2029, reducing near-term pressure but setting a hard deadline. Anyone drafting institutional guidance should also consult the CASRAI dictionary of open-research terms for precise definitions of AAM, Gold, Green and embargo, since REF 2029, UKRI and Plan S each scope these terms differently.

    Looking ahead, the 1 January 2029 convergence date effectively puts REF on a collision course with Plan S’s zero-embargo, CC BY-default model — but only for licensing, not embargoes. Institutions with a five-year open access strategy should plan now for a licensing regime that will be materially stricter than anything REF has required to date, rather than treating 2026’s changes as the final word.

  • Wellcome Trust Open Access Policy vs Plan S and REF Requirements

    The Wellcome Trust open access policy requires immediate, embargo-free deposit of Wellcome-funded research articles in Europe PMC under a CC BY licence, restricts article-processing-charge funding to fully open-access venues from January 2025, and layers a separate data-sharing mandate on top of its OA rules — diverging in mechanics from both Plan S’s route-based minimum and REF 2029’s embargo-tolerant, lower-bar licensing floor.

    Wellcome is a UK-based biomedical research charity and a founding funder of cOAlition S, the international funder consortium that created Plan S in 2018.

    What does Wellcome’s open access policy require in 2026?

    Wellcome’s policy, in force since 1 January 2021 and tightened twice since, applies to all original research articles arising in whole or part from its funding. Three mechanics define it. First, the article must be deposited in Europe PMC and made freely available on the official publication date, with no embargo permitted. Second, authors must retain enough rights to apply a CC BY licence to the Author Accepted Manuscript — a mechanism known as rights retention — with CC BY-ND granted only by exception. Third, from 1 January 2025 Wellcome funds article-processing charges only in fully open-access journals or platforms; transitional funding for hybrid “read and publish” agreements ended in December 2024.

    A 16 January 2024 update added a fourth route: where neither the Version of Record nor the Accepted Manuscript can be made compliant, a CC BY-licensed preprint posted to a Europe PMC-indexed server before final publication now satisfies the policy. Scholarly monographs and book chapters submitted after 1 January 2021 fall under a related but separate Wellcome monograph policy, which permits a maximum six-month embargo — a materially different rule from the zero-embargo standard applied to journal articles.

    How Wellcome aligns with — and adds to — Plan S

    Wellcome has been a cOAlition S founding member since 2018, and its journal-article rules track Plan S’s core requirements closely: immediate access, a CC BY default, and no embargo. Both frameworks recognise the same three compliance routes — publishing in a fully open-access venue, self-archiving via rights retention in a repository, or publishing through a transformative agreement — and both use the shared Journal Checker Tool to let authors verify a venue in advance.

    Wellcome goes beyond the Plan S baseline in enforcement and scope. Plan S sets principles each signatory funder operationalises independently; Wellcome adds funder-specific detail Plan S does not itself mandate — the 2024 preprint route, a ban on OA block-grant funds paying hybrid APCs, and named sanctions (loss of lead-applicant eligibility, suspended grant payments) for non-compliance. Plan S does not prescribe monograph rules; Wellcome does, via its separate six-month-embargo monograph policy.

    Where Wellcome diverges from REF 2029’s open access rules

    REF 2029 — the UK’s national research assessment exercise, run by Research England and the other UK funding bodies — is not a Plan S signatory framework, and its open access requirements are structurally looser than Wellcome’s. Under the REF 2029 policy for outputs published between 1 January 2026 and 31 December 2028, journal articles and conference proceedings must be deposited within three months of publication, but embargoes are still permitted: up to six months for Main Panels A and B, and up to twelve months for Main Panels C and D. That is a reduction from REF 2021’s 12- and 24-month allowances, but it is not the zero-embargo standard Wellcome and Plan S apply.

    REF 2029’s licensing floor is also lower. While CC BY is the funding bodies’ stated preference, a CC BY-NC-ND licence — Non-Commercial, No Derivatives — meets the minimum requirement, versus Wellcome’s CC BY default with only narrow CC BY-ND exceptions. REF 2029 additionally excludes monographs, book chapters and scholarly editions from its open access scope entirely, whereas Wellcome applies its own (separate) embargo rule to those output types. The table below summarises the divergence.

    Requirement Wellcome (2026) Plan S / cOAlition S REF 2029
    Embargo (journal articles) None None 6 months (Panels A/B); 12 months (Panels C/D)
    Default licence CC BY (CC BY-ND by exception) CC BY CC BY preferred; CC BY-NC-ND meets minimum
    APC funding scope Fully OA venues only (from Jan 2025) Route-dependent, funder-operationalised Not an APC-funding body
    Compliance route Europe PMC deposit, rights retention, or CC BY preprint Gold OA, rights retention, or transformative agreement Repository deposit (green route) within 3 months of publication
    Monographs/book chapters In scope; max 6-month embargo Not prescribed by Plan S itself Out of scope for REF 2029
    Data sharing mandate Separate DMSP requirement Not part of core Plan S text Not part of REF open access policy

    Data sharing and rights retention: Wellcome’s additional layer

    Neither Plan S nor REF 2029 mandates data sharing as a condition of open access compliance; Wellcome does, through a policy that operates alongside — not inside — its OA rules. Wellcome’s Data, Software and Materials Management and Sharing Policy, updated 1 August 2024, requires funded researchers to submit an outputs management plan and to maximise access to research data with as few restrictions as possible. For research relating to public health emergencies, the policy requires quality-assured interim and final data to be shared as rapidly and as widely as possible, ahead of formal publication.

    • A Data Management and Sharing Plan (DMSP) is typically required at the application or award stage, not deferred to end-of-grant reporting.
    • The rights-retention statement authors must insert into subscription and hybrid-journal submissions is a Wellcome-specific compliance artefact — it is not required in the same form under REF 2029’s repository-deposit route.
    • Non-compliance with either the open access or the data-sharing policy can trigger the same sanction: ineligibility to apply as lead applicant on future Wellcome grants.

    This is the funder-specific compliance gap institutions most often miss: a paper can satisfy REF 2029’s repository-deposit rule and still fail Wellcome’s audit if the underlying dataset was not made accessible under the separate data policy.

    Frequently asked questions

    Does Wellcome allow any embargo on open access articles?

    No. Wellcome’s open access policy requires immediate deposit in Europe PMC with no embargo for original research articles. This is stricter than REF 2029, which permits six- or twelve-month embargoes depending on the assessment panel, and applies only to journal articles and conference proceedings, not to monographs.

    Is Wellcome Trust a Plan S funder?

    Yes. Wellcome has been a founding member of cOAlition S since 2018 and its 2021 policy was designed to align with Plan S principles. However, Wellcome operationalises those principles through its own mechanics — including a 2024 preprint-compliance route and named non-compliance sanctions — that Plan S itself does not mandate.

    Do REF 2029 open access rules apply to monographs?

    No. REF 2029’s open access policy covers only journal articles and conference proceedings with an ISSN; monographs, book chapters and scholarly editions are excluded from the current cycle, though UK funding bodies have signalled monograph requirements from the following REF exercise.

    Will Wellcome pay for open access publication in a hybrid journal?

    Not from January 2025 onward. Wellcome’s OA block grant now funds article-processing charges only in fully open-access journals or platforms; the transitional funding for hybrid “read and publish” agreements ended in December 2024.

    Implications for institutions and researchers

    Research administration teams managing multi-funder portfolios cannot apply one embargo or licensing rule across Wellcome, Plan S-aligned funders and REF 2029 — the three frameworks set genuinely different floors. A paper compliant with REF 2029’s CC BY-NC-ND minimum via green deposit can still breach Wellcome’s zero-embargo, CC BY-default rule if Wellcome funding is also acknowledged. Institutions need compliance checklists that track funder-specific mechanics, not a generic “open access” requirement, and should route Wellcome-funded outputs through the Journal Checker Tool before submission rather than after acceptance.

    The direction of travel across all three frameworks is convergence on stricter terms: REF’s embargo ceilings have already fallen once, UK funding bodies have flagged monograph open access for the exercise after REF 2029, and Wellcome’s data-sharing layer signals that funders increasingly treat open access and open data as linked obligations, not separate ones. Compliance processes built around funder-specific detail, not the lowest common denominator, will hold up best as these policies keep tightening.

  • MRC and BBSRC Open Access Policy: How UKRI’s Research Councils Diverge

    Grant administrators handling awards that straddle more than one UK Research and Innovation (UKRI) council quickly discover that “one policy” does not mean “one set of instructions.” The MRC open access policy and the Biotechnology and Biological Sciences Research Council (BBSRC) open access policy both sit inside UKRI’s single overarching open access framework, yet the Medical Research Council (MRC) and BBSRC apply distinct additional expectations around Europe PMC deposit, embargo language and preprint citation. For institutions administering multi-council grants, those gaps — not the shared UKRI baseline — are where compliance actually breaks down.

    The shared UKRI foundation

    Since 1 April 2022, UKRI has run a single open access policy covering peer-reviewed research articles, conference papers and reviews acknowledging funding from any of its seven councils, including MRC and BBSRC. From 1 January 2024 the policy extended to monographs, book chapters and edited collections, requiring open access within 12 months of publication.

    For journal articles, the UKRI policy sets out two routes to compliance:

    • Route 1 (Gold): the publisher’s version of record is made immediately open access, typically under a CC BY licence.
    • Route 2 (Green): the author’s accepted manuscript is deposited in a repository and made immediately available at the point of publication.

    Both MRC and BBSRC researchers must comply with this baseline. The divergence begins with what each council layers on top of it.

    How MRC and BBSRC diverge in practice

    MRC’s own policy page states plainly that funded researchers are “expected to comply” with the UKRI policy and must ensure a copy of every in-scope publication is deposited in Europe PubMed Central (Europe PMC) at the time of final publication — a requirement MRC treats as mandatory, with a named contact ([email protected]) for compliance queries.

    BBSRC’s published guidance, by contrast, frames Europe PMC archiving as something researchers are “strongly encouraged” to do rather than an enforced condition, and separately states that BBSRC-funded results must be made freely available “no later than six months from the formal date of publication” — language that sits alongside, rather than fully aligned with, UKRI’s 2022 immediate-access requirement. In practice this means MRC administrators treat Europe PMC deposit as a hard compliance gate, while BBSRC administrators are working from softer, less current wording.

    Requirement MRC BBSRC
    Base policy UKRI open access policy UKRI open access policy
    Europe PMC deposit Required, tied to funding terms and conditions Strongly encouraged, not stated as mandatory
    Stated access timeline Immediate, per UKRI policy Guidance still references a 6-month freely-available window
    Preprints in applications Accepted, subject to MRC preprints policy Accepted; must carry a DOI and be under 5 years old
    Block grant / OA funding route UKRI block grant plus institutional strategic funding UKRI block grant plus a dedicated BBSRC Open Access Grant for strategically funded institutes

    The block grant distinction matters for multi-council awards: a BBSRC-funded institute receiving strategic funding is eligible for a separate BBSRC Open Access Grant on top of the standard UKRI block grant allocation, whereas MRC funding does not carry an equivalent parallel grant line. Administrators reconciling publication costs across a joint MRC–BBSRC award therefore need to identify which funding pot a given article’s costs should be drawn from, rather than assuming a single shared allocation.

    Common questions from grant administrators

    What is the MRC open access policy?

    The MRC open access policy requires researchers funded by the Medical Research Council to comply with the overarching UKRI open access policy and to deposit a copy of every in-scope publication in Europe PMC at the time of final publication, whether via the gold or green route.

    Does BBSRC require Europe PMC deposit?

    BBSRC’s guidance encourages researchers to archive published articles in Europe PMC but does not state this as a mandatory condition in the way MRC does, making it a softer compliance expectation that administrators should still track for biomedical-adjacent outputs.

    What is the difference between MRC and BBSRC open access requirements?

    Both follow the same UKRI baseline, but MRC treats Europe PMC deposit as compulsory while BBSRC treats it as encouraged, and BBSRC’s own guidance still references a six-month access window that predates UKRI’s 2022 immediate-access requirement.

    Will REF 2029 use the same open access policy as UKRI?

    The UK’s four higher education funding bodies have signalled that REF 2029 open access requirements will move closer to the UKRI framework, including extending expectations to long-form outputs, but REF policy is set separately from UKRI’s council-level rules and administrators should not assume identical scope or timing.

    REF 2029 open access alignment

    The Research Excellence Framework is administered by the four UK higher education funding bodies — Research England, the Scottish Funding Council, the Higher Education Funding Council for Wales and the Department for the Economy in Northern Ireland — not by UKRI’s research councils directly. For REF 2021, the open access policy applied to journal articles and conference proceedings, with a deposit window measured from acceptance rather than publication.

    For REF 2029, the funding bodies have indicated closer alignment with UKRI’s current policy, including bringing long-form outputs such as monographs into scope in a manner consistent with UKRI’s January 2024 monograph requirement. For a multi-council award spanning MRC and BBSRC funding, this means outputs already compliant with the UKRI open access route are well placed for REF eligibility, but administrators should confirm the specific REF 2029 rules once published rather than relying on UKRI compliance as an automatic proxy.

    Implications for multi-council award administrators

    The practical risk on a joint MRC–BBSRC grant is not non-compliance with the UKRI baseline — most institutions have that workflow embedded — but under-tracking the council-specific layer on top of it. Three things follow from the comparison above:

    1. Treat Europe PMC deposit as mandatory for any output acknowledging MRC funding, and as strongly recommended (verify locally) for BBSRC-only outputs.
    2. Do not assume a single open access funding pot covers a joint award; check whether the receiving institute holds a BBSRC Open Access Grant in addition to its UKRI block grant.
    3. Flag REF 2029 scope changes as a live item rather than a fixed rule, since final funding-body guidance may extend beyond the current UKRI monograph policy.

    Institutions supporting research administration across multiple UKRI councils benefit from building compliance checklists that separate “UKRI-wide” requirements from “council-specific” additions, rather than treating open access as a single monolithic policy. As REF 2029 guidance solidifies and UKRI continues its open access policy review, the gap between MRC’s stricter Europe PMC language and BBSRC’s older embargo wording is the clearest signal that “UKRI open access policy” is a floor, not a uniform standard — and that administrators verifying terminology such as gold, green and embargo routes should consult a maintained research administration dictionary alongside each council’s primary source.