CASRAI Dictionary

Tag: rights retention strategy

  • 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.

  • Plan S Wikipedia vs cOAlition S: What Changed

    Plan S is an initiative for open-access science publishing, launched in September 2018 by cOAlition S, a consortium of research funders. Wikipedia’s article on Plan S is broadly accurate on the initiative’s origins and ten principles, but its most-cited figures on transformative agreements, rights-retention uptake, and coalition membership are frozen between 2021 and 2023 — and the article makes no mention of cOAlition S’s own Strategy for 2026-2030, published in November 2025.

    Plan S is the requirement, backed by cOAlition S funders, that peer-reviewed research they fund be made immediately and freely available in a compliant open-access journal, platform, or repository, without embargo, under an open licence.

    What does Wikipedia say about Plan S?

    Wikipedia’s “Plan S” article opens by describing the initiative as a consortium of national research agencies and funders from twelve European countries, requiring that publicly funded research be published in open repositories or fully open-access journals by 2021. It correctly identifies cOAlition S as the coordinating body and lists the ten founding principles set out in the original implementation guidance.

    The article also notes real, later developments: the extension of the compliance deadline from 2020 to 2021, the Rights Retention Strategy, an October 2023 proposal to explore publishing models without author-facing fees (“diamond” open access), and a 2024 Gates Foundation policy shift described as not fully aligned with Plan S. This shows the page is edited, not abandoned — but the edits are sparse and several core figures have not been touched in years.

    Where the Wikipedia article holds up

    Several elements of Wikipedia’s account remain a fair summary of Plan S as it was designed. The ten principles — author copyright retention, standardised and capped publication fees, funder-level monitoring of compliance, and the explicit statement that hybrid open-access journals do not satisfy the key principle — match the original guidance released by the Science Europe-coordinated task force on 27 November 2018.

    The licensing detail is also accurate: compliant articles must carry a CC BY 4.0 licence, or alternatively CC BY-SA 4.0 or CC0, and journals must meet baseline peer-review standards consistent with guidance from the Committee on Publication Ethics (COPE) and listing in the Directory of Open Access Journals (DOAJ). None of this has changed, and Wikipedia states it correctly.

    Where the record is stale

    The gaps are concentrated in exactly the areas that move fastest: funding mechanics, uptake statistics, and coalition scope. The table below sets Wikipedia’s wording against cOAlition S’s own published record.

    Wikipedia’s claim Current cOAlition S position Source
    Transformative agreement contracts “may not last beyond 2023” cOAlition S confirmed in January 2023 that member funding for transformative arrangements would continue but cease entirely on 31 December 2024, with no new agreements accepted after 30 June 2023 cOAlition S, “cOAlition S confirms the end of its financial support for Open Access publishing under transformative arrangements after 2024”
    Rights Retention Strategy uptake given “as of October 2021 … over 500 works” No comparable running total has been added since; the Strategy remains active guidance with no current uptake figure cited on the page cOAlition S Rights Retention Strategy guidance (ongoing)
    Lede describes cOAlition S as funders “from twelve European countries” Membership and policy alignment now extends beyond that founding European core, as the article’s own later reference to the Gates Foundation’s 2024 policy shift illustrates cOAlition S member list; Wikipedia “Plan S” article, “Policy changes by member organizations” section
    No mention of a forward strategy beyond 2023-24 developments cOAlition S published its Strategy for 2026-2030 in November 2025, setting three strategic priorities across two implementation phases cOAlition S, “cOAlition S Strategy for 2026-2030”

    None of this makes the Wikipedia article wrong about what Plan S was. It makes the article an increasingly incomplete guide to what Plan S is now — a distinction that matters for anyone citing it in a policy brief, grant compliance note, or institutional guidance document.

    What cOAlition S’s 2026-2030 strategy adds

    cOAlition S’s Strategy for 2026-2030, published in November 2025, is the most authoritative recent statement of where the coalition is heading, and it is entirely absent from Wikipedia’s coverage. The strategy sets three strategic priorities: reinforcing the foundations for full, immediate, and equitable open access to peer-reviewed articles; supporting the digital infrastructure that underpins open access; and exploring financially sustainable and equitable publishing models while tracking their outcomes.

    Implementation runs in two phases. Phase one (2026-2027) concentrates on foundational work, digital infrastructure, and member services. Phase two (2028-2030) is intended to deepen work on sustainability and equity, subject to review of phase-one outcomes by the Leaders Group. This phased structure directly supersedes the transitional, 2018-2023 “transformative agreement” framing that still anchors Wikipedia’s implementation section.

    • Three strategic priorities replace the earlier single-minded focus on the 2021 compliance deadline.
    • A defined two-phase timetable (2026-2027, then 2028-2030) gives institutions a planning horizon Wikipedia’s article does not mention.
    • Financial support for transformative arrangements ended on 31 December 2024, closing a funding route Wikipedia still frames as open until “2023”.

    Common questions

    What is Plan S in open access?

    Plan S requires that peer-reviewed publications resulting from research funded by cOAlition S members be made immediately open access on publication, with no embargo, under an open licence such as CC BY 4.0. Authors must retain copyright. The requirement applied to grants awarded from 1 January 2021 onward.

    What are the five pillars of Wikipedia?

    Wikipedia operates on five pillars: it functions as an encyclopedia, is written from a neutral point of view, offers free content anyone can use or edit, expects civility among editors, and has no firm rules. Those norms explain why fast-moving funder guidance, like Plan S’s, can lag behind primary sources between volunteer edits.

    What this means for institutions and publishers

    Research administrators, library staff, and publishers who cite Wikipedia’s Plan S article as a compliance reference should treat it as a starting point, not a current-state document. Anyone advising on plan s open access obligations should verify funding-route and deadline details directly against cOAlition S’s guidance pages before applying them to a grant, agreement, or institutional policy — particularly anything touching transformative agreements, which stopped receiving cOAlition S funding at the end of 2024, not 2023.

    This pattern is not unique to Plan S. Fast-moving standards and funder mandates routinely outrun general-reference encyclopedia coverage, which depends on volunteer editors noticing and sourcing each change. The practical fix is straightforward: use Wikipedia to orient, then confirm operative dates, funding rules, and current strategic priorities against the originating body’s own published guidance.

    For related standards and terminology used across research administration, see CASRAI’s open research dictionary and the research administration pillar.

  • 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.

  • 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.

  • cOAlition S Members in 2026: Which Funders Still Mandate Immediate Open Access

    cOAlition S is a coalition of 28 national research funders, charitable foundations, and international agencies that endorse Plan S, the requirement that publications from funded research be made openly accessible without embargo. Not every one of those coalition s members still enforces that requirement in the same way. Some, like UK Research and Innovation (UKRI) and Wellcome Trust, still apply the Rights Retention Strategy to force immediate access regardless of publisher policy. Others — most visibly the Bill & Melinda Gates Foundation — have adopted 2024-era policies that no longer mandate an openly accessible accepted manuscript, and the coalition itself formally broadened its accepted routes to compliance under its 2026-2030 strategy, published 12 November 2025.

    cOAlition S is an informal alliance of research funders and research-performing organisations, launched in September 2018, that coordinates funding conditions requiring full and immediate open access to the peer-reviewed publications it supports. This article gives the current 2026 roster, distinguishes funders that still hold a full immediate-OA mandate from those that have relaxed enforcement, and explains what changed under the coalition’s newest strategic phase.

    Contents

    Who are the current cOAlition S members?

    cOAlition S began in 2018 with twelve founding organisations. According to the coalition’s own Strategy 2026-2030 document, that founding group “has developed into a robust network of 28 funders, encompassing agencies from Europe, North America, Jordan, Zambia, South Africa, and Australia.” The European Research Council (ERC) engaged at launch but formally withdrew support in July 2020.

    Founding and long-standing members include UKRI and Wellcome Trust (UK), the Austrian Science Fund (FWF), France’s Agence Nationale de la Recherche (ANR), the Dutch Research Council (NWO), the Swiss National Science Foundation (SNSF), Science Foundation Ireland, Luxembourg’s Fonds National de la Recherche (FNR), Poland’s National Science Centre (NCN), Portugal’s Fundação para a Ciência e a Tecnologia (FCT), the Research Council of Norway, Australia’s National Health and Medical Research Council, the South African Medical Research Council, Jordan’s Higher Council for Science and Technology, Zambia’s National Science and Technology Council, and US philanthropic funders including the Gates Foundation, Howard Hughes Medical Institute, and Templeton World Charity Foundation.

    Which funders still hold a full immediate open-access mandate?

    A small group of cOAlition S members still enforces the original, strict version of Plan S: immediate open access with no embargo, secured through the Rights Retention Strategy, which requires grantees to apply a CC BY licence to the author accepted manuscript regardless of what the publisher’s own copyright policy says.

    • UKRI requires a CC BY-licensed accepted manuscript deposited with no embargo (or a compliant gold route), enforced through its funding assurance processes.
    • Wellcome Trust applies its own Rights Retention Statement, requiring immediate open access on acceptance.
    • National European funders such as FWF, ANR, NWO, and SNSF have kept their domestic OA policies aligned with the coalition’s founding principles.

    The coalition’s commissioned review, Galvanising the open access community: A study on the impact of Plan S (2024), credits the Rights Retention Strategy as the mechanism with the most “game-changing effect,” since institutions have since adopted it independently, beyond the original funder mandate.

    Which members have relaxed enforcement?

    The clearest case of a member funder relaxing its own mandate is the Gates Foundation. In 2024 it announced a “preprint-centric” open access policy and confirmed it would stop paying article processing charges (APCs). Per Wikipedia’s sourced summary of the change, this policy is “not entirely in line with cOAlition S,” because it no longer requires that an accepted manuscript itself be made openly accessible — it instead relies on preprint deposit, which is a materially weaker guarantee than the coalition’s founding immediate-OA principle.

    Two organisations exited or declined the coalition outright rather than relaxing in place:

    • Riksbankens Jubileumsfond (Sweden) was a member in 2018 but left in 2019 over concerns about Plan S’s implementation timeline.
    • India publicly declined to join cOAlition S in October 2019, despite earlier supportive signals from its Department of Biotechnology.
    • The European Research Council withdrew its formal backing in July 2020, even though the European Commission remains engaged with the coalition’s wider work.

    Separately, cOAlition S confirmed in 2024 that it would end financial support for “transformative agreements” altogether, removing 1,589 of 2,326 journals (68%) from its transformative journals scheme in 2023. That decision tightened one enforcement lever even as the coalition’s broader 2026-2030 strategy loosened others — illustrating that “enforcement” at cOAlition S is not moving in a single direction.

    Funder-by-funder status at a glance

    Funder 2026 status Basis
    UKRI (United Kingdom) Full mandate, active Rights Retention Strategy; no-embargo CC BY requirement
    Wellcome Trust (United Kingdom) Full mandate, active Own Rights Retention Statement
    FWF, ANR, NWO, SNSF (Austria, France, Netherlands, Switzerland) Full mandate, active Domestic OA policy aligned to founding principles
    Gates Foundation (United States) Relaxed in 2024 Preprint-centric policy; APCs no longer funded; accepted manuscript OA not required
    Riksbankens Jubileumsfond (Sweden) Departed 2019 Left over Plan S implementation timeline
    European Research Council Withdrew support, 2020 Formal withdrawal in July 2020
    India (Department of Biotechnology) Never joined Declined membership, October 2019

    What changed under the 2026-2030 strategy?

    cOAlition S published its Strategy 2026-2030 on 12 November 2025, organised around three priorities: strengthening the foundations for “full, immediate, sustainable, and equitable” open access; supporting shared digital infrastructure (including a joint position on AI training uses of CC BY content); and exploring financially sustainable publishing models.

    Chemistry World’s reporting on the strategy quotes Lidia Borrell-Damián, chair of the coalition’s executive steering group and secretary general of Science Europe, describing a shift toward embracing “a range of open access models” — including publish-review-curate (PRC), diamond open access, and preprints — rather than insisting on one route. Researcher commentary quoted in the same piece characterised this as the coalition “scaling back its ambitions” from the original single 2021 target of full immediate Gold/Green access. Per the International Association of Scientific, Technical & Medical Publishers (STM) OA Dashboard, cited in that coverage, the global share of articles published immediately open access (gold) rose from 14% in 2014 to 40% in 2024, while subscription-only publication fell from 70% to 54% over the same decade.

    The coalition also changed its own governance in this period. In December 2025 it issued a tender for a new host secretariat, backed by an annual budget of roughly €0.8 million, after the European Science Foundation’s hosting arrangement wound down. Curt Rice — previously rector of two Norwegian universities — was appointed cOAlition S’s new director in May 2026, with Operas confirmed as the new host secretariat managing the coalition’s funds and communications.

    What does this mean for institutions and researchers?

    Research administrators advising authors funded by a cOAlition S member should not assume uniform enforcement across the roster. UKRI- and Wellcome-funded authors still face a hard Rights Retention requirement with no embargo tolerance. Gates Foundation-funded authors now face a materially different, preprint-centric expectation. The coalition’s collective policy language has shifted from “full and immediate” as the only route toward a “multitude of routes to open access” — compliance officers should check each funder’s own published policy rather than treating the cOAlition S label as a proxy for one uniform rule.

    For research administration teams tracking funder compliance, and for anyone verifying open access terminology in the CASRAI dictionary, the practical takeaway is that “cOAlition S member” is now a looser designation of shared principle rather than a guarantee of identical mandate terms.

    Answer-first Q&A

    What is cOAlition S?

    cOAlition S is an alliance of national research funders, charitable foundations, and international agencies, launched in September 2018, that coordinates Plan S — the requirement that publications from the research they fund be made openly accessible without embargo, typically via the Rights Retention Strategy.

    How many funders are in cOAlition S in 2026?

    cOAlition S counts 28 member funders as of its 2026-2030 strategy, spanning Europe, North America, Jordan, Zambia, South Africa, and Australia, up from the twelve founding organisations that launched Plan S in 2018.

    Have any funders left cOAlition S?

    Yes. Riksbankens Jubileumsfond left in 2019 over Plan S’s timeline, India declined to join in 2019, and the European Research Council withdrew formal support in July 2020, though the European Commission remains engaged.

    Is Plan S still mandatory for cOAlition S members in 2026?

    Core members such as UKRI and Wellcome Trust still enforce immediate open access with no embargo, but the coalition’s 2026-2030 strategy formally recognises additional routes — preprints, diamond open access, and publish-review-curate models — alongside the original mandate, rather than treating “full and immediate” as the only compliant route.

    Looking ahead

    With Curt Rice now leading the coalition and Operas installed as host secretariat, cOAlition S enters 2026-2027 — the first phase of its new strategy — with a wider tent of acceptable open access routes than it had in 2018. The roster of 28 funders remains largely intact, but “cOAlition S member” increasingly describes a shared aspiration rather than one uniform compliance rule. Institutions should track each funder’s own published policy directly rather than inferring mandate strength from coalition membership alone.

  • 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.

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

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

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

    What is green open access under Plan S?

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

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

    What are the zero-embargo deposit rules?

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

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

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

    Which repositories qualify?

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

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

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

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

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

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

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

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

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

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

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

    Frequently asked questions

    What does green open access mean?

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

    What is the difference between gold and green open access?

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

    Is green open access free?

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

    What is Plan S in open access?

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

    What this means for research offices

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

    Outlook

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

  • 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.

  • Is Plan S Open Access Working? A Sceptic’s Case for Differentiated Mandates

    Five years on from its 1 January 2021 compliance deadline, Plan S open access policy sits in an odd position: widely credited with putting open access on every funder’s agenda, yet quietly walked back by the very coalition that wrote it. An independent October 2024 review, Galvanising the Open Access Community: A Study on the Impact of Plan S, found the policy had a “game-changing” effect through its Rights Retention Strategy. But cOAlition S’s own 2026–2030 strategic plan tells a second story — one of phased retreat from the rigid, one-size-fits-all mandate it launched in 2018. That gap between celebratory retrospective and quiet course-correction is the real story, and it is worth asking plainly whether a blanket mandate was ever the right instrument.

    What Plan S Actually Requires

    Plan S was launched in September 2018 by cOAlition S, an international consortium of national research funders and charitable foundations that includes UKRI and the Wellcome Trust. Its ten founding principles required that, from 2021, all peer-reviewed publications resulting from funding by coalition members be made immediately open access — either in a fully open access journal or platform, or via deposit in an open repository with no embargo.

    Two mechanisms did the heavy lifting:

    • The Rights Retention Strategy (RRS), which lets funded authors apply a CC BY licence to their author-accepted manuscript regardless of the publisher’s own policy, enabling immediate green open access.
    • Article processing charges (APCs), the fee-based gold open access route, which cOAlition S initially agreed to fund on authors’ behalf where a compliant venue existed.

    Notably, the original ten principles were scoped to peer-reviewed journal articles and conference proceedings. cOAlition S explicitly deferred a firm mandate for monographs and book chapters, citing the different funding cycles, peer-review norms, and licensing conventions of humanities and social-science (HSS) publishing — an early acknowledgement that a single rulebook does not fit every discipline.

    The Case Against the Blanket Mandate

    The criticisms of Plan S are not new, but they have hardened rather than faded. Three stand out.

    Cost-shifting to APCs. By pushing gold open access as the default compliant route, Plan S moved the cost of publishing from reader-side subscriptions to author-side fees. Well-resourced institutions and grant-rich disciplines absorb this easily; early-career researchers, unfunded scholars, and institutions in lower-income countries do not. Critics — including Science (AAAS), in its 2024 “mixed review” of the policy — have argued this risks a pay-to-publish stratification that Plan S was meant to dismantle, not recreate.

    Disciplinary disparities. STEM fields, with large grant budgets and a journal-article-centred publishing culture, adapted to Plan S’s timelines relatively smoothly. Fields with smaller grants, more diffuse funding, or monograph- and edited-volume-centred outputs did not. A mandate calibrated to biomedical and physical-science funding flows does not transfer cleanly to a discipline where the primary scholarly output is a single-author book written over several years.

    The humanities and monograph fit problem. Books remain the primary currency of career advancement in much of the humanities. Open access book publishing carries different cost structures (often higher per-unit costs than a journal article), different licensing sensitivities (image rights, third-party permissions, translated quotations), and a much thinner diamond and institutional-press ecosystem to absorb the volume. Applying a journal-shaped policy to a book-shaped discipline was, on the evidence of cOAlition S’s own deferred treatment of monographs, recognised as a mismatch from the outset — yet the underlying tension has never been fully resolved.

    Open access route How it works Typical discipline fit Cost burden cOAlition S’s current stance
    Gold (APC) Author or funder pays a publication fee for immediate open access STEM, grant-funded fields Shifted to authors/funders Supported, but flagged as unsustainable at scale
    Green (repository, via RRS) Author-accepted manuscript deposited under a retained CC BY licence Broad, including HSS Low direct cost Core mechanism, actively promoted
    Diamond (no author or reader fees) Community- or institution-funded journals/platforms Broad, especially HSS and society publishing Institutional/consortial funding Increasing emphasis in the 2026–2030 strategy
    Transformative agreements Institutions pay combined subscription-plus-publishing deals STEM-heavy, large-consortium markets High, opaque Support being phased out

    cOAlition S’s Own Retreat From Rigidity

    What makes the sceptic’s case harder to dismiss is that cOAlition S has, in effect, conceded much of it. The coalition’s published strategy for 2026–2030 signals a deliberate shift away from the rigid instruments of the 2018 launch:

    • Support for transformative agreements — once framed as a transitional bridge to full open access — is being wound down, an implicit admission that offsetting deals entrenched incumbent publishers’ revenue rather than transforming the market.
    • The strategy explicitly states that “no single model can meet all needs”, formally endorsing a plurality of routes (green, diamond, community-owned platforms) instead of privileging APC-funded gold.
    • Diamond open access — non-APC, non-subscription publishing typically funded by consortia, learned societies, or institutions — receives markedly more strategic weight than it did in 2018, partly because it fits humanities and society-publishing contexts that APC-gold never did.
    • Implementation timelines and compliance routes have been extended and softened repeatedly since 2021, a pattern of flexibility that was largely absent from the original ten principles.

    None of this is framed by cOAlition S as a repudiation of Plan S. But read against the criticisms above, it is difficult to interpret the 2026–2030 strategy as anything other than a coalition adjusting a blanket mandate toward the differentiated approach critics have been requesting since 2018.

    Common Questions About Plan S

    What is Plan S in open access?

    Plan S is an open access mandate launched in 2018 by cOAlition S, a coalition of national research funders including UKRI and the Wellcome Trust. It requires that peer-reviewed outputs from coalition-funded research be made immediately open access on publication, either through a compliant journal or platform, or via a no-embargo repository deposit.

    Do I have to pay for open access?

    Not necessarily. Gold open access typically involves an article processing charge (APC) paid by the author or funder. Green open access via repository deposit and diamond open access (no author or reader fees) are both compliant, fee-free alternatives that Plan S — and increasingly cOAlition S’s own strategy — actively supports.

    Toward Differentiated Funder Mandates

    The evidence points toward a specific policy design failure rather than a failure of open access as a goal. A single compliance clock, a single funding assumption, and a single default route (APC-gold) were applied across disciplines with radically different publishing economies. The fix is not to abandon open access mandates but to differentiate them:

    • Route-neutral compliance that treats green, diamond, and gold as equally valid by default, rather than gold-as-default with green as an exception.
    • Discipline-aware timelines, recognising that a monograph-based field cannot realistically match a journal-article field’s production cycle.
    • Direct funding for diamond infrastructure in HSS fields, rather than expecting APC markets to develop where publishing economics do not support them.
    • Transparent reporting on cost-shifting, so funders and institutions can see whether a mandate is redistributing cost fairly or simply moving it from library budgets to grant budgets.

    For research administration teams managing funder compliance day to day, this is not an abstract debate — differentiated mandates mean different checklists, different budget lines, and different risk profiles by discipline, and institutional policy needs to reflect that variation rather than applying one open access rulebook across every faculty.

    Conclusion: What Should Come Next

    Plan S succeeded at the one thing a blanket mandate is good at: forcing the issue onto every funder’s and publisher’s agenda within a few years, where voluntary encouragement had achieved comparatively little in the preceding two decades. It failed, or at least strained badly, at the thing blanket mandates are structurally bad at — accommodating disciplinary and economic diversity. cOAlition S’s own 2026–2030 strategic pivot toward plural, discipline-flexible routes is the clearest evidence that the coalition has reached the same conclusion. The sensible reading is not “Plan S failed” or “Plan S succeeded”, but that the next generation of funder mandates should be designed as differentiated instruments from the outset, rather than retrofitted into flexibility five years after a rigid launch.

  • cOAlition S EU-Funded Projects: What Horizon Europe Grantees Must Still Do

    Search “cOAlition S EU-funded projects” and you land on a page that is easy to misread. It does not list the projects cOAlition S funds for grantees — it lists the European Commission grants that fund cOAlition S itself. That distinction matters for research administrators trying to work out which obligations actually attach to a Horizon Europe grant, and which belong to the separate, funder-driven Plan S mandate that the European Commission helped create.

    This piece reads that page on its own terms, then answers the practical question institutions actually have: given that the European Commission’s own Horizon Europe open access mandate already exists, where — if anywhere — does cOAlition S add anything a grantee still has to act on?

    What “EU-Funded Projects” Actually Lists on cOAlition S’s Site

    cOAlition S’s “EU-funded projects” resource page catalogues five Horizon Europe and Horizon 2020 grants awarded to the European Science Foundation and partner consortia to build the infrastructure and evidence base around Plan S — it is not guidance aimed at individual grant recipients. Each entry names the funding call, the EU contribution, the duration and the coordinating institution.

    Project Funded under EU contribution Duration Coordinator
    OA-Advance HORIZON.4.2 €132,000 2024–2025 European Science Foundation (France)
    SOAR H2020-EU.5.e. €299,930 2020–2023 European Science Foundation (France)
    DIAMAS HORIZON-WIDERA-2021-ERA-01-43 €3,000,000 2022–2025 Aix-Marseille University (France)
    CRAFT-OA HORIZON-INFRA-2022-EOSC-01-02 €5,000,000 2023–2028 University of Göttingen Library (Germany)
    PALOMERA HORIZON-WIDERA-2022-ERA-01-42 €2,000,000 2023–2025 OPERAS (Belgium)

    The through-line is instructive: the European Commission is not a passive observer of Plan S. It is a funding partner for the studies (OA-Advance’s independent review of Plan S impact), tools (SOAR’s support for identifying compliant venues) and Diamond open-access infrastructure (DIAMAS, CRAFT-OA, PALOMERA) that keep the mandate operable. That funding relationship is the real answer to how cOAlition S and Horizon Europe are connected — and it is the fact most generic summaries of Plan S skip entirely.

    How cOAlition S and the Horizon Europe Mandate Overlap

    The European Commission is itself a cOAlition S member, alongside national funders including several that fund UK-based and other associated-country researchers, and the Horizon Europe open access mandate is, in substance, the Commission’s own implementation of Plan S principles inside its Model Grant Agreement. Both frameworks require:

    • Immediate open access to peer-reviewed publications, with no embargo period.
    • Deposit of the publication, or the accepted manuscript, in a trusted repository at the time of publication.
    • A Creative Commons Attribution (CC BY) licence, or equivalent, on journal articles and conference papers.
    • Author retention of sufficient rights to comply, regardless of what a publisher’s default policy allows.

    Because these baseline requirements are shared, a grantee who satisfies the Horizon Europe Model Grant Agreement’s open access clause will, in almost all cases, also satisfy Plan S. This is why cOAlition S materials describe Horizon Europe as an aligned implementation rather than a competing regime.

    Where cOAlition S Rules Still Add to the Horizon Europe Baseline

    Alignment is not identity. Three areas where the two frameworks are not simply interchangeable deserve attention from institutional research offices.

    Scope beyond the grant. Plan S is a funder mandate: it binds a researcher’s Plan-S-relevant output for as long as they hold funding from a cOAlition S member, not only the outputs tagged to a single Horizon Europe grant number. A researcher holding both a Horizon Europe grant and, say, a Wellcome or Research Council of Norway award is subject to the combined Plan S obligations of every cOAlition S funder involved — the Horizon Europe clause alone does not cover that.

    The compliance route. cOAlition S operationalises compliance through the Journal Checker Tool, which tells an author whether a specific journal, for their specific funder and affiliation, satisfies the mandate via the fully open access “Gold” route, a compliant transformative agreement, or the self-archiving Rights Retention Strategy route. The Horizon Europe Model Grant Agreement states the requirement; the Journal Checker Tool is the operational instrument grantees actually use to verify a chosen venue — and it is a cOAlition S resource, not an EC one.

    Article Processing Charges in hybrid venues. Horizon Europe funding rules do not reimburse APCs for publishing in hybrid journals — subscription titles that also sell open access on a per-article basis — only in fully open access journals or platforms, including the Commission’s own Open Research Europe platform. Plan S’s broader principle is the same, but grantees who assume “my publisher offered an open access option” is automatically fundable frequently discover the hybrid exclusion applies regardless of which mandate they cite.

    Common Questions from Grantees

    What is an EU funded project?

    An EU-funded project is a research or coordination activity receiving a grant from a European Union programme such as Horizon Europe or its predecessor, Horizon 2020. In cOAlition S’s own case, five such projects — OA-Advance, SOAR, DIAMAS, CRAFT-OA and PALOMERA — fund the coalition’s open access infrastructure and evidence base, not individual researchers’ compliance.

    Can the UK apply for EU funding?

    Yes. The UK re-associated to Horizon Europe from January 2024, meaning UK-based researchers can again apply for and hold Horizon Europe grants directly. UK recipients follow the same open access mandate as any other beneficiary, alongside any separate Plan S obligations from UK funders such as UKRI or Wellcome.

    Is cOAlition S the same body as the European Commission?

    No. cOAlition S is a voluntary alliance of national and private research funders, of which the European Commission is one member among roughly two dozen. The Commission sets Horizon Europe’s own grant conditions independently, but has aligned them closely with Plan S principles as part of that membership.

    Do Horizon Europe grantees need to follow Plan S separately from their grant agreement?

    Usually not in substance, since the Horizon Europe Model Grant Agreement already embeds Plan S’s core requirements. Grantees should still check Plan S obligations separately whenever a co-funder, prior grant, or institutional mandate outside Horizon Europe applies to the same publication.

    A Practical Compliance Checklist

    For research offices triaging a Horizon Europe-funded manuscript against both frameworks, the practical questions are the same regardless of which document a grant officer cites:

    1. Does the venue offer immediate open access with no embargo — checked directly, not assumed from the journal’s general reputation?
    2. Is a CC BY licence (or CC BY-NC / CC BY-ND for a monograph) applied to the published or accepted version?
    3. Has the author retained rights to deposit the accepted manuscript, independent of the publisher’s standard licence terms?
    4. If the venue is hybrid, has the team confirmed the APC is not eligible for reimbursement under Horizon Europe rules before committing funds?
    5. Do any other cOAlition S funders co-fund the same output, requiring a combined compliance check beyond the Horizon Europe grant alone?

    What This Means for Institutions

    The practical risk is not that Horizon Europe and Plan S conflict — it is that research offices treat “we’re Horizon Europe funded, so we’re covered” as a substitute for checking the venue, licence and co-funder picture on each output. Teams that build Journal Checker Tool and rights-retention verification into submission workflows, rather than relying on the Model Grant Agreement clause as a proxy, catch hybrid-APC and multi-funder edge cases before they become a post-award finding.

    For teams supporting research administration workflows across multiple funders, the EU-funded projects underpinning cOAlition S’s own infrastructure — particularly DIAMAS and CRAFT-OA’s work on Diamond open access publishing — are also worth tracking directly, since they signal where funder-preferred, no-fee publishing routes are likely to expand over the current Horizon Europe programming period.

    Outlook

    With DIAMAS and CRAFT-OA running through 2025 and 2028 respectively, and OA-Advance’s independent review due to feed recommendations on what comes after Plan S, the EU-funded projects on cOAlition S’s own page are best read as a forward signal rather than a static resource list. Institutions tracking them alongside their Horizon Europe grant terms — rather than treating the two frameworks as separate compliance tracks — will be better placed as Diamond open access infrastructure matures and funder mandates converge. CASRAI’s open research terminology reference provides further grounding for related definitions.