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.