CASRAI Dictionary

Tag: ukri open access policy

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

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

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

    What does the REF 2029 open access policy cover?

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

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

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

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

    What is the deposit window for REF 2029 outputs?

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

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

    What are the REF 2029 embargo caps by panel?

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

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

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

    What licence does REF 2029 require?

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

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

    Why are monographs excluded from REF 2029 open access rules?

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

    Frequently asked questions

    What outputs are eligible for REF 2029 open access requirements?

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

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

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

    What is an open access policy in the REF context?

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

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

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

    What this means for research administrators

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

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

    Outlook: the run-up to 2029

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

  • UKRI Open Access Policy vs Plan S: Differences

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

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

    What is the UKRI open access policy?

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

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

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

    How does Plan S set the global baseline?

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

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

    Where UKRI rules are stricter than Plan S

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

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

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

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

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

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

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

    Common questions on UKRI’s open access policy

    What is the UKRI open access review?

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

    Do authors have to pay for open access?

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

    What outputs are eligible for REF 2029?

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

    What is the open access policy?

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

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

  • REF 2029 Open Access Policy vs Plan S Rules

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

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

    What is the REF 2029 open access policy?

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

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

    How do the REF 2029 eligibility requirements work?

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

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

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

    What does Plan S require on embargoes and licensing?

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

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

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

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

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

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

    Answer-first Q&A

    What outputs are eligible for REF 2029?

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

    What are the key changes for REF 2029?

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

    What period does REF 2029 cover?

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

    What is an open access policy?

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

    Implications for institutions and researchers

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

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

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

  • 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.

  • RCUK Open Access Report: What Changed Under UKRI

    The RCUK open access report was the annual institutional compliance return that UK universities filed to Research Councils UK from 2013, tracking block-grant spend and Gold/Green compliance rates. UK Research and Innovation (UKRI) absorbed this reporting duty on its formation in 2018 and then retired the manual return altogether under its harmonised 2022 open access policy.

    The Research Councils UK (RCUK) open access policy is the funder mandate, introduced on 1 April 2013, that required peer-reviewed outputs acknowledging Research Council funding to be made freely accessible via a Gold or Green route.

    What was the RCUK open access report?

    The RCUK open access report was an institution-level compliance return, typically prepared as a spreadsheet, that recorded how each university’s RCUK block grant had been spent and what proportion of eligible outputs met the policy’s Gold or Green requirements. Research organisations receiving RCUK open access block grants were expected to submit these figures annually to the relevant research council.

    Under the RCUK policy, Gold open access — the publisher making the final Version of Record free on publication, usually funded by an Article Processing Charge (APC) — was the preferred route, supported by direct block-grant payments to institutions. Green open access, depositing the Author’s Accepted Manuscript in a repository, was permitted subject to an embargo of up to six months for STEM subjects and twelve months for arts, humanities and social sciences. Universities such as Imperial College London, the University of Edinburgh and the University of Southampton published detailed versions of their own compliance reports, illustrating how administratively heavy the annual return had become by the mid-2010s.

    Why UKRI absorbed RCUK’s reporting regime

    UKRI was formed on 1 April 2018 under the Higher Education and Research Act 2017, bringing together the seven former Research Councils, Innovate UK and Research England into a single funding body. This merger created both the opportunity and the obligation to harmonise the fragmented council-by-council open access reporting that RCUK had left behind.

    UKRI subsequently ran a formal open access policy review, consulting institutions, publishers and researchers, with the explicit goal of replacing seven overlapping council policies — and their separate compliance paperwork — with a single UKRI-wide mandate. UKRI is also a member of cOAlition S, the international funder consortium behind Plan S, which launched in 2018 and became fully operative for its members on 1 January 2021. Plan S’s ten principles, including immediate open access with no embargo and a preference for CC BY licensing, became the template UKRI built its new policy around, rather than a patchwork of council-specific embargo periods.

    What changed under the 2022 UKRI open access policy

    The new UKRI open access policy took effect on 1 April 2022 for peer-reviewed research articles and conference papers with an ISSN, and on 1 January 2024 for monographs, book chapters and edited collections. It requires immediate open access with no embargo permitted, via either Gold (Version of Record free on the publisher’s site) or Green (Author’s Accepted Manuscript in a repository, released immediately under a CC BY licence through UKRI’s Rights Retention Strategy).

    The most consequential change for research administrators is what UKRI removed, not just what it added: the annual institutional compliance spreadsheet that defined the RCUK era is gone. UKRI monitors compliance through existing publication metadata — repository records, CrossRef and publisher data — rather than requiring institutions to submit a standalone report. UKRI has also committed a dedicated fund of £3.5 million per year to support open access costs for long-form outputs, separate from the block-grant model that funded RCUK-era Gold APCs.

    • No embargo permitted on journal articles or conference papers from 1 April 2022
    • CC BY is the default licence, with CC BY-ND permitted only by exception
    • Monographs, book chapters and edited collections join the policy from 1 January 2024
    • Compliance monitoring shifts from submitted spreadsheets to existing metadata sources

    RCUK vs UKRI open access reporting compared

    The table below sets out the practical differences institutions need to reconcile when auditing historical RCUK-funded outputs against current UKRI-funded ones.

    Aspect RCUK policy (2013–2022) UKRI policy (from 2022/2024)
    Reporting mechanism Annual institutional compliance spreadsheet submitted per council Monitoring via existing publication metadata; no standalone institutional report
    Governing body Seven separate Research Councils Single UKRI-wide policy
    Green embargo Up to 6 months (STEM) / 12 months (AHSS) No embargo permitted
    Default licence Not standardised across councils CC BY, via the Rights Retention Strategy
    Scope Peer-reviewed articles and conference papers Adds monographs, book chapters, edited collections from 2024
    Funding model Block grants to institutions Block grants plus a dedicated £3.5m/year long-form fund

    Frequently asked questions

    What is an open access report?

    An open access report is a compliance return that documents whether research outputs funded by a body such as RCUK or UKRI meet that funder’s open access requirements. Under RCUK it was an institution-submitted spreadsheet tracking block-grant spend; under UKRI, compliance is now inferred from publication metadata rather than a submitted document.

    What is the RCUK policy on open access and supporting guidance?

    The RCUK policy on open access, introduced 1 April 2013, required peer-reviewed papers acknowledging Research Council funding to be made freely available through Gold or Green routes, supported by block-grant guidance issued to research organisations on eligible costs and embargo limits.

    What was the UKRI open access review?

    The UKRI open access review was a formal consultation process examining UKRI’s inherited RCUK-era policies to design a single, harmonised mandate. It engaged institutions, publishers and researchers, and its outcome was the 2022 UKRI open access policy that superseded all seven prior council-specific arrangements.

    What are open access requirements under UKRI?

    Current UKRI open access requirements mandate immediate access with no embargo for journal articles funded from 1 April 2022, a CC BY licence by default, and a Data Access Statement in every covered article, whether or not underlying data exists.

    What this means for institutions filing compliance today

    Research offices auditing historical outputs still need to apply RCUK-era rules — embargo periods, council-specific block-grant terms — to anything published before 1 April 2022, while applying the no-embargo UKRI standard to everything after. This dual-track reality means institutional repositories and current research information systems (CRIS) should retain the ability to flag which regime governed a given output, since RCUK-era Green deposits legitimately carried embargoes that would now be non-compliant under UKRI rules.

    Because UKRI no longer requires a submitted spreadsheet, the burden has shifted from periodic reporting to continuous metadata hygiene: accurate funder acknowledgement, licence tagging and repository deposit timing now do the compliance work that the annual RCUK report used to do. Institutions should also note that the separate REF 2021 open access policy, which required AAM deposit within three months of acceptance, ran on its own track alongside RCUK and is expected to align more closely with UKRI’s approach under the successor REF exercise.

    Conclusion: where UK open access reporting goes next

    The transition from RCUK to UKRI did not add a new reporting layer — it removed one. The annual compliance spreadsheet that defined a decade of RCUK administration has been replaced by metadata-driven monitoring under a single UKRI policy shaped by cOAlition S’s Plan S principles. For institutions, the practical task now is less about filing a report and more about ensuring the underlying publication record is accurate enough that UKRI’s monitoring can find compliance without being told about it.

    For research administrators managing legacy and current outputs side by side, understanding which policy era governs a given publication remains essential groundwork before any funder audit.

  • Why Publish Open Access? A Case for Researchers, Funders and Institutions

    Why publish open access? Because immediate, paywall-free publication increases a paper’s readership and citation potential, satisfies funder mandates from cOAlition S, UKRI and Wellcome, keeps outputs REF-eligible, and extends publicly funded research to readers who cannot access subscription journals — benefits that typically outweigh the cost of article processing charges.

    Open access is a publishing model in which the final, peer-reviewed version of a research output is made freely available online at the point of publication, without a subscription or paywall, under a licence that permits reuse. That single design choice — removing the paywall — is what drives every benefit and every trade-off discussed below.

    Why does open access matter for visibility and citation?

    Removing a paywall expands a paper’s potential readership beyond subscribing institutions to independent scholars, clinicians, policymakers and researchers in lower-income countries. Publisher-commissioned meta-analyses report open-access citation advantages in the region of 18–40%, a range corroborated by Taylor & Francis and Springer Nature author-services data. Independent bibliometricians caution that part of this gap reflects self-selection — authors tend to pay for open access on papers they already judge to be their strongest — so the advantage should be read as a correlation, not a guaranteed multiplier.

    Visibility gains are strongest for interdisciplinary and applied fields, where readers outside a paper’s home discipline or sector are less likely to hold a subscription. For research administrators tracking impact, unrestricted access also improves the reliability of usage metrics reported to funders and REF impact case studies, since download and view counts are not artificially depressed by paywall friction.

    Why do funders require open access?

    A growing share of research funding now carries a binding open-access condition, not a recommendation. Non-compliance can mean ineligible outputs, clawed-back grant funds, or exclusion from future funding rounds — which is why open access has shifted from an ethical preference to a compliance requirement for most UK and European researchers.

    • cOAlition S / Plan S — launched in 2018, this consortium of research funders requires immediate open access with no embargo, typically under a CC BY licence, for all funded research articles.
    • UKRI — UKRI’s open access policy has applied to journal articles and conference proceedings from grants awarded since 1 April 2022, and extended to monographs, book chapters and edited collections from 1 January 2024.
    • Wellcome — Wellcome’s open access policy requires immediate open access under a CC BY licence for all research articles arising from Wellcome funding, with no embargo permitted.
    Funder Embargo permitted Preferred licence Route accepted
    cOAlition S (Plan S) No CC BY Gold or green with no embargo
    UKRI No (journal articles) CC BY Gold or green via repository deposit
    Wellcome No CC BY Gold, with preprint posting expected

    These mandates are the practical reason many researchers no longer treat open access as optional: the funding itself is now conditioned on it.

    Why is open access so expensive?

    The commonest objection to open access is cost. Gold open access is usually funded through an article processing charge (APC) paid by the author, institution or funder rather than by the reader, and APCs at established hybrid and fully open-access journals frequently run into several thousand pounds per article. That cost has not disappeared — it has moved from the reader’s library subscription to the author’s grant budget, which is precisely why the objection persists even as access improves.

    Three developments are making that cost more visible and, in places, avoidable:

    • Price transparency requirements — cOAlition S’s Price and Service Transparency Framework requires participating publishers to disclose a cost breakdown behind their APCs, rather than setting a single opaque list price.
    • Transformative and Read-and-Publish agreements — many UK institutions now hold deals with major publishers that bundle subscription and publishing costs, so individual authors at those institutions pay no APC directly.
    • No-fee routes exist — green open access (self-archiving the accepted manuscript in a repository) and diamond open access (journals that charge neither reader nor author) both avoid APCs entirely; a substantial share of journals indexed in the Directory of Open Access Journals charge no APC at all.

    The honest answer to “why is open access so expensive” is that the cost of publishing has not fallen — it has been reallocated and, under frameworks such as Plan S’s transparency requirement, made auditable in a way subscription pricing never was.

    Is open access REF-ready — and who else benefits?

    For UK institutions, open access is also an assessment-eligibility issue. REF’s open-access policy, first applied in REF 2021 and carried forward into REF 2029 preparations, requires eligible journal articles and conference proceedings to be deposited in an institutional or subject repository within three months of acceptance to count towards the exercise. An output published open access but deposited late, or not deposited at all, can be ruled ineligible regardless of its quality — making the deposit step, not just the publishing decision, the compliance-critical action.

    Beyond assessment mechanics, open access serves the public-benefit case that funders increasingly require research to articulate: publicly funded findings reaching the clinicians, teachers, small businesses, patient groups and policymakers who funded them through taxation but who never held a university library card. This is the same accountability logic behind open metadata and contributor-transparency standards more broadly. CASRAI originated the CRediT contributor role taxonomy in 2014 as one such standard; it is now stewarded by NISO as ANSI/NISO Z39.104-2022, and, like open access itself, exists to make the research record more usable to people beyond the original authorship team.

    Common questions about publishing open access

    Should you publish open access?

    In most cases, yes — and increasingly it is not discretionary. If your funder is part of cOAlition S, or is UKRI or Wellcome, open access is a condition of the grant. Even without a mandate, the visibility, compliance and public-benefit case generally outweighs the APC cost, particularly where a transformative agreement or green route removes that cost entirely.

    What are the benefits of open access publishing?

    The core benefits are wider readership, a documented (if contested) citation advantage, compliance with funder mandates, REF eligibility when deposited correctly, and public access for readers outside subscribing institutions. Authors publishing gold open access also typically retain copyright under a CC BY licence rather than assigning it to the publisher.

    Do authors pay for open access?

    Often, but not always. Gold open access is usually funded via an APC paid by the author’s institution or funder. Green open access (repository self-archiving) and diamond open access (no-fee journals) both let authors publish openly without paying an APC at all.

    What are the disadvantages of open access publishing?

    The main drawbacks are APC cost where no waiver or agreement applies, uneven journal-quality perceptions in some fields, and the administrative burden of tracking funder-specific licensing and deposit requirements. Predatory journals exploiting the APC model are a further, separate risk that authors should screen for via journal vetting tools.

    What this means for authors going forward

    The direction of travel is unambiguous: funder mandates are expanding, not retreating, and REF-style assessment exercises are tightening deposit compliance rather than relaxing it. Researchers, institutions and publishers who treat open access as a compliance and visibility strategy — choosing the route (gold, green or diamond) that matches their funder’s requirement and their budget — are better positioned than those who treat each publication decision in isolation. The cost objection remains real, but transparency frameworks and no-fee routes mean it is no longer the unanswerable objection it once was.

  • cOAlition S Funders: Who’s In, Who Has Left

    cOAlition S funders are the roughly two-dozen national research funders, charitable foundations and international bodies — including UKRI, Wellcome Trust, the Swiss National Science Foundation and the European Commission — that publicly endorsed Plan S in 2018 and continue to require immediate, CC BY open access from their grant recipients. Not every major funder stayed the course: the Gates Foundation has diverged toward a preprint-first model, and the European Research Council, Sweden’s Riksbankens Jubileumsfond and India’s national funders withdrew or declined to join outright.

    cOAlition S is the funder consortium — not a legal entity but a voluntary alliance of research-funding and research-performing organisations — that created and continues to steward Plan S, the 2018 open-access mandate requiring full and immediate public access to publications arising from the funding it provides. This guide sets out exactly who is in that coalition today, who has left, and what that split means for grants administrators trying to work out which awards trigger Plan S compliance obligations.

    What is cOAlition S and who funds it?

    cOAlition S launched on 4 September 2018 when a group of eleven national research funding organisations, coordinated through Science Europe, announced a “collective declaration of commitment” to mandate open access from 1 January 2020. The coalition has since grown to include national funders across Europe, Africa and the Middle East, several of the world’s largest biomedical and scientific charities, and formal support from the European Commission and the World Health Organization.

    Membership is not static. Funders join, adjust their policies, or step away as their own institutional priorities and legal constraints evolve — which is exactly why a periodically-updated reference list, rather than a single static claim, is the useful format for this question.

    Which funders currently back Plan S?

    cOAlition S’s own organisations page groups its supporters into national funders, charitable and international funders, and European funders (including the European Commission). Based on cOAlition S’s published membership record and the sourced Wikipedia membership history, the coalition’s core currently includes the following.

    • National research funders: UK Research and Innovation (UKRI); Austrian Science Fund (FWF); France’s Agence Nationale de la Recherche (ANR); Science Foundation Ireland (SFI); Istituto Nazionale di Fisica Nucleare (INFN, Italy); Luxembourg National Research Fund (FNR); Netherlands Organisation for Scientific Research (NWO); Research Council of Norway (RCN); National Science Centre, Poland (NCN); Fundação para a Ciência e a Tecnologia (FCT, Portugal); Slovenian Research Agency (ARRS); Swedish Research Council for Sustainable Development (Formas), Forte and Vinnova; Swiss National Science Foundation (SNSF); Academy of Finland; National Health and Medical Research Council (NHMRC, Australia); South African Medical Research Council (SAMRC); Jordan’s Higher Council for Science and Technology; and Zambia’s National Science and Technology Council.
    • Charitable and international funders: Wellcome Trust; the Bill & Melinda Gates Foundation (with a materially diverged policy — see below); the Howard Hughes Medical Institute (HHMI); Templeton World Charity Foundation; and Aligning Science Across Parkinson’s (ASAP).
    • Institutional and multilateral support: the European Commission, which funds Horizon Europe on Plan S-aligned open-access terms, and the World Health Organization.

    cOAlition S publishes this list as a live, JavaScript-rendered directory rather than a static page, so administrators verifying a specific funder’s status should cross-check coalition-s.org/organisations directly rather than relying solely on any single secondary source, including this one.

    Which funders have left or diverged from Plan S?

    Three organisations have formally withdrawn from or declined to join cOAlition S, and one major member has substantially diverged from the original Plan S model while remaining nominally affiliated.

    Funder Status What changed
    Bill & Melinda Gates Foundation Member, policy diverged 2024 “preprint-centric” policy took effect January 2025; the foundation stopped paying article processing charges (APCs) and instead requires a preprint at or before formal publication, rather than mandating immediate open access to the accepted manuscript itself.
    European Research Council (ERC) Withdrew, July 2020 Supported the initiative from 2018 but its Scientific Council withdrew, citing concerns that Plan S’s implementation was too restrictive for early-career researchers and limited publication-venue choice.
    Riksbankens Jubileumsfond (RJ), Sweden Left, 2019 An early signatory that withdrew citing concerns over the implementation timeline.
    India (national funders) Declined to join, October 2019 Principal Scientific Adviser Vijay Raghavan announced India would pursue its own national open-access policy rather than sign on to cOAlition S.

    The Gates Foundation case is the one administrators most often ask about, because Gates remains publicly associated with the open-access movement while its funding terms have moved furthest from the original Plan S template. Its 2024 policy refresh, reported by Nature in April 2024, replaced APC funding with a preprint-first requirement — a shift toward green, repository-based access rather than the gold, journal-published-and-APC-funded model Plan S initially popularised. Wellcome Trust, by contrast, has kept its CC BY, zero-embargo requirement fully aligned with Plan S principles and remains a full cOAlition S member.

    How does this affect grant compliance for administrators?

    For research administrators, the practical question is rarely “is my institution generally Plan S-aligned” — it is “does this specific grant trigger Plan S obligations.” That depends entirely on the funder listed on the award, not on the institution or the discipline.

    • A UKRI, Wellcome, SNSF, NWO or European Commission (Horizon Europe) grant carries a live Plan S-style requirement: immediate, CC BY, zero-embargo open access to the peer-reviewed manuscript, with rights retention where the funder has adopted that strategy.
    • A Gates Foundation grant awarded or renewed after January 2025 requires a preprint at or before publication, but no longer carries a guaranteed APC payment — so budgeting APCs into a Gates-funded proposal on the old assumption will leave a funding gap.
    • An ERC (Horizon Europe) grant sits in a genuinely mixed position: the ERC itself withdrew cOAlition S support in 2020, but ERC grants are still funded under Horizon Europe, which the European Commission administers on Plan S-aligned terms — so the operative obligation traces to the Commission’s rules, not the ERC’s own institutional stance.
    • A grant from a funder never affiliated with cOAlition S (most US federal agencies, most Indian national funders) should be checked against that funder’s own policy rather than assumed to follow Plan S at all.

    The single most reliable compliance step is to check the specific funder named on the award letter against cOAlition S’s current organisations list and that funder’s own most recent policy document, rather than relying on institutional memory of what a funder required in 2019 or 2020.

    Frequently asked questions

    Has the Gates Foundation left cOAlition S?

    No. The Gates Foundation remains formally affiliated with cOAlition S, but its 2024 policy refresh — effective January 2025 — dropped APC funding in favour of a preprint-first requirement, moving its practical terms away from the original Plan S model without a formal exit.

    Is Wellcome Trust still part of Plan S?

    Wellcome Trust is a founding cOAlition S member and remains fully aligned with Plan S: its open-access policy requires immediate deposit of the peer-reviewed manuscript under a CC BY licence with no embargo, matching the original 2018 mandate.

    Why did the European Research Council withdraw from cOAlition S?

    The European Research Council backed the initiative in 2018 but its Scientific Council withdrew support in July 2020, stating that Plan S’s implementation guidance was too restrictive, particularly for early-career researchers‘ choice of publication venue.

    Where can I find the full, current list of cOAlition S funders?

    cOAlition S publishes its authoritative, continuously updated member list at coalition-s.org/organisations, grouped into national funders, charitable and international funders, and European funders — administrators should treat that page, not older news coverage, as the source of record.

    Implications and outlook

    cOAlition S was never designed as a fixed, closed membership — it is a voluntary coalition that funders join and leave as their institutional strategies evolve. The Gates Foundation’s shift toward a preprint-centric model is the most consequential recent change because it signals that even committed founding-era supporters are questioning APC-funded gold open access as the default route, in favour of greener, lower-cost alternatives. For institutions with active research administration functions, the practical takeaway is to treat “is this funder in cOAlition S” as a per-grant lookup rather than a one-time institutional assumption, and to revisit that lookup whenever a funder announces a policy refresh.

  • Wellcome Trust Open Access Policy Explained: Requirements, APC Funding and the Plan S Link

    Wellcome Trust’s open access policy requires that original research articles arising, in whole or in part, from Wellcome funding be made freely available in Europe PMC immediately on publication, licensed CC BY, with no embargo permitted — a rule that has applied to all qualifying submissions since 1 January 2021 and is backed by direct grant-linked funding for publication costs.

    The Wellcome Trust open access policy is the funder’s mandatory requirement that peer-reviewed research articles, monographs and book chapters supported by its grants be deposited in Europe PMC (and NCBI Bookshelf, for long-form works) and openly licensed at the point of publication, with compliance routes and funding administered directly by Wellcome rather than through a separate national mandate.

    What Wellcome’s open access policy requires

    Wellcome’s current policy took effect for articles submitted from 1 January 2021. It applies to all original peer-reviewed research articles supported wholly or partly by Wellcome funding, and requires immediate, unembargoed open access with a CC BY licence (CC BY-ND only by case-by-case exception, requested before submission).

    Three routes satisfy the policy:

    • Gold route — publish in a fully open access journal or platform; the publisher deposits the version of record in PubMed Central and Europe PMC.
    • Green route — publish in a subscription journal and make the author accepted manuscript (AAM) open in Europe PMC immediately, under CC BY, via Wellcome’s rights retention clause.
    • Transformative-agreement route — publish through an institutional transformative agreement that makes the version of record open access.

    Scholarly monographs and book chapters carry a separate provision: they may be deposited up to six months after publication and are not required to use CC BY if another Creative Commons licence is more appropriate.

    How Wellcome funds APC and open access costs

    Wellcome funds open access directly rather than relying solely on national block-grant schemes. In the 2021/22 grant year, Wellcome awarded £7.2 million in open access block grants to 38 institutions, and 92% of individually reported articles complied with the policy, according to Wellcome’s own published guidance.

    The funding rules tightened materially from 1 January 2025: Wellcome now funds article processing charges only for research articles published in fully open access journals or platforms. Hybrid (“paywall-plus-OA-option”) subscription journals are no longer eligible for Wellcome APC funding, even where an institution holds a transformative agreement with the publisher — a stricter position than Wellcome held during 2021–2024, when transformative-agreement “publish” fees were still fundable.

    This mirrors the broader Plan S trajectory away from hybrid subsidy, but Wellcome reached the fully-OA-only funding line on its own timetable, separate from any coalition-wide deadline.

    Rights retention: the automatic CC BY clause

    Wellcome’s rights retention mechanism is built into its grant conditions rather than delivered through a separate author addendum. Since 1 January 2021, Wellcome grant terms automatically apply a CC BY licence to the author accepted manuscript of any original research article the grant supports, in whole or in part — meaning the author retains sufficient rights to make the AAM open immediately, regardless of a publisher’s default embargo.

    This differs in mechanism, though not in intent, from UKRI’s parallel approach. UKRI’s own open access policy, which took effect for journal articles submitted from 1 April 2022, established a comparable zero-embargo, CC BY-on-AAM route roughly fifteen months after Wellcome’s clause had already been in force.

    Funder Zero-embargo Green route Automatic CC BY on AAM effective from cOAlition S / Plan S status
    Wellcome Trust Yes 1 January 2021 Founding member
    UKRI Yes 1 April 2022 Founding member
    cOAlition S baseline (Plan S) Required for Green route Recommended coalition-wide via the Rights Retention Strategy Coalition framework itself

    Where an author cannot secure rights retention on the AAM and the article is not published Gold, several UK institutions — including UCL — accept a CC BY-licensed preprint deposited in a Europe PMC-indexed preprint server before publication as an alternative compliance path.

    Wellcome is a founding member of cOAlition S, the funder consortium that launched Plan S in September 2018 alongside Science Europe and the European Commission, and that now counts roughly two dozen funder organisations among its members. Wellcome’s current policy is deliberately aligned with Plan S’s core principles: immediate access, open licensing, and author choice of venue.

    But the relationship runs the other way chronologically. Wellcome introduced one of the world’s first funder open access mandates in 2006 — over a decade before Plan S existed — requiring deposit of funded research in PubMed Central. The 2021 policy update did not create Wellcome’s open access commitment; it tightened an existing mandate (removing the embargo Wellcome had previously permitted) specifically to bring it into line with Plan S’s stricter, zero-embargo standard. Wellcome-funded researchers can check which compliance route a given journal supports using the Journal Checker Tool, built jointly by cOAlition S and its funder members.

    Common questions about Wellcome’s policy

    Does Wellcome Trust pay for open access publishing?

    Yes. Wellcome funds APCs directly for articles in fully open access journals and platforms, distributes annual open access block grants to grant-holding institutions, and separately funds compliant open access publication of monographs and book chapters on request.

    What licence does Wellcome require for open access articles?

    CC BY is the default requirement for all research articles made open under the policy. A more restrictive CC BY-ND licence is permitted only by prior, case-by-case exception, requested through Wellcome’s dedicated request form before submission.

    Is Wellcome Trust part of Plan S?

    Yes. Wellcome is a founding member of cOAlition S, the funder coalition behind Plan S. Its own open access policy is fully aligned with Plan S principles, though Wellcome’s underlying open access mandate predates Plan S by more than ten years.

    What happens if a Wellcome-funded paper doesn’t comply?

    Non-compliant articles are not automatically penalised per se, but Wellcome tracks compliance rates at institutional level, ties future open access block grant funding to institutional performance, and expects grant-holding organisations to actively support researchers in meeting the policy’s routes.

    Implications for institutions and researchers

    For research administrators managing Wellcome grant portfolios, the practical shift is the narrowing of fundable routes since January 2025: budgeting for hybrid-journal APCs against Wellcome funds is no longer viable outside a qualifying transformative agreement’s non-hybrid terms, so pre-submission journal checking has become a compliance necessity rather than a courtesy.

    Researchers publishing in subscription journals should treat rights retention as the default fallback, since it requires no publisher fee and no embargo negotiation — the CC BY licence on the accepted manuscript is already secured by the grant terms before the paper is ever submitted.

    Outlook

    Wellcome’s trajectory — mandate first, coalition alignment second, funding restriction third — has become a template other funders are following at their own pace. As UKRI, NIHR and other cOAlition S members continue tightening hybrid-journal funding eligibility, institutions that already built Wellcome-compliant workflows around zero-embargo Green routes are better placed to absorb the next round of funder-specific restrictions.

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

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

    The shared UKRI foundation

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

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

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

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

    How MRC and BBSRC diverge in practice

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

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

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

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

    Common questions from grant administrators

    What is the MRC open access policy?

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

    Does BBSRC require Europe PMC deposit?

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

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

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

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

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

    REF 2029 open access alignment

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

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

    Implications for multi-council award administrators

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

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

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

  • Jisc Open Access Agreements: A cOAlition S Compliance Route Map

    UK research administrators juggling funder mandates now face a genuinely confusing question: does a given Jisc open access agreement actually satisfy a cOAlition S-aligned funder’s Plan S requirement, or does it only cover the invoice? Jisc negotiates centrally on behalf of UK higher education institutions, but the resulting deals are not automatically interchangeable with Plan S’s own compliance routes — and conflating the two is a common source of avoidable non-compliance findings at grant closeout.

    This route map sets out, mechanism by mechanism, how Jisc’s negotiated agreements map onto cOAlition S’s three approved compliance routes and the UK Research and Innovation (UKRI) open access policy, so research offices can advise authors with confidence rather than by rule of thumb.

    What Jisc open access agreements actually negotiate

    Jisc negotiates three broad categories of open access agreement on behalf of its member institutions, governed by the UUK/Jisc Research Licensing Strategy Group and informed explicitly by the principles of Plan S and the OA2020 initiative:

    • Transitional (transformative) agreements — convert existing subscription spend into a combined fund covering both continued read access and open access publishing costs at hybrid and subscription titles (Elsevier, Wiley, Springer Nature, Taylor & Francis and others).
    • Fully open access agreements — membership or flat-fee arrangements with born-open-access and society publishers, including current deals with ACM (2026–2028), MDPI’s Institutional Open Access Program (2026–2027) and PLOS’s flat-fee and Community Action Publishing licences (2026–2027).
    • Compliant green agreements — publisher commitments to an immediate, embargo-free, CC BY-licensed repository deposit route for authors who cannot or do not use a paid option.

    Springer Nature alone reports over 100 UK institutions participating in its Jisc-negotiated agreement, illustrating the scale of collective bargaining involved. These agreement types are the practical instruments; the compliance routes they need to satisfy come from cOAlition S itself.

    The three cOAlition S Plan S compliance routes

    cOAlition S launched Plan S in 2018, with implementation beginning on 1 January 2021. Its implementation guidance sets out exactly three routes by which a funded output can be considered compliant. Understanding these routes independently of any single publisher deal is the foundation for everything that follows.

    Plan S route What it requires Typical publication type
    Route 1 — Open access venue Publish in a fully open access journal or platform, immediately available under CC BY Gold OA / Diamond OA journals
    Route 2 — Transformative arrangement Publish in a subscription/hybrid journal covered by a recognised transitional agreement Hybrid journals under a Jisc transitional deal
    Route 3 — Repository deposit Deposit the author accepted manuscript (or, increasingly, version of record) immediately, with no embargo and a CC BY licence, often invoking the Rights Retention Strategy Any subscription journal, including those with no Jisc deal at all

    Route 3 matters most for institutional risk management: it is the fallback that keeps every author compliant even when no Jisc agreement exists for their chosen journal, or when an agreement’s funding allocation has already been exhausted for the year.

    Matching Jisc agreement types to each compliance route

    Jisc’s own three agreement categories were designed with these routes in mind, but the mapping is not always one-to-one, and research offices need to check eligibility at the point of submission rather than assume coverage.

    Jisc agreement type Plan S route satisfied Practical caveat for research offices
    Fully open access agreement Route 1 (OA venue) Confirm the specific journal or platform is listed under the current licence, not just the publisher brand
    Transitional (transformative) agreement Route 2 (transformative arrangement) Fund caps and corresponding-author eligibility rules mean coverage can lapse mid-year
    Compliant green agreement Route 3 (repository deposit) Requires active AAM deposit workflow — Jisc’s Publications Router can automate metadata and full-text delivery to the repository

    UKRI, a founding cOAlition S funder, layers its own 2021 open access policy on top of this framework: immediate open access is required for journal articles and conference proceedings from grants awarded on or after 1 April 2022, and for monographs, book chapters and edited collections from 1 January 2024. UKRI’s policy is designed to align with Plan S principles but is administered separately — an author can be UKRI-compliant via the same Gold, transformative, or Green routes described above, but institutions must check UKRI’s specific embargo and licensing terms rather than assume Plan S compliance automatically satisfies UKRI, or vice versa.

    Common questions from UK research offices

    What is a read and publish deal?

    A read and publish deal is a single institutional agreement, usually negotiated by a consortium such as Jisc, that bundles subscription access to a publisher’s journals with funded open access publishing rights for eligible corresponding authors, replacing separate read and pay-to-publish invoices.

    What are the three routes to Plan S compliance?

    cOAlition S recognises three routes: publishing in a fully open access journal or platform; publishing in a subscription journal under a recognised transformative arrangement; or depositing the accepted manuscript in a repository immediately, with no embargo and a CC BY licence.

    Is the UKRI open access policy the same as Plan S?

    No. UKRI is a cOAlition S founding funder and designed its 2021 open access policy to align closely with Plan S principles, but the two are administered separately, with UKRI setting its own effective dates, embargo rules and licensing requirements that research offices must check independently.

    Is Jisc’s Open Policy Finder the same as the Journal Checker Tool?

    No — they are commonly confused. Open Policy Finder is Jisc’s own tool for checking publisher and funder policies, while the Journal Checker Tool is operated independently by cOAlition S at journalcheckertool.org to confirm a specific journal-institution-funder combination against Plan S routes.

    A practical compliance checklist

    Research offices advising authors on a submission should work through the following before a manuscript goes out:

    1. Confirm whether the funder is a cOAlition S signatory, and separately whether UKRI-specific terms also apply.
    2. Check the target journal against the current Jisc agreement list for the author’s institution and publisher — agreement coverage varies by title, not just by publisher.
    3. Run the combination through cOAlition S’s Journal Checker Tool to confirm which of the three routes applies before submission, not after acceptance.
    4. Monitor transitional agreement fund caps; many UK institutions see APC allocations exhausted before the calendar year ends.
    5. Maintain a documented Green-route fallback — immediate AAM deposit with a Rights Retention Statement — for any journal outside a live agreement.
    6. Record the compliance route used against each output for funder reporting and REF-adjacent audit trails.

    Implications for research offices

    The practical risk sits less in the headline agreements than in their edges: mid-year fund exhaustion on transitional deals, journals moving in or out of coverage between renewal cycles, and corresponding-author eligibility rules excluding co-authors at non-participating institutions. Jisc’s multi-year renewals — the ACM Open Journals agreement running 2026–2028, PLOS licences renewed for 2026–2027 — give planning stability, but offices should treat every agreement as time-bound and re-verify eligibility annually rather than relying on a static internal list.

    There is also a structural shift underway toward Subscribe to Open and community-based membership models, which remove per-article APC decisions entirely but still require a compliant Green fallback under current Jisc guidance, since S2O agreements depend on enough institutions subscribing to unlock full participation. For research administration teams building durable workflows, the safest design principle is to treat Route 3 — immediate repository deposit — as the permanent baseline, with Jisc’s negotiated Routes 1 and 2 as opportunistic upgrades rather than the primary compliance mechanism.

    Looking ahead

    As UKRI’s open access policy embeds further into monograph and long-form publishing and Jisc continues renewing its publisher portfolio, the institutions with the least audit risk will be those that stopped treating “which Jisc deal applies” as the first question. The first question should be which Plan S route the output needs to satisfy; the applicable Jisc agreement, if one exists, is simply the most convenient way to deliver it. Research offices that build their author guidance and internal tooling — including terminology drawn from a shared open access dictionary — around the three compliance routes, rather than around individual publisher brands, will adapt fastest as agreements are renegotiated, replaced or allowed to lapse.