The Wellcome Trust open access policy requires immediate, embargo-free deposit of Wellcome-funded research articles in Europe PMC under a CC BY licence, restricts article-processing-charge funding to fully open-access venues from January 2025, and layers a separate data-sharing mandate on top of its OA rules — diverging in mechanics from both Plan S’s route-based minimum and REF 2029’s embargo-tolerant, lower-bar licensing floor.
Wellcome is a UK-based biomedical research charity and a founding funder of cOAlition S, the international funder consortium that created Plan S in 2018.
- What does Wellcome’s open access policy require in 2026?
- How Wellcome aligns with — and adds to — Plan S
- Where Wellcome diverges from REF 2029’s open access rules
- Data sharing and rights retention: Wellcome’s additional layer
- Frequently asked questions
- Implications for institutions and researchers
What does Wellcome’s open access policy require in 2026?
Wellcome’s policy, in force since 1 January 2021 and tightened twice since, applies to all original research articles arising in whole or part from its funding. Three mechanics define it. First, the article must be deposited in Europe PMC and made freely available on the official publication date, with no embargo permitted. Second, authors must retain enough rights to apply a CC BY licence to the Author Accepted Manuscript — a mechanism known as rights retention — with CC BY-ND granted only by exception. Third, from 1 January 2025 Wellcome funds article-processing charges only in fully open-access journals or platforms; transitional funding for hybrid “read and publish” agreements ended in December 2024.
A 16 January 2024 update added a fourth route: where neither the Version of Record nor the Accepted Manuscript can be made compliant, a CC BY-licensed preprint posted to a Europe PMC-indexed server before final publication now satisfies the policy. Scholarly monographs and book chapters submitted after 1 January 2021 fall under a related but separate Wellcome monograph policy, which permits a maximum six-month embargo — a materially different rule from the zero-embargo standard applied to journal articles.
How Wellcome aligns with — and adds to — Plan S
Wellcome has been a cOAlition S founding member since 2018, and its journal-article rules track Plan S’s core requirements closely: immediate access, a CC BY default, and no embargo. Both frameworks recognise the same three compliance routes — publishing in a fully open-access venue, self-archiving via rights retention in a repository, or publishing through a transformative agreement — and both use the shared Journal Checker Tool to let authors verify a venue in advance.
Wellcome goes beyond the Plan S baseline in enforcement and scope. Plan S sets principles each signatory funder operationalises independently; Wellcome adds funder-specific detail Plan S does not itself mandate — the 2024 preprint route, a ban on OA block-grant funds paying hybrid APCs, and named sanctions (loss of lead-applicant eligibility, suspended grant payments) for non-compliance. Plan S does not prescribe monograph rules; Wellcome does, via its separate six-month-embargo monograph policy.
Where Wellcome diverges from REF 2029’s open access rules
REF 2029 — the UK’s national research assessment exercise, run by Research England and the other UK funding bodies — is not a Plan S signatory framework, and its open access requirements are structurally looser than Wellcome’s. Under the REF 2029 policy for outputs published between 1 January 2026 and 31 December 2028, journal articles and conference proceedings must be deposited within three months of publication, but embargoes are still permitted: up to six months for Main Panels A and B, and up to twelve months for Main Panels C and D. That is a reduction from REF 2021’s 12- and 24-month allowances, but it is not the zero-embargo standard Wellcome and Plan S apply.
REF 2029’s licensing floor is also lower. While CC BY is the funding bodies’ stated preference, a CC BY-NC-ND licence — Non-Commercial, No Derivatives — meets the minimum requirement, versus Wellcome’s CC BY default with only narrow CC BY-ND exceptions. REF 2029 additionally excludes monographs, book chapters and scholarly editions from its open access scope entirely, whereas Wellcome applies its own (separate) embargo rule to those output types. The table below summarises the divergence.
| Requirement | Wellcome (2026) | Plan S / cOAlition S | REF 2029 |
|---|---|---|---|
| Embargo (journal articles) | None | None | 6 months (Panels A/B); 12 months (Panels C/D) |
| Default licence | CC BY (CC BY-ND by exception) | CC BY | CC BY preferred; CC BY-NC-ND meets minimum |
| APC funding scope | Fully OA venues only (from Jan 2025) | Route-dependent, funder-operationalised | Not an APC-funding body |
| Compliance route | Europe PMC deposit, rights retention, or CC BY preprint | Gold OA, rights retention, or transformative agreement | Repository deposit (green route) within 3 months of publication |
| Monographs/book chapters | In scope; max 6-month embargo | Not prescribed by Plan S itself | Out of scope for REF 2029 |
| Data sharing mandate | Separate DMSP requirement | Not part of core Plan S text | Not part of REF open access policy |
Data sharing and rights retention: Wellcome’s additional layer
Neither Plan S nor REF 2029 mandates data sharing as a condition of open access compliance; Wellcome does, through a policy that operates alongside — not inside — its OA rules. Wellcome’s Data, Software and Materials Management and Sharing Policy, updated 1 August 2024, requires funded researchers to submit an outputs management plan and to maximise access to research data with as few restrictions as possible. For research relating to public health emergencies, the policy requires quality-assured interim and final data to be shared as rapidly and as widely as possible, ahead of formal publication.
- A Data Management and Sharing Plan (DMSP) is typically required at the application or award stage, not deferred to end-of-grant reporting.
- The rights-retention statement authors must insert into subscription and hybrid-journal submissions is a Wellcome-specific compliance artefact — it is not required in the same form under REF 2029’s repository-deposit route.
- Non-compliance with either the open access or the data-sharing policy can trigger the same sanction: ineligibility to apply as lead applicant on future Wellcome grants.
This is the funder-specific compliance gap institutions most often miss: a paper can satisfy REF 2029’s repository-deposit rule and still fail Wellcome’s audit if the underlying dataset was not made accessible under the separate data policy.
Frequently asked questions
Does Wellcome allow any embargo on open access articles?
No. Wellcome’s open access policy requires immediate deposit in Europe PMC with no embargo for original research articles. This is stricter than REF 2029, which permits six- or twelve-month embargoes depending on the assessment panel, and applies only to journal articles and conference proceedings, not to monographs.
Is Wellcome Trust a Plan S funder?
Yes. Wellcome has been a founding member of cOAlition S since 2018 and its 2021 policy was designed to align with Plan S principles. However, Wellcome operationalises those principles through its own mechanics — including a 2024 preprint-compliance route and named non-compliance sanctions — that Plan S itself does not mandate.
Do REF 2029 open access rules apply to monographs?
No. REF 2029’s open access policy covers only journal articles and conference proceedings with an ISSN; monographs, book chapters and scholarly editions are excluded from the current cycle, though UK funding bodies have signalled monograph requirements from the following REF exercise.
Will Wellcome pay for open access publication in a hybrid journal?
Not from January 2025 onward. Wellcome’s OA block grant now funds article-processing charges only in fully open-access journals or platforms; the transitional funding for hybrid “read and publish” agreements ended in December 2024.
Implications for institutions and researchers
Research administration teams managing multi-funder portfolios cannot apply one embargo or licensing rule across Wellcome, Plan S-aligned funders and REF 2029 — the three frameworks set genuinely different floors. A paper compliant with REF 2029’s CC BY-NC-ND minimum via green deposit can still breach Wellcome’s zero-embargo, CC BY-default rule if Wellcome funding is also acknowledged. Institutions need compliance checklists that track funder-specific mechanics, not a generic “open access” requirement, and should route Wellcome-funded outputs through the Journal Checker Tool before submission rather than after acceptance.
The direction of travel across all three frameworks is convergence on stricter terms: REF’s embargo ceilings have already fallen once, UK funding bodies have flagged monograph open access for the exercise after REF 2029, and Wellcome’s data-sharing layer signals that funders increasingly treat open access and open data as linked obligations, not separate ones. Compliance processes built around funder-specific detail, not the lowest common denominator, will hold up best as these policies keep tightening.