CASRAI Dictionary

Tag: wellcome trust open access policy

  • Gates Foundation Open Access Policy: No More APCs for cOAlition S Funders

    The Gates Foundation open access policy was refreshed for 2025, taking effect on 1 January 2025: the foundation stopped paying article processing charges (APCs) for individual manuscripts, added a mandatory preprint-deposit requirement, and expanded the policy’s scope to cover every funded manuscript and its underlying data.

    The Gates Foundation open access policy is the Bill & Melinda Gates Foundation’s mandatory framework requiring that all peer-reviewed research and data arising from its funding be made freely available, openly licensed, and reusable without embargo. As a founding member of cOAlition S, the funder that co-created and popularised Plan S in 2018, the foundation’s 2025 refresh is being watched closely as a signal of where other research funders may be heading on APC costs.

    What Changed in the 2025 Policy Refresh?

    The 2025 policy is framed as a “refresh” of the 2021 policy, not a wholesale replacement — the core repository mandate survives intact. What changes is scope and support. It now applies to “all published research funded, in whole or in part, by the foundation” — termed Funded Manuscripts — and to “any data underlying the Funded Manuscripts,” a broader remit than the 2021 text.

    Three elements define the refresh:

    • Mandatory preprint deposit for every funded manuscript, in addition to the existing accepted-manuscript deposit requirement.
    • An earlier trigger for open data: data must now be accessible as soon as the preprint is available, not only once the accepted article is published.
    • Withdrawal of financial support for individual APC payments, shifting that cost onto grantees and co-authors.

    Why Did the Foundation Stop Paying APCs?

    The 2025 policy is unambiguous on this point: “The Foundation Will Not Pay Article Processing Charges (APC). Any publication fees are the responsibility of the grantees and their co-authors.” This is a change to support, not to what is mandated — grantees were never obliged to use the foundation’s APC funds under the 2021 policy, but many did, particularly for publishing in fully open-access journals listed in the Directory of Open Access Journals (DOAJ).

    The foundation frames this as part of a wider push against the gold-OA/APC model, which critics argue rewards well-resourced authors while pricing out others. Rather than underwriting per-article fees, it says it will back non-APC routes to open publishing, including its own Gates Open Research platform and select publisher partnerships covering Gates-funded authors outside the standard APC mechanism.

    The practical effect falls unevenly. Per an analysis by Lisa Janicke Hinchliffe in The Scholarly Kitchen (15 April 2024), Gates grantees publish roughly 4,000 papers a year — about 0.07% of articles published globally — so the aggregate revenue impact on any single open-access publisher is likely modest, even though the effect on individual grantees lacking alternative funding can be significant.

    What Does the New Preprint-First Mandate Require?

    Every Funded Manuscript must now be “published as a preprint in a preprint server recognized by the foundation” that applies sufficient scrutiny, carrying a CC BY 4.0 licence or equivalent. This sits alongside — not instead of — the existing requirement that the accepted manuscript be deposited “immediately upon publication in PubMed Central (PMC), or in another openly accessible repository, with proper metadata tagging identifying Gates funding.”

    Two details matter for compliance teams:

    • Grantees can self-exempt from the preprint requirement where they determine “a preprint is not appropriate due to ethical, safety or other legitimate concerns” — the foundation has not yet published criteria for what counts.
    • The foundation is not mandating a single preprint server. It has said it will point grantees to ASAPbio’s preprint server directory rather than maintain its own list, though it separately partnered with Taylor & Francis/F1000 to launch VeriXiv, a verified preprint platform grantees may optionally use.

    Copyright-retention language is essentially unchanged: grantees must retain enough copyright to deposit and licence the manuscript CC BY 4.0, and include a foundation-mandated acknowledgement and rights-retention statement.

    How Does Gates Compare With Other cOAlition S Funders?

    The Gates Foundation is not the only cOAlition S member re-examining its terms, but it is the first founding funder to formally withdraw central APC funding. Wellcome Trust and UK Research and Innovation (UKRI), the two other funders most closely associated with Plan S’s origins, still fund publication fees through institutional block-grant mechanisms rather than the pay-per-article support the Gates Foundation has now dropped.

    Funder Current policy effective date Pays APCs? Preprint requirement
    Gates Foundation 1 January 2025 (refresh) No — discontinued for individual manuscripts Mandatory, narrow ethical/safety exemption
    Wellcome Trust 1 January 2021 Yes — via institutional block grants Encouraged, not mandated
    UKRI 1 April 2022 (journal articles); 1 January 2024 (monographs) Yes — via block grant to research organisations Not mandated
    cOAlition S / Plan S baseline Founding principles from 2018 Funder-dependent; no central APC cap post-2024 Not centrally mandated; Rights Retention Strategy supported

    cOAlition S has been diplomatic about the change. Responding to the refresh, Executive Director Johan Rooryck said: “Five years on since Plan S was first published, it is entirely appropriate that funders are reviewing their OA policies to ensure they are effectively meeting their goals… Our collective dedication to making full and immediate OA a reality remains the driving force behind our collaboration.” Separately, Rooryck told Nature the refreshed policy is not “entirely in line” with cOAlition S guidance, while noting member funders retain “a lot of leeway” in how they implement shared principles. The Scholarly Kitchen nonetheless judges the policy relatively well aligned with Plan S’s repository route, since the accepted-manuscript deposit mandate — the mechanism that satisfies Plan S compliance — is retained, not replaced.

    Common Questions About the Gates Foundation Open Access Policy

    Does the Gates Foundation still pay APCs?

    No. Since the 2025 Open Access Policy took effect on 1 January 2025, the Bill & Melinda Gates Foundation no longer pays article processing charges for individual manuscripts. Publication fees are now the responsibility of grantees and co-authors, though the foundation continues to fund open infrastructure and select publisher arrangements.

    Does the Gates Foundation require preprints?

    Yes. Under the 2025 policy, every funded manuscript must be posted as a preprint on a foundation-recognised server carrying a CC BY 4.0 licence, in addition to the existing requirement to deposit the accepted manuscript in PubMed Central or another open repository. Grantees may seek an exemption only for documented ethical or safety concerns.

    Is the Gates Foundation still aligned with Plan S?

    Largely, yes. cOAlition S publicly welcomed the 2025 refresh, and analysts judge the policy broadly consistent with Plan S‘s repository route despite the APC-funding withdrawal. Executive Director Johan Rooryck said the update reflects funders “reviewing their OA policies,” while stopping short of declaring it fully in line with coalition guidance.

    What are the Gates Foundation’s data-sharing requirements?

    The 2025 policy requires underlying data to be openly accessible immediately once the funded manuscript becomes available — including at the preprint stage. This is earlier than the 2021 policy, which triggered the data-sharing mandate only once the accepted article was formally published in a journal.

    Implications and What to Watch Next

    For grantees without alternative funding, the squeeze is real: authors who relied on Gates APC support for DOAJ-listed open-access journals must now find a fee waiver, an institutional agreement, or a non-APC venue, while still meeting deposit and rights-retention requirements some publishers only accommodate via paid gold-OA routes. Research administrators managing multi-funder compliance will need to track this alongside UKRI and Wellcome Trust obligations, since the three funders no longer follow a uniform APC-support model despite shared Plan S origins.

    For publishers, immediate revenue exposure looks limited given the modest volume of Gates-funded output, but the policy adds pressure toward non-APC business models — waiver programmes, “pure publish” institutional agreements, and preprint-native platforms — that cOAlition S’s own “Beyond Article-Based Charges” working group, established with Jisc and PLOS, is separately examining.

    The signal for other funders is the more consequential story. Gates is the first cOAlition S founding member to formally withdraw central APC funding while retaining a Plan S-compatible repository mandate. Whether Wellcome Trust, UKRI, or other coalition funders follow with funding recalibrations — rather than eligibility or embargo changes — is the development worth monitoring as institutions plan multi-year compliance budgets.

    Research administrators managing multi-funder open access compliance can find related standards context in CASRAI’s research administration resources.

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

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

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

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

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

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

    How Wellcome aligns with — and adds to — Plan S

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

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

    Where Wellcome diverges from REF 2029’s open access rules

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

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

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

    Data sharing and rights retention: Wellcome’s additional layer

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

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

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

    Frequently asked questions

    Does Wellcome allow any embargo on open access articles?

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

    Is Wellcome Trust a Plan S funder?

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

    Do REF 2029 open access rules apply to monographs?

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

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

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

    Implications for institutions and researchers

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

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