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
• How Wellcome funds APC and open access costs
• Rights retention: the automatic CC BY clause
• How the policy predates and aligns with Plan S
• Common questions about Wellcome’s policy
• Implications for institutions and researchers
• Outlook

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.

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.

How the policy predates and aligns with Plan S

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.