# Funder Open Access Mandates ## Quick Answer - Verify journal compliance before submission by checking the journal's open access policy against your funder's specific mandate, including embargo periods and repository requirements. - Use funder-approved journal finders and repository directories to confirm a journal meets your obligations, then document your verification for your records. - Compliance is not permanent, so recheck policies at submission and acceptance, since funder mandates and journal policies change over time. ## Understanding Funder Open Access Mandates Funder open access mandates are policy requirements that research funders place on grant recipients. These policies dictate how the peer-reviewed articles resulting from funded research must be made publicly available. The core requirement across most mandates is that the final published version or the accepted manuscript must be accessible to readers without a subscription, typically within a specified time frame. The two most prominent mandate systems that researchers in the United States will encounter are the National Institutes of Health (NIH) Public Access Policy and the coalition of European funders known as Plan S. The NIH policy applies to all peer-reviewed articles that arise from NIH funding, and it requires that those articles be deposited in the National Library of Medicine's PubMed Central repository. The NIH Grants and Funding portal provides the official context for understanding how these requirements attach to grant awards and what researchers must do to remain compliant. Plan S operates differently. It is an initiative supported by a coalition of national research funders and charitable organizations, primarily in Europe. Plan S requires that funded research be published in compliant journals or platforms that allow immediate open access, or that the research be deposited in an approved repository without any embargo. The practical effect is that researchers funded by Plan S signatories cannot publish in subscription journals that do not offer a compliant open access option. The stakes for noncompliance are concrete. Funders can withhold final grant payments, exclude researchers from future funding opportunities, and in some cases require corrective action before a grant is closed out. For a researcher, this means that journal selection is also a matter of prestige or fit. It is a compliance decision that carries financial and professional consequences. ## At a Glance: Major Mandate Requirements | Funder System | Key Requirement | Embargo Allowance | Repository Requirement | | --- | --- | --- | --- | | NIH Public Access Policy | Deposit final peer-reviewed manuscript or published article | Up to 12 months after publication | PubMed Central | | Plan S (cOAlition S funders) | Immediate open access or zero-embargo repository deposit | None permitted | Approved repository or compliant journal | | Institutional policies | Varies by university or research organization | Varies, often 6 to 12 months | Institutional repository or subject repository | The table above shows the structural differences between the major mandate systems. NIH allows a maximum embargo period of 12 months, during which the article may remain behind a paywall before it must be freely available in PubMed Central. Plan S permits no embargo at all, which means the article must be openly accessible at the time of publication. Institutional policies, which many universities maintain independently of funder mandates, typically fall somewhere between these two extremes. ## How Funder Mandates Affect Journal Selection Journal selection becomes a compliance exercise when you have funder obligations. The first step is to identify which mandates apply to your research. A single project may have multiple funders, and each funder may have different requirements. When mandates conflict, the most restrictive requirement generally governs your compliance obligations. The practical questions you must answer for each candidate journal are straightforward. Does the journal offer an open access option that meets your funder's requirements? If the journal is subscription-based, does it allow deposit of the accepted manuscript in the required repository? What embargo period does the journal impose on repository deposits? Does the journal charge an article processing charge (APC) for open access, and does your funder allow APC costs as an allowable grant expense? These questions require you to read the journal's policies directly instead of relying on third-party descriptions. Journal websites typically publish their open access policies in their author guidelines or in a dedicated open access section. The policies should state whether the journal is fully open access, hybrid, or subscription-only, and they should specify the allowed embargo periods for repository deposit. The Committee on Publication Ethics Core Practices provide a useful framework for evaluating journal integrity during this process. While the Core Practices focus on editorial and publication ethics, they also address transparency in journal policies. A journal that clearly documents its open access terms and adheres to stated policies is more likely to be a reliable compliance partner than one with vague or contradictory statements. ## Using Journal Finders and Compliance Tools Several tools exist to help researchers identify journals that comply with specific funder mandates. The NIH maintains a journal selection resource that allows authors to check whether a journal is indexed in PubMed Central and whether it automatically deposits articles on behalf of authors. This is a critical distinction because some journals handle the deposit process themselves, while others require the author to initiate the deposit. For Plan S compliance, the cOAlition S funders maintain a Journal Checker Tool that allows researchers to enter a journal name and their funder to determine whether the journal is compliant. The tool draws on data about journal open access models, embargo periods, and repository participation. It provides a clear yes or no answer for each combination of journal and funder. The EQUATOR Network serves a different but complementary function. While it does not check funder compliance, it provides access to reporting guidelines that many journals require or recommend. When you are evaluating a journal, you should verify that it endorses the relevant reporting guideline for your study type. A journal that requires adherence to reporting guidelines is generally more transparent about its editorial and publication practices, which reduces the risk of encountering unexpected policy barriers at the acceptance stage. ## Practical Workflow for Verifying Compliance The following workflow provides a systematic approach to verifying funder compliance before you submit your manuscript. ### Step 1: Document Your Funder Obligations Start by reading the official policy documents from each funder that supports your research. For NIH-funded work, the NIH Grants and Funding portal provides the authoritative policy text and any updates. For Plan S funders, the cOAlition S website provides the implementation guidance. Record the specific requirements that apply to your project, including embargo limits, repository requirements, and any license requirements. ### Step 2: Screen Candidate Journals Create a shortlist of journals that are appropriate for your research topic and quality standards. For each journal, visit its official website and locate the open access policy. Record the journal's open access model, its APC or other fees, its embargo policy for repository deposit, and whether it offers automatic deposit to PubMed Central or other repositories. ### Step 3: Run Compliance Checks Use the funder-specific tools to verify your findings. For NIH compliance, check whether the journal is listed in the NIH journal selection resource. For Plan S compliance, use the Journal Checker Tool. Record the results of each check, including the date you performed the verification. ### Step 4: Assess Repository Compatibility Confirm that the journal's deposit policy is compatible with the repository your funder requires. For NIH, this means the journal must allow deposit in PubMed Central within the permitted embargo window. For Plan S, the journal must allow immediate deposit in an approved repository. Some journals have policies that appear compliant on the surface but contain restrictions on the version that may be deposited or the license that may be applied. ### Step 5: Document Your Verification Keep a compliance record for each manuscript. This record should include the funder policy requirements, the journal's stated policies, the results of any compliance checks, and the date of verification. This documentation is valuable if questions arise during grant closeout or if you need to demonstrate compliance to your institution's research office. ## Records and Measurements for Compliance Tracking Maintaining accurate records is essential for demonstrating compliance with funder mandates. The following records should be maintained for each funded manuscript. | Record Type | What to Track | When to Update | | --- | --- | --- | | Funder policy summary | Embargo limits, repository requirements, license requirements | At grant award and when policies change | | Journal policy log | Open access model, APC, deposit rights, embargo period | At journal selection and at acceptance | | Compliance check results | Tool used, date checked, outcome | At submission and at acceptance | | Deposit confirmation | Repository name, deposit date, article version deposited | At deposit and at publication | The NIH Data Management and Sharing Policy adds another layer of record-keeping for NIH-funded research. While this policy focuses on data instead of publications, it requires researchers to plan for data sharing and to document their data management practices. The policy is relevant to open access compliance because many journals now require a data availability statement, and funders may check that the data supporting a publication is accessible. ## Common Failure Patterns in Funder Compliance Researchers encounter several recurring problems when trying to comply with funder mandates. Understanding these failure patterns can help you avoid them. ### Assuming Journal Claims Are Accurate A journal may describe itself as open access or NIH-compliant without actually meeting the funder's technical requirements. The journal's self-description is not authoritative. You must verify compliance through the funder's official tools or by reading the journal's deposit agreement carefully. ### Missing the Embargo Calculation Embargo periods are calculated from the date of publication, not from the date of acceptance or the date of online posting. If a journal posts articles online ahead of print, the embargo clock may start earlier than you expect. This can result in a compliance violation if the embargo period is calculated incorrectly. ### Overlooking the Accepted Manuscript Requirement Some funders require deposit of the final published version, while others accept the accepted manuscript. The accepted manuscript is the version that has passed peer review but has not yet undergone copyediting and typesetting. If your funder requires the published version and the journal does not provide it for deposit, you may face a compliance gap. ### Ignoring License Requirements Funder mandates often specify the license that must be applied to the deposited article. The most common requirement is a Creative Commons Attribution license, which allows broad reuse with attribution. If the journal applies a more restrictive license, the deposit may not satisfy the funder's requirements even if the article is openly accessible. ### Failing to Recheck at Acceptance Journal policies can change between the time you submit a manuscript and the time it is accepted. A journal that was compliant at submission may have changed its open access model or its deposit policy by acceptance. Recheck compliance at every milestone in the publication process. ## Welfare and Safety Context for Research Publication The open access compliance process intersects with research integrity in ways that affect the welfare of research participants and the safety of research communities. Transparent reporting is a core component of ethical research publication, and the EQUATOR Network provides reporting guidelines that support this transparency. When you select a journal, you should verify that it endorses the relevant reporting guideline for your study design. This endorsement indicates that the journal expects authors to report their methods and results completely, which supports the reproducibility of research. The Committee on Publication Ethics Core Practices address the responsibilities of journals in maintaining research integrity. These practices cover authorship, peer review, data access, and the handling of misconduct allegations. A journal that follows these practices provides a safer environment for your research to be evaluated fairly and published without ethical complications. For research involving animals, the welfare context is particularly important. Journals that follow ethical publication practices typically require authors to confirm that their research complied with animal welfare regulations and that the study was approved by an institutional animal care and use committee. The open access mandate does not change these requirements, but it does mean that the published article will be more widely accessible, which increases the scrutiny applied to the research methods and welfare documentation. ## Professional Escalation Criteria There are situations where you should escalate a compliance concern to a professional instead of attempting to resolve it yourself. The following criteria indicate when escalation is appropriate. ### Institutional Research Office Involvement If you are uncertain about whether a journal meets your funder's requirements, or if you receive conflicting information from the journal and the funder, contact your institution's research office or sponsored programs office. These offices have experience with funder compliance and can provide authoritative guidance. ### Funder Contact for Ambiguous Policies If the funder's policy text is ambiguous or if you cannot determine how it applies to your specific situation, contact the funder directly. Funders maintain staff who answer policy questions from grantees. Document the response you receive, including the name of the person who provided it and the date. ### Legal Review for Complex Agreements If a journal's publishing agreement contains terms that appear to conflict with your funder obligations, or if the agreement requires you to transfer rights that would prevent compliance, seek review from your institution's legal office or a qualified attorney. Publishing agreements are legally binding contracts, and you should not sign one that creates a compliance conflict. ### Ethics Consultation for Publication Misconduct If you suspect that a journal is engaging in deceptive practices, such as misrepresenting its open access status or failing to honor its stated deposit policies, report the concern to the Committee on Publication Ethics or to your institution's research integrity office. These bodies can investigate and take action against journals that violate publication ethics. ## Limitations of Compliance Verification Compliance verification has inherent limitations that you should understand before relying on any tool or policy reading. ### Tools Reflect Current Data Journal compliance tools rely on data that may not be current. A journal may have changed its policies without the tool being updated. Always confirm tool results by reading the journal's official policies directly. ### Policies Are Subject to Change Funder policies change over time. The NIH periodically updates its public access policy, and Plan S implementation has evolved since its initial announcement. You must verify that you are reading the current version of any policy. ### Journal Policies Can Be Complex A journal's open access policy may have different terms for different article types, funding sources, or submission routes. A policy that appears compliant for one scenario may not be compliant for another. Read the full policy text instead of relying on summaries. ### International Variations Apply Funder mandates vary by country and by funding organization. A policy that applies to a European funder may not apply to a US funder, and vice versa. You must identify the specific mandates that apply to your funding sources instead of assuming a universal standard. ## Building a Journal Compliance Decision Matrix A practical decision matrix helps you move from general compliance knowledge to a specific journal choice. This framework converts the abstract requirements of funder mandates into a structured comparison that you can apply consistently across multiple candidate journals. The matrix works alongside the verification workflow by giving you a scoring system for ranking journals against your specific funder obligations. ### Constructing the Decision Matrix Create a table with one row for each candidate journal and columns for the compliance factors that matter for your funding situation. The core columns should include the journal's open access model, the version of the article you may deposit, the permitted embargo period, the repository options, the license requirements, and the article processing charge. Add a column for the verification date and the tool you used to confirm each factor. For each column, assign a status of compliant, noncompliant, or uncertain. A journal that allows deposit of the accepted manuscript in PubMed Central within 12 months receives a compliant status for NIH-funded work. A journal that requires exclusive copyright transfer without a repository deposit exception receives a noncompliant status. A journal with unclear policy language receives an uncertain status, which means you must contact the journal or your institution's research office before proceeding. The matrix serves two purposes. First, it forces you to document each compliance factor explicitly instead of relying on a general impression of a journal. Second, it creates a permanent record that you can present to your institution or funder if questions arise about your journal selection process. ### Applying the Matrix to Mixed Funding Scenarios The matrix becomes especially valuable when your project has multiple funders with different requirements. A common scenario is a project funded by both NIH and a Plan S signatory. The NIH policy allows a 12 month embargo with deposit in PubMed Central. The Plan S policy requires immediate open access with no embargo. The most restrictive requirement governs your compliance obligations, which means you must select a journal that meets the Plan S standard. In this scenario, the decision matrix should include a column for each funder's requirements. A journal that is NIH compliant but not Plan S compliant receives a noncompliant status for the Plan S column, which disqualifies it from consideration. A journal that meets both standards receives a compliant status in both columns and moves forward in your evaluation. The matrix also helps you identify partial compliance situations. Some journals offer a hybrid model where you can pay an article processing charge to make your specific article open access immediately. This option may satisfy Plan S requirements even if the journal's default model is subscription based. The matrix should capture these nuances by recording the specific open access options available to you instead of only the journal's default model. ### Weighting Compliance Factors by Risk Not all compliance factors carry equal weight. The embargo period and repository requirements are hard constraints that determine whether you can comply with your funder at all. The article processing charge is a financial consideration that affects your budget but does not determine compliance. The license requirement sits in between because some funders mandate a specific license while others accept any open license. Assign weights to each factor based on your funder's policy language. A factor that appears in the funder's mandatory requirements receives the highest weight. A factor that appears as a recommendation or an allowable option receives a lower weight. This weighting helps you distinguish between journals that are truly compliant and journals that are merely compatible with your preferences. For example, the NIH Public Access Policy requires deposit in PubMed Central. This is a mandatory requirement, so the repository column receives maximum weight in your matrix. The policy does not mandate a specific license, so the license column receives lower weight unless your institution has its own policy. The Committee on Publication Ethics Core Practices emphasize transparency in journal policies, which supports your use of a structured matrix because it documents your due diligence in evaluating each journal. ### Recording Matrix Results for Grant Closeout Your completed decision matrix becomes part of your compliance documentation. Store it with your other grant records, including your data management plan and your publication agreements. The NIH Data Management and Sharing Policy requires you to document your data sharing practices, and your journal selection documentation serves a parallel function for publication compliance. Update the matrix at each publication milestone. A journal that was compliant at submission may change its open access model before your article is accepted. Recheck each factor and update the verification date. If a journal's status changes from compliant to noncompliant, you must either negotiate a different arrangement with the journal or select a different journal for your work. The matrix also supports conversations with your institution's research office. When you request guidance on a journal with uncertain compliance status, the matrix gives the research office a clear picture of the specific factors that concern you. This targeted approach is more productive than asking a general question about whether a journal is compliant. ### Common Matrix Errors to Avoid The most common error is treating the matrix as a one time exercise. Journal policies and funder requirements change, and your matrix must reflect those changes. Set a reminder to review your matrix at submission, at acceptance, and before you sign the publishing agreement. Another error is relying on the journal's self reported compliance status without independent verification. A journal may describe itself as compliant with a funder mandate without meeting the technical requirements. Use the funder's official tools to confirm each factor in your matrix. The EQUATOR Network provides reporting guidelines that can help you evaluate whether a journal follows transparent practices, which reduces the risk of encountering hidden policy barriers. A third error is ignoring the interaction between compliance factors. A journal may allow repository deposit but impose a license that your funder does not accept. The matrix must capture these interactions by requiring a compliant status in every mandatory column. A journal that meets all but one mandatory requirement is still noncompliant and should not receive your manuscript. ## Frequently Asked Questions ### How do I know which funder mandates apply to my research? Review your grant award documents and the official policy pages of each funder that supports your project. The NIH Grants and Funding portal provides the authoritative policy for NIH-funded research. For other funders, consult their official websites and any policy documents referenced in your award agreement. ### What is the difference between the accepted manuscript and the published version? The accepted manuscript is the final version after peer review but before copyediting and typesetting. The published version is the version of record with journal formatting and pagination. Some funders accept either version for repository deposit, while others require the published version. Check your funder's policy to determine which version you must deposit. ### Can I publish in a subscription journal if my funder requires open access? Yes, in many cases, but the journal must allow deposit of the article in the required repository within the permitted embargo period. For NIH funding, the journal must allow deposit in PubMed Central within 12 months of publication. For Plan S funding, the journal must offer a compliant open access option or allow immediate repository deposit. ### What happens if I do not comply with my funder's open access mandate? Noncompliance can result in the funder withholding final grant payments, excluding you from future funding, or requiring corrective action. The specific consequences depend on the funder and the severity of the violation. Your institution's research office can advise you on the potential consequences for your situation. ### Does my funder pay for article processing charges? Many funders allow article processing charges as an allowable grant expense, but you must verify this in your grant terms and the funder's cost policy. Some funders have specific caps or require prior approval for APC costs. Check your award documents before committing to a journal that charges an APC. ### How do I deposit my article in PubMed Central? The NIH provides a manuscript submission system for authors to deposit their articles. Some journals deposit articles automatically on behalf of authors. Check whether your journal offers automatic deposit, and if not, use the NIH manuscript submission system to deposit the article within the required time frame. ### What is the Journal Checker Tool for Plan S compliance? The Journal Checker Tool is an online resource maintained by cOAlition S that allows researchers to enter a journal name and their funder to determine whether the journal is compliant with Plan S requirements. The tool provides a clear indication of whether the journal meets the funder's open access requirements. ### How often should I recheck journal compliance? Recheck compliance at every significant milestone in the publication process, including at submission, at acceptance, and before signing the publishing agreement. Journal policies and funder requirements can change at any time, and you are responsible for ensuring compliance at the time of publication. ## Related Articles - [Open Access Practices for Researchers: A Guide](/blog/guides/open-access-practices-for-researchers-a-guide) - [Open Science Practices: A Guide for Researchers](/blog/guides/open-science-practices-a-guide-for-researchers) - [Data Management Plan Template: A Practical Guide for Researchers](/blog/guides/data-management-plan-template-a-practical-guide-for-researchers) - [NSF Data Management Plan: Requirements and Writing Tips](/blog/guides/nsf-data-management-plan-requirements-and-writing-tips) - [Reference Managers for Researchers: Choosing a Workflow That Survives Collaboration](/blog/careers/reference-managers-for-researchers-choosing-a-workflow-that-survives-collaborati) ## References and Further Reading - [Research Methods Resources](https://www.ncbi.nlm.nih.gov/books). National Library of Medicine. - [EQUATOR Network](https://www.equator-network.org/). EQUATOR Network. - [Core Practices](https://publicationethics.org/core-practices). Committee on Publication Ethics. - [NIH Grants and Funding](https://grants.nih.gov/). National Institutes of Health. - [ORCID for Researchers](https://info.orcid.org/researchers). ORCID. - [Data Management and Sharing Policy](https://sharing.nih.gov/data-management-and-sharing-policy). National Institutes of Health. - [NCBI Literature Resources](https://www.ncbi.nlm.nih.gov/). National Center for Biotechnology Information. - [PubMed](https://pubmed.ncbi.nlm.nih.gov/). National Library of Medicine. > This article is educational and does not replace institutional policy, professional advice, or applicable safety and regulatory requirements.