For much of the last decade, the practical pathway to open access compliance has been straightforward if expensive: use grant money to pay the journal's article processing charge (APC), get the gold open access badge, satisfy your funder's mandate. Inconvenient, occasionally painful, but clear. That pathway is now narrowing from multiple directions at once. Three of the most influential research funders in the world have either capped, restricted, or entirely withdrawn their support for APC payments in the past year, and the changes arrived with enough overlap that many authors are still piecing together what applies to them.
This post covers the three distinct policies, what each one actually requires of funded researchers, what remains uncertain, and what options remain when your funder's open access mandate and its publication funding no longer point at the same journal.
The Core Tension
Open access mandates say you must make your paper freely available. APC caps and funding withdrawals say your funder will no longer pay for the gold open access route to get there. The answer is not to ignore the mandate. It is to understand which alternative routes satisfy compliance.
Why APCs Became a Problem Worth Capping
Article processing charges did not start out high. When gold open access was a niche model in the early 2000s, many fees were under $1,000 and some journals charged nothing at all. The period from roughly 2012 to 2024 changed that. Major publishers discovered that prestige could be monetized twice: first through library subscriptions, and then through APCs in hybrid journals that charged authors for open access inside a journal that libraries were already paying to access. Prices at the top end climbed well past what most grant budgets were designed to absorb.
By 2025, NIH data showed that authors were paying as much as $12,690 per paper to publish in Nature journals, with fees at other prominent titles clustering between $5,000 and $10,000. The global average APC across all journals was closer to $1,235, and the average across U.S.-based journals sat around $2,177, but those figures blur a vast range. Labs at well-resourced institutions with institutional agreements could absorb a $3,000 APC without discussion. Labs running on tight budgets, or researchers at smaller institutions without publisher deals, sometimes chose between lab consumables and publication fees. NIH noted in its July 2025 announcement that some grantees were forgoing equipment purchases or using personal funds to cover the gap.
That background explains why three funders moved in roughly the same direction within months of each other. None of them framed the change as opposition to open access. All of them framed it as a response to pricing that had outrun any reasonable relationship to the service being provided.
NIH's Proposed APC Cap: What Is Known and What Is Not
On July 8, 2025, NIH Director Jay Bhattacharya announced that NIH intended to establish new limits on how much of a grant award could be spent on publication costs. On July 30, NIH published a formal Request for Information (NOT-OD-25-138) outlining five options and invited public comment through September 15, 2025. The proposed effective date for any resulting policy was January 1, 2026.
The five options ranged considerably in how far they would restrict authors. The first would disallow all publication costs from grant awards entirely, placing NIH in the same position the Gates Foundation adopted in 2024. The second would set a hard per-publication cap of $2,000, roughly matching the average APC at U.S.-based journals and covering the fees at a large number of fully open access titles. The third would allow $3,000 per paper, but only at journals that compensate peer reviewers and make reviewer reports publicly available. The fourth would apply a flexible cap tied to grant size, set at either 0.8% of direct costs or a maximum of $20,000 over the award period, with a possible per-paper ceiling of $6,000. A fifth option, described more briefly, explored hybrid approaches mixing per-paper and portfolio limits.
The math behind the $2,000 cap option
- •A $2,000 cap would cover the APCs at approximately 162 journals, or about 7% of indexed titles.
- •A $3,000 cap would cover roughly 566 journals, or about 25% of titles.
- •Nature's APC is approximately $12,690. Springer Nature's flagship titles generally run $5,000 to $9,000.
- •PLOS ONE's APC sits around $1,999, which would fit within the lowest proposed cap.
- •Many fully OA society journals charge under $2,000, and some charge nothing (diamond OA).
What makes the NIH situation genuinely uncertain is that, as of this writing in May 2026, the final policy has not been formally announced. The comment period closed in September 2025, but NIH has not published a final notice specifying which option was adopted. Authors should treat the January 2026 effective date with caution. If your institution has NIH grants and your team is planning a submission to a journal with APCs above $3,000, it is worth confirming with your grants administration office whether any updated guidance has been circulated internally. University research offices have generally been tracking this more closely than individual investigators.
The broader signal from NIH is clear even before the final rule arrives: the agency considers high APCs an inefficient use of research funds, and some form of restriction is coming. Planning your publication pathway around journal fees that could exceed a future cap is a reasonable precaution now, not something to defer until the policy lands.
HHMI's Hybrid Journal Ban: In Effect Since January 2026
The Howard Hughes Medical Institute moved faster than NIH and with more clarity. Effective January 1, 2026, HHMI lab budgets may no longer be used to pay APCs at hybrid journals, defined as subscription journals that offer individual articles as open access for a fee while the rest of the content remains behind a paywall. APCs at fully open access journals, where every article is freely available, remain an allowable expense.
This distinction matters because many of the most-cited clinical and biomedical journals are hybrids. The New England Journal of Medicine, JAMA, The Lancet, and BMJ are all subscription-based journals that offer authors an open access option at a significant APC. Under HHMI's January 2026 policy, investigators on HHMI awards cannot use their lab budgets to pay those fees. They can still publish in those journals. They cannot pay for the gold OA option using HHMI funds.
HHMI's open access mandate, which the organization updated in 2022, still requires that all HHMI-funded research be freely available immediately upon publication with a CC BY license. The hybrid ban does not eliminate that requirement. It means authors now have to satisfy it through a different mechanism, typically a green OA deposit in a public repository, or by choosing a fully OA journal from the start. This matches the position that Wellcome Trust adopted for its own grantees in January 2025, when Wellcome stopped covering hybrid APCs for newly funded grants.
If you are an HHMI-funded researcher as of January 2026
- You cannot use HHMI lab funds to pay the gold OA APC at hybrid journals such as NEJM, JAMA, Lancet, or BMJ.
- You can still submit to and publish in those journals; you simply cannot pay for the open access option from your HHMI award.
- Your OA compliance obligation still applies. The green OA route (accepted manuscript deposited in Europe PMC or PubMed Central, CC BY) satisfies the HHMI mandate.
- Fully OA journals remain eligible for APC support from your award budget.
- If you have co-funding from another source (an R01, an institutional fund), that separate funding may still be usable, subject to that funder's own policies.
Cancer Research UK: Full Withdrawal Starting April 2026
Cancer Research UK announced in April 2026 that it would cease all financial support for open access publication costs. From April 1, 2026, CRUK stopped funding new APC payments, including through block grants that it had previously provided to institutions to cover publication fees. All CRUK financial support for APCs ends entirely on October 1, 2026, which gives researchers currently in the submission pipeline a transitional window but not a long one.
The rationale CRUK gave was sustainability. Most of the growth in open access publishing over the past decade occurred in hybrid journals, where publishers collected both subscription revenue and per-article APCs. CRUK concluded that this model was not producing genuine open access at a defensible price. The charity estimated its decision would save approximately £5.2 million over three years. That number should be read as a measure of how much was being spent on a model the organization had decided no longer served its mission.
CRUK-funded researchers still have an open access obligation. Their papers must be made freely available under a CC BY license within six months of publication. The mechanism for meeting that obligation shifts entirely to the green OA route: deposit the accepted manuscript in Europe PMC (CRUK's designated repository), observe the six-month embargo on that deposit, and the compliance requirement is satisfied. The published version may sit behind a journal paywall for that period. The free-to-read version on Europe PMC provides the route to compliance.
The practical implication is that CRUK-funded cancer researchers who previously defaulted to gold OA now need to confirm their target journal's green OA policy before submission. Most major oncology journals, including Annals of Oncology, Cancer Research, and The Lancet Oncology, permit deposit of the accepted manuscript with an embargo that aligns with or is shorter than the six-month CRUK requirement. But some journals impose longer embargoes or restrict which version can be deposited, and discovering that incompatibility at the point of acceptance rather than at the planning stage creates real pressure.
The Pattern Behind the Three Decisions
NIH, HHMI, and CRUK are not coordinating their policies. They arrived at similar positions by separate routes. What they share is a common frustration with the economics of hybrid open access, where publishers collected author fees on top of library subscriptions without passing proportionate benefit to either readers or funders. This model worked for publishers. It was less clearly beneficial to funders who wanted research to be freely available and found themselves paying premium prices for access that libraries could already provide.
The Gates Foundation moved in this direction in 2024, disallowing APC payments from its grants entirely. Wellcome stopped covering hybrid APCs for new grants in January 2025. UKRI ended support for transformative journal agreements in December 2024. The trend has been visible for roughly eighteen months. What makes 2026 different is the inclusion of NIH, which funds a larger share of global biomedical research than any of the others, and the escalation from restricting hybrid APCs to questioning whether any APC above a moderate threshold is a defensible research expense.
This does not mean the APC model is dying. Fully OA journals with reasonable fees remain an acceptable publishing pathway under all of the above policies. What is under pressure is the hybrid premium, the $8,000 to $12,000 fee that lets a paper appear in a subscription journal with an open access badge.
What Routes Remain Open to Authors
The narrowing of APC funding does not mean you are forced to choose between compliance and publication in selective journals. It means the compliance pathway requires more planning than writing a check. Several routes remain, and understanding which ones apply to your situation before you submit saves considerable trouble later.
Green open access is the most universal fallback. Almost all major journals now allow deposit of the accepted manuscript (not the formatted PDF) in a public repository after some embargo period. For NIH-funded research, PubMed Central is the designated repository and the NIH public access policy requires deposit regardless of whether you paid for gold OA. For HHMI and CRUK, Europe PMC is the designated repository. Checking the journal's self-archiving policy (the SHERPA/RoMEO database is a reasonable first lookup) before submission should be a standard part of journal selection for any author with an OA mandate.
Institutional read-and-publish agreements, called transformative agreements, are a second route that many authors overlook because they are negotiated at the library level rather than the author level. Under these agreements, a university pays a publisher a bundled fee covering both reading access and open access publication for affiliated authors. If your institution has an agreement with, for example, Springer Nature, Wiley, or the American Chemical Society, you may be eligible to publish gold OA in that publisher's journals at no direct cost from your grant. The eligibility, coverage, and author caps vary by agreement. Your library or research office typically maintains a list of current agreements and how to claim the OA benefit.
Diamond open access is a third option that has grown considerably in medical publishing. Diamond OA journals charge neither authors nor readers. They are sustained by learned societies, institutional consortia, or national funding bodies. The quality range is wide, as it is across all journal categories, but several high-quality diamond OA journals exist in medicine, public health, and the biomedical sciences. The DOAJ (Directory of Open Access Journals) and the OpenDOAR registry are reasonable starting points for identifying options in a given field.
APC waiver programs
Many publishers offer fee waivers for authors who can demonstrate financial hardship or who are affiliated with institutions in low- and middle-income countries. Springer Nature, Wiley, and PLOS all have formal waiver programs. The process varies. Some require a waiver request before submission. Others ask you to indicate financial hardship in the submission system. A few decide case by case after acceptance. If you are considering a high-APC journal and your funder no longer covers fees at that level, contacting the editorial office directly and asking about waiver eligibility before you submit is not an unusual request and will not affect how your manuscript is handled.
Preprint servers are a separate but related consideration. Posting to bioRxiv, medRxiv, or a relevant preprint server does not satisfy most OA mandates on its own, because preprints are not peer-reviewed publications. But preprint posting does ensure your findings are accessible immediately, which serves the underlying purpose of OA while your peer-reviewed paper moves through review. Some funder policies are beginning to recognize preprints as part of compliance, but they are not yet a full substitute in most frameworks.
Journal Selection in the Age of APC Constraints
The practical effect of funder APC restrictions is that journal selection can no longer be separated from publishing budget planning. Authors have always had to think about scope, audience, and acceptance likelihood. Now the cost structure of a target journal is a concrete constraint rather than a nuisance to deal with at the end. A study funded by NIH, HHMI, or CRUK that is destined for a journal with a $9,000 APC needs a clear answer to the question of how that APC will be covered before the corresponding author clicks submit.
This does not mean high-APC journals are off the table. It means the funding source for those fees needs to be identified in advance. If your institution has a transformative agreement with that publisher, the fee may be covered institutionally. If the journal has a green OA policy compatible with your funder's embargo requirements, you may not need to pay any APC at all. If neither of those applies, and your funder's policy either caps or disallows that fee level, you need a different journal.
It is also worth noting that this situation creates a modest equity dimension. Labs at large, well-resourced research universities are far more likely to have institutional agreements that cover APCs at major publishers. Labs at teaching hospitals, smaller research institutions, or international universities are more likely to face the full APC out of pocket. If your funder's new cap or restriction effectively limits the journals accessible through grant funding to those with fees under $2,000 to $3,000, the researchers most affected are those without the institutional infrastructure to bridge the gap. That is worth factoring into how you think about the policy beyond your own immediate situation.
Steps to Take Now
The most useful thing to do immediately is to confirm exactly what your primary funder currently permits. If you are NIH-funded, check with your grants administration office for the most current guidance on allowable publication costs, since the final NIH APC policy may have been released after this post was written. If you are HHMI-funded, the hybrid journal ban is in effect and the answer is clear. If you are CRUK-funded, APC support ended April 1, 2026 for new submissions.
Next, check whether your institution has transformative agreements with your target publishers. Most research libraries maintain a list, and many have set up self-service portals where authors can check eligibility by ORCID or institutional affiliation. If an agreement exists, read the coverage details. Agreements typically have caps on the number of articles per year and may cover only certain journals within a publisher's portfolio.
If neither of the above resolves the funding question for a high-APC journal, check the journal's self-archiving policy and compare it against your funder's embargo requirements. SHERPA/RoMEO is the standard database for this lookup. If the journal's permitted embargo matches your funder's compliance window, the green OA route closes the gap at no author cost.
Finally, if you are early enough in the research process to affect study planning, consider building journal selection into your data management and sharing plan. Knowing in advance where you intend to publish, and confirming that the funding pathway is clear, prevents the situation where a study completes, the corresponding author selects a journal on scientific grounds, and the team discovers two weeks before submission that no one has a clear answer to how the APC will be paid.
What Authors Should Watch in the Coming Months
The NIH final policy notice is the most immediately consequential thing to watch. When it arrives, it will specify which of the five proposed options was selected, whether the effective date remained January 1, 2026 or shifted forward, and what transition provisions apply to grants awarded before the policy took effect. Checking the NIH Grants Policy Statement page and the NIH Office of Extramural Research update notices is the reliable way to stay current. University research offices will almost certainly circulate internal guidance when the final rule is published.
Beyond NIH, it is reasonable to expect further movement from funders who have not yet moved. Major medical research funders in Germany, France, and the Netherlands have been active in OA policy but have not yet announced APC caps in the same terms as NIH and HHMI. The argument for some form of restriction has become considerably harder to counter now that two of the largest U.S. funders have framed high APCs as a research efficiency problem rather than a desirable publishing option.
For authors, the takeaway is straightforward even if the policy details are still settling. The assumption that open access publishing means paying a large APC from your grant is no longer safe. The infrastructure for alternatives, institutional agreements, green OA, diamond OA, and preprints, is more developed than it was five years ago. Using that infrastructure requires knowing it exists and checking whether it applies to your situation before your paper is accepted, not after. That is the adjustment the 2026 funder landscape is quietly demanding of most active researchers.
Further Reading
Open Access Mandates in 2025: NIH, Wellcome, and UKRI
The access-side requirements from major funders, and what they mean for your submission route.
Article Processing Charges: Complete Guide to Open Access Fees
Typical APCs by field, how institutional agreements work, and where to find waivers.
Open Access vs Traditional Publishing
Understanding the models behind gold, green, hybrid, and diamond OA.
How to Choose the Right Journal
Integrating cost, scope, and compliance into a workable journal selection process.
Written by Dr. Meng Zhao
Physician-Scientist · Founder, LabCat AI
MD · Former Neurosurgeon · Medical AI Researcher
Dr. Meng Zhao is a former neurosurgeon turned medical-AI researcher. After years in the operating room, he moved into applied AI for clinical workflows and now leads LabCat AI, a medical-AI company working on decision support and research tooling for clinicians. He built Journal Metrics as a free resource for researchers who need reliable journal metrics without paid database subscriptions.
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