Open Access Mandates in 2025: What NIH, Wellcome, and UKRI Now Require

For most of the past decade, open access felt optional to many biomedical researchers. If your funder required it, you found a way. If they did not, you submitted to the journal that made the most sense scientifically and left the access question for after acceptance. That situation has changed. Three of the largest public and charitable funders of biomedical research have now moved from preference to firm requirement, and the timeline for compliance has shifted from “before we close your grant” to “immediately upon publication.”

The changes are not all new, but several took effect within the past twelve months, and their combined effect is significant. The NIH eliminated its 12-month embargo window on July 1, 2025. Wellcome Trust stopped funding article processing charges in hybrid journals as of January 1, 2025. UKRI closed access to block grant funding for transformative journals at the end of December 2024. Each change, taken alone, is manageable. Together, they mean that a large share of biomedical researchers now have funder requirements that effectively constrain which journals are viable submission targets.

This guide goes through each policy in practical terms, then explains what the combined effect means for journal selection, article processing charges, and the pre-submission decisions that matter most.

Why Funders Are Moving Toward Immediate Open Access

The argument for open access has been straightforward for years: research paid by the public should be accessible to the public. What shifted the timeline for policy enforcement was a combination of preprint adoption, pandemic-era experience, and political pressure. When COVID-19 research needed to move quickly in 2020, the biomedical publishing community demonstrated, faster than anyone expected, that immediate public access was technically feasible. Preprints on bioRxiv and medRxiv were shared within days of submission. Many journals expedited peer review and waived embargoes for pandemic-related manuscripts. That emergency created a precedent that advocates then used to push for permanent policy change.

The cOAlition S initiative, launched in 2019 by a group of European research funders with support from the European Commission, established Plan S as the coordinating framework. Plan S requires that all research funded by participating organizations be published in or transferred to fully open access journals or platforms without embargo. While Plan S's original target of 2020 slipped through negotiations with publishers, its core demand, immediate OA without embargo, has since been adopted by each of the major funders discussed here. The terminology differs by funder, but the practical requirement converges.

The other driver is growing dissatisfaction with the hybrid journal model. Hybrid journals, which are subscription-based publications that allow individual articles to be made open access for a fee, were the dominant compliance route during the transition period. Funders paid those fees, but the fees were high, the underlying journals remained paywalled for most content, and publishers effectively collected subscription revenue and open access revenue simultaneously. The term for this practice is “double dipping.” Major funders decided around 2024 and 2025 that they were no longer willing to fund it, which is why the hybrid journal route has narrowed so sharply.

The NIH Change: No More 12-Month Embargo

The NIH Public Access Policy has required that NIH-funded manuscripts be deposited in PubMed Central since 2008. What changed on July 1, 2025, was the embargo. Under the previous policy, publishers could delay public access to deposited manuscripts for up to 12 months after publication. That delay was widely used. Many subscription journals routed NIH-funded manuscripts into PMC but kept them locked behind the publisher's paywall for a year before making the PMC version public. The revised policy removes that option entirely.

For any manuscript accepted on or after July 1, 2025, the Author Accepted Manuscript must be submitted to PubMed Central immediately upon acceptance for publication, and the PMC version must be made publicly available without any embargo on the official date of publication. Not 12 months later. Not 6 months later. On publication day.

A few practical points follow from this. First, disclosing NIH funding to the publisher at the time of submission matters more than it used to. If a publisher does not know your work is NIH-funded when you submit, they may not route the manuscript through the NIH Manuscript Submission (NIHMS) system or arrange compliant PMC deposit. Make the disclosure explicit in your cover letter and in any submission system checklist fields. Second, read your author agreement before you sign it. Some agreements include language that grants the publisher exclusive rights that would prevent PMC deposit or impose delays. NIH guidance is clear that authors should retain the rights necessary for compliance. If the standard agreement conflicts with NIH policy, the agreement needs to be modified. Major publishers have standard addenda to handle this, and most will provide one on request.

Third, submitting to PMC does not cost authors anything. NIH explicitly states that fees charged by publishers for AAM deposit to PMC are not allowable under the policy. If a publisher tries to charge for this step, that cost is not your responsibility and is not covered by NIH funds. The deposit route through NIHMS is free. Finally, compliance tracking is through My Bibliography in your MyNCBI account. NIH ties compliance status to grant renewals and progress reports, and the agency has indicated that non-compliance can affect future funding decisions for researchers and their institutions.

Most large publishers, including Elsevier, Springer Nature, Wiley, and Oxford University Press, have existing NIHMS deposit agreements and route manuscripts automatically. Smaller or newer publishers may not. If you are submitting to a society journal or a newer publisher, ask explicitly whether they participate in NIHMS before you submit.

Wellcome Trust: Fully Open Access Journals Only

Wellcome Trust was one of the first major funders to adopt a stringent open access policy, and it has tightened that policy progressively. The most significant recent change took effect January 1, 2025: Wellcome will no longer fund article processing charges for hybrid journals. This is not a minor procedural shift. For researchers who received Wellcome funding and routinely published in high-prestige subscription journals by paying the hybrid open access fee, the route they were using has closed.

From January 2025, Wellcome will cover APCs only for research articles published in fully open access journals or platforms that are indexed in the Directory of Open Access Journals (DOAJ). There is an additional technical requirement: the journal must have a deposit agreement with the National Library of Medicine to route the Version of Record to PubMed Central and allow that content to be shared with Europe PubMed Central. Journals that meet both criteria and that publish biomedical content include PLOS Medicine, PLOS Biology, BMJ Open, eLife, Communications Medicine, and Wellcome's own publishing platform, Wellcome Open Research. There are hundreds of qualifying journals, and the DOAJ is searchable by subject area.

The requirements that applied before also continue. All Wellcome-supported research publications must be deposited in Europe PMC upon publication and must be available under a Creative Commons Attribution licence (CC BY). A CC-BY-ND licence is available by exception, but researchers must apply to Wellcome for this exception before publication, not after. Every publication must include a data availability statement. These requirements have not changed; the tightening is specifically the closure of hybrid journal funding.

What this means in practice: researchers funded wholly or partly by Wellcome who want to publish in subscription journals like The Lancet, the New England Journal of Medicine, JAMA, or the British Medical Journal now face a gap. Those journals offer hybrid open access, but Wellcome will not pay for it. Some of these journals have launched fully OA companion titles (for example, The Lancet family includes eClinicalMedicine and The Lancet Regional Health journals), and those may be compliant options. Alternatively, researchers can use the green OA route: deposit the Author Accepted Manuscript in a compliant repository immediately, but only if the journal's own policies permit immediate deposit without embargo. Given that Wellcome requires immediate public access, a subscription journal that imposes a six-month embargo on repository versions is not a compliant path.

UKRI: Immediate Open Access and the Exit from Transformative Journals

UK Research and Innovation has had a mandatory open access policy for research articles since April 2022, and extended it to monographs, book chapters, and edited collections from January 2024. The core requirements are that peer-reviewed research articles from UKRI-funded work must be made open access immediately on publication, under a CC BY licence, with no embargo. There are two compliance routes: publish in a fully open access journal (gold OA), or deposit the Author Accepted Manuscript in an open repository immediately upon publication (green OA). Either route works, as long as no embargo applies.

The change that affected researchers most recently was the closure of the transformative journal route at the end of December 2024. Transformative journals are subscription journals that have entered commitments to transition to full open access over time, listed in a registry maintained by cOAlition S. For a period, UKRI treated these journals as an acceptable compliance path because they were moving toward full OA, and allowed block grant funds to cover APCs in those journals. From January 2025 onwards, that allowance ended. UKRI block grants can no longer pay for articles submitted to transformative journals.

There is still a way to publish in a hybrid or transformative journal with UKRI funding, but it requires that your institution has a current read-and-publish or transformative agreement with that journal's publisher, approved by Jisc. These institutional agreements typically cover APCs for researchers at participating institutions in exchange for a subscription fee. If your university library has such an agreement with the publisher in question, and the agreement is still current, then the APC for your article may be covered through that arrangement rather than directly from UKRI block grant funds. The practical advice is to check with your institution's open access team before committing to a journal, not after.

UKRI provides open access block grants to eligible UK research organisations to help cover the cost of gold OA publishing. For research articles, these grants cover APCs in qualifying fully OA journals. For long-form publications, UKRI contributes up to ten thousand pounds toward open access book processing charges, and up to one thousand pounds toward chapter processing charges, under its 2024 policy for monographs. These figures are subject to change, and researchers should confirm current amounts with their institution.

What the Changes Mean for Journal Selection

The practical convergence of these three policies is that the journal you choose now has direct compliance implications for funded researchers. This is a genuine change from the situation ten years ago, when OA compliance was typically an afterthought handled by depositing a copy in a repository sometime after publication.

For NIH-funded researchers, the situation is relatively manageable because the green OA route through PMC is the primary compliance mechanism, and most major publishers participate in NIHMS. Almost any well-established journal in biomedicine is a viable target, as long as you confirm the PMC deposit arrangement and retain the rights to make it happen. The risk is smaller or newer publishers that have not established PMC deposit protocols.

For Wellcome-funded researchers, the journal pool is more constrained. The journal must be fully open access and listed in the DOAJ, with a PMC deposit agreement. This rules out most of the traditional flagship subscription journals for funded APC purposes, though it leaves hundreds of high-quality fully OA titles in biomedicine, including many with strong reputations and reasonable impact records. The PLOS family, BMJ Open, eLife, iScience, Communications Medicine, and the growing number of journals launched specifically as gold OA venues cover most research areas.

For UKRI-funded researchers, the journal must be either fully OA or covered by a current institutional transformative agreement. Check the Jisc list of active agreements for your institution. These change over time as agreements expire or are renegotiated.

Researchers with funding from more than one source, a common situation in collaborative grants, need to satisfy the most stringent requirement. If you have both Wellcome and NIH funding on a single paper, Wellcome's requirement (fully OA journal only, for funded APCs) is more restrictive and should guide the decision. If you have UKRI and NIH funding, the green OA route through PMC may satisfy NIH, while UKRI requires either fully OA or a current institutional agreement.

The Hybrid Journal Problem

Hybrid journals deserve their own section because they remain the source of the most confusion in compliance discussions. A hybrid journal is a subscription-based title that allows individual articles to be made open access for a fee, typically called an article processing charge or APC. Hybrid journals used to be the dominant compliance route for funded researchers: keep publishing in the journal your field respects, pay the APC, satisfy the funder. That route has narrowed significantly.

Wellcome will not fund hybrid journal APCs under any circumstances from January 2025. UKRI will not fund them from block grants from January 2025, unless covered by a current institutional Jisc agreement. NIH does not fund APCs directly and does not mandate gold OA, so its position on hybrid journals is less about payment and more about confirming that PMC deposit is possible under the author agreement.

The residual route for hybrid journals is the institutional transformative agreement. Many UK and European universities have negotiated read-and-publish agreements with major publishers that bundle subscription access and OA publishing rights for researchers at participating institutions. If your institution has a current agreement with Elsevier, Springer Nature, Wiley, or another large publisher, you may be able to publish OA in a hybrid journal under that agreement without paying out of pocket or from a block grant. But these agreements change, and they are not universal. An agreement your institution had in 2023 may have expired, been renegotiated, or had different terms applied to specific journals within the publisher's portfolio.

The clearest advice is this: if your target journal is a hybrid title and you have Wellcome or UKRI funding, do not assume compliance is possible. Check the specific journal against your institution's current agreements before you submit. If the journal is not covered, choose a different target or plan to use the green OA deposit route, confirming that the journal actually permits immediate green OA without embargo.

Article Processing Charges: Who Pays and What Is Available

APCs for fully open access journals in biomedicine vary widely. Society-run fully OA journals often charge two thousand dollars or less. Prestige journals in the Nature Portfolio's fully OA titles, such as Nature Communications, Communications Medicine, and Scientific Reports, currently charge amounts in the range of several thousand dollars, with the exact figure subject to change. PLOS Medicine and PLOS Biology charge somewhat less. Many journals in the DOAJ charge nothing, particularly those based in lower-income countries or run by academic societies as a service to the field.

If your funder covers APCs (Wellcome for qualifying journals, UKRI through block grants), the APC is typically paid by your institution's open access team directly to the publisher after acceptance. You do not usually pay upfront. The process varies by institution, but most research libraries or research support offices that manage open access funding have a form or workflow for handling this after you notify them of acceptance.

Waivers and discounts are more available than many researchers know. PLOS has a longstanding policy of waiving or discounting APCs for researchers who demonstrate financial inability to pay. Springer Nature, Wiley, and Elsevier all operate APC waiver schemes for researchers from low- and middle-income countries, and some extend them to researchers without grant funding regardless of geography. The process for requesting a waiver typically happens at submission or acceptance, and requires a written explanation. Reviewers of waiver requests are generally not the same people reviewing the science.

NIH does not pay APCs as part of its compliance mechanism. The NIH public access policy is structured around the green OA route through PMC, which is free. If an NIH-funded researcher chooses to publish in a fully OA journal and pay an APC, that cost may be includable in a grant budget as a research expense, but it is not required for policy compliance. The point worth repeating: NIH compliance does not require paying any APC. It requires PMC deposit. Those are different things.

A Practical Pre-Submission Compliance Check

The right time to verify compliance is when you are shortlisting journals, before you prepare the manuscript to a specific format. Post-acceptance compliance problems are solvable but stressful. Some involve negotiating with publishers over author agreements while you are trying to celebrate an acceptance. A brief compliance check at the shortlisting stage eliminates that stress entirely.

Start by listing every funder that contributed to the work, even minor contributions. Co-funders are a common compliance gap. A paper co-funded by NIH and a Wellcome-funded collaborator needs to satisfy both policies. The stricter requirement governs.

For each candidate journal on your shortlist, check three things. First, is the journal fully OA or hybrid? Fully OA journals are searchable via the DOAJ. Second, if you plan to use the green OA route, check the journal's self-archiving policy. Sherpa/Romeo is the most widely used tool for this: it catalogues the repository deposit rights granted by specific journals and publishers, including whether immediate deposit is permitted and under which licence. Third, if the journal is hybrid and you need APC coverage from Wellcome or UKRI, check your institution's current Jisc agreement list.

If any of those checks raises a question, contact your institution's library or research support office before submitting. These teams deal with exactly this kind of question and usually respond quickly. What feels like a complex compliance puzzle to a researcher is a standard question for open access librarians.

Where This Is Heading

The direction is clear. The NIH joining Wellcome and UKRI in requiring immediate open access without embargo signals that the 12-month delay window that characterized the previous decade of biomedical publishing is effectively over for researchers funded by major public and charitable sources. European funders through cOAlition S, including funding bodies in France, Austria, the Netherlands, and several Nordic countries, have adopted similar requirements, and the European Commission's Horizon Europe funding already requires immediate open access. The cluster of holdouts is shrinking.

The hybrid journal problem will continue to work itself out through institutional agreements and through journals making fuller transitions to open access models. Several publishers have already announced plans to flip major titles, and the economics of the transformative agreement model, while contested, are pushing more journals toward full OA. Whether that transition happens smoothly or creates gaps for specific fields or researchers without institutional agreement coverage is uncertain.

For researchers working now, the practical implication is to build open access compliance into the front end of the submission process rather than treating it as a bureaucratic step to handle after acceptance. The policies are enforced, the compliance consequences are real, and the tools to check compliance before submission, DOAJ, Sherpa/Romeo, your institution's library system, are free and genuinely useful. Spending ten minutes on a compliance check before shortlisting journals is almost always a better use of time than renegotiating an author agreement under deadline pressure after the fact.

Further Reading