Beginning on or before 31 December 2025, all recipients of United States federal research funding will be required to make their federally funded scholarly outputs, including scientific data, freely available via public access venues with no delays or embargos. These requirements are outlined in the Memorandum on Ensuring Free, Immediate and Equitable Access to Federally Funded Research issued by the US Office of Science and Technology Policy, commonly called the “Nelson memo”.

Here, we present an initial report on our findings as part of our project to investigate “reasonable costs” for public access to United States federally funded research and scientific data, generously supported by the US National Science Foundation. This paper focuses on research data as one of the key scholarly output types impacted by the Nelson Memo.

Key Observations and Findings

  1. We found considerable variation in the use of four key terms: cost, price, reasonable, and allowable. In this paper, we set out working definitions for these terms.
  2. For repositories leveraging sources of revenue other than deposit fees or other revenue streams that do not immediately scale up with increased deposits, sustainability is an important concern. We review the literature and available information about business models and fees to provide an overview of the landscape for repositories working with research data.
  3. Labour is the most significant cost for repositories and data curation, particularly in support of ingest and access, although the actual cost of data curation in repositories varies by discipline, characteristics of data, and level of curatorial services provided. We review cost-modelling experimentation in the fields of research data management and digital preservation.
  4. If "reasonable" cost is not readily generalizable, greater clarity regarding allowable activities and more transparency in repositories’ costs would aid researchers and funders in evaluating whether any deposit, membership, or other form of fees that are charged are appropriate for the services rendered. Where some or all of the effort associated with meeting public access requirements is performed by members of the research team, costs could be properly allocated to research and to publication components of grant budgets.

Next Steps

We continue our literature review and landscape survey regarding additional implications of cost and price, including for public access to research articles. We are working with stakeholder groups, including representatives from sponsored research offices, libraries, publishers, scholarly societies, and data management and scholarly communication infrastructure providers, to learn more about what questions they are fielding from researchers, and what elements go into their equations of what it costs to make research outputs publicly accessible.


This material is based upon work supported by the National Science Foundation under Grant No. 2330827. Any opinions, findings, conclusions or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the National Science Foundation. 

We thank Reid Boehm (Purdue University), and Shawna Taylor (ARL) for providing feedback to the complete draft of this report, as well as Mark Kurtz (Dryad) and Michael Witt (Purdue University) for commenting on earlier versions of this paper and Lauren Collister (IOI) who prepared this report for publication. 

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We welcome all questions, comments, and feedback on this work – please email us at research [at] investinopen [dot] org.

Social media image by micheile henderson on Unsplash.

Posted by Gail Steinhart & Lauren Collister