The cost of public access: Do we get what we pay for?

Introduction

Free and immediate access to the results of taxpayer-funded research has gained widespread support from governments around the world over the last several decades. Public access policies, memoranda, and guidance have proliferated, promising to make science more transparent, equitable, and collaborative.

While these policies have garnered widespread praise for their potential to transform research culture, they also raise important questions about resources. Who pays for implementation? What happens when policies mandate access without providing funding mechanisms?

Drawing on perspectives from stakeholders across three global regions implementing such policies — including Kathleen Fitzpatrick, Jennifer Gibson, Bianca Kramer, Jonah McAllister-Erickson, and Eunice Mercado-Lara — as well as findings from IOI’s Reasonable Costs project,[1] we categorize various costs involved and identify opportunities to invest in these areas to promote public access and advance open research principles. We reached out to a broad stakeholders for interviews and scheduling problems limited us to those who could accept; we note that the interviewees in this piece are more heavily library and repository focused, though we do try to account for additional perspectives that we have heard from the many society, repository, library, publishing, administrative, and research-focused stakeholders in our Reasonable Costs work.

The cost of culture change

As more and more governments and private funders require the research outputs they fund to be publicly available, researchers themselves are leading an ever- growing movement toward “open science” — a broad set of research principles and practices that emphasize transparency and inclusiveness.

Jennifer Gibson, Executive Director at the data publishing platform Dryad, believes that while the spirit of directives like the OSTP Public Access Memo,[2] also known as the Nelson Memo, in the US are on the right track, “policy isn’t enough” to actually change how researchers work (personal communication, April 2, 2025). The symbiosis of public access policies and open science practices is key to creating meaningful change. Jumping straight to mandates without laying essential groundwork can lead to resistance and failed implementation.

Eunice Mercado-Lara, who helped create Mexico’s public access policy, advocates a multi-step formula for success: raise awareness, build skills, create infrastructure, and only then introduce requirements (personal communication, March 6, 2025).

Where to invest

• Next generation research assessment. Traditional evaluation metrics can conflict with open science practices, creating career risks for researchers (Belles et al., 2023). Assessment systems must recognize and reward open practices to drive meaningful culture change. Investment in the work of groups like CoARA,[3] which promote “more inclusive and effective assessment practices,” helps create the necessary conditions to promote openness.
• Data sharing support. Campus data services, often based in university libraries, offer critical training, guidance, and (in some cases) infrastructure for researchers. Public access requirements elevate these services to institution-level strategic priorities that deserve commensurate investment. West Virginia University offers an example of this investment in action. When Jonah McAllister-Erickson, Scholarly Communication Librarian at the WVU Libraries, reviewed recent proposals from investigators at WVU, he found that nearly half had budgeted nothing for data management. This may stem from uncertainty about allowable costs and underestimating the labor involved in proper data sharing. The lack of specific budget lines for data management could force research teams to shift project resources from data collection and analysis to accommodate data cleaning and processing (personal communication, March 21, 2025). A cross-campus working group at WVU concluded that “ensuring data sharing compliance would require new processes, guidance, training, services and roles” and is collaborating to put these systems in place (“Rising to meet research needs”, 2025).
• Open science skills. Public access and open science are not synonymous. However, public access mandates create opportunities to introduce researchers to a wider range of open science practices and motivate them to participate. Kathleen Fitzpatrick, Interim Associate Dean for Research and Graduate Studies at Michigan State University (MSU) and Director of the open repository Knowledge Commons, is seeing changes at MSU in the form of “projects to promote the idea that scientific enterprise is one giant collaboration and figuring out how we can work together in ways that are supportive rather than competitive.” Initiatives like the NASA-led 2023 Year of Open Science,[4] building on the momentum of the Nelson Memo, “are really attempting to think beyond making publications and data available and open up practices more generally” (personal communication, April 2, 2025). Campus-based and community-led initiatives can provide necessary training in coding, data management, and reproducibility, among other open science skills. Investment from institutions, consortia, as well as public and private funders can help make this type of training the norm across disciplines and geographic regions.

The cost of equity

Public access and open science policies from around the world reference “equity” as a core principle and a desired outcome. For example, the Nelson Memo explicitly establishes a strong connection between public access and equity, emphasizing that access should benefit all segments of society; the UNESCO Recommendation on Open Science[5] prominently features equity as a core principle. However, when public access policies conflate “public access” with “equity,” they flatten the differences between the very narrow ability to read published research results with the broader ideal of enabling full participation in research by all people (Khisro & Fenlon, 2025).[6]

Public access policies do little to address broad participation in knowledge creation, focusing instead on the right to consume. In the context of India’s open science policy, for example, critics noted that “knowledge dissemination receives immediate attention with little or no contemplation of the knowledge creation process” and insufficient consideration is given to “cultural diversity in knowledge production” and knowledge systems (Koley, 2022). Achieving an inclusive and equitable research ecosystem requires addressing deeper cultural and organizational barriers (National Academies of Science, Engineering, and Medicine, 2024).

Where to invest

• Community ownership. Fitzpatrick notes that, while the Nelson Memo explicitly addresses the importance of high-quality, trustworthy repositories, it doesn’t “open the possibilities for exploring non-corporate models and ensuring that those are supported.” In Europe, organizations have urged public investment in open infrastructure “to prevent open science appropriation by private multinational companies” (Bacalexi, 2022). Public funding can offer critical, stable funding for open infrastructure, though reliance on any single funding source can create risks and vulnerabilities, as demonstrated by the radical and unprecedented cuts to federal funding currently hitting the US. Open infrastructure organizations need to build diverse revenue streams — which may include public and private grants, membership and service fees, donations, and in-kind contributions — coupled with governance models that put researchers over profits and incorporate inclusive scholarship into their mission.
• Regional initiatives. Investment in local and regional open science infrastructure helps counter the dominance of Western models and perspectives. Regional initiatives can better account for contextual differences in research capacity, cultural knowledge systems, community needs, and norms and engage end users in the design of knowledge infrastructure that works in their context (Arthur et al., 2023; Okune et al., 2018). Funding models should acknowledge and accommodate different economic realities across regions and solutions should be co-designed with local stakeholders, include diverse representation in governance, and reflect regional differences in connectivity and hardware. A successful example of a regional initiative supported by a global collaboration is LIBSENSE,[7] which has defined priorities and developed concrete deliverables in support of open science policy adoption in Africa (Chiware & Skelly, 2022).
• Data reusability. Proper investment in FAIR (Findable, Accessible, Interoperable, Reusable) data practices can create more equitable research opportunities. Broader implementation of the CARE Principles[8] helps ensure that data governance aligns with Indigenous worldviews and interests while providing collective benefit. McAllister-Erickson notes that access to underlying data breaks down barriers for validation and replication and provides a rich resource for stakeholders who may not have the resources to generate the data for themselves. Poor data management practices and gatekeeping by researchers has historically prevented much of this data from being used to its full potential. Data reusability requires standards, platforms, tools, and training that support diverse research communities.  Public and private funders that care about catalysing scientific research breakthroughs need to be investing not only in research studies, but in standards-based infrastructure for data sharing and reuse.
• Non-APC-based publishing models. As public access requirements become the norm, publishers have increasingly adopted article processing charges (APCs) — where an author pays a fee to make their article openly readable — to replace subscription revenue. Business models built around maximizing open access fees end up “excluding people from all the same groups as the subscription model, except that they’re now excluded from participating in the conversation rather than seeing the results of the conversation” (Kathleen Fitzpatrick, personal communication, April 2, 2025). Concern about replacing paywalls with “playwalls” (i.e., researchers with more funding get higher visibility as the more prestigious journals turn to APC-based OA business models) demonstrate the need for more radical change in how we support scholarly publishing (Hampson & Steinhauer, 2023; Krauskopf, 2021; Peterson et al., 2013). The high cost of publishing forces many researchers to choose between career advancement through prestigious but expensive journals and making their work widely accessible (Belles, et al., 2023). Diamond and Green Open Access (OA) initiatives, led by the academy, can put the power back in the hands of researchers and provide opportunities for more equitable participation in scholarly communication. Funders interested in furthering research participation by marginalized groups could be investing in initiatives that advance Diamond OA, such as the Open Journals Collective (OJC),[9] which aims to direct collective investment into hundreds of Diamond OA journals, as well as in open source repositories and publishing platforms, such as AfricArxiv, that specifically promote scholarship from developing regions.

The cost of infrastructure

Public access mandates require significant ongoing investment in technical infrastructure to host, distribute, and preserve research outputs.

The technical infrastructure that enables public access to research is built and maintained by a range of entities, including national governments and agencies, research institutions, infrastructure providers, and publishers. This distributed responsibility creates both opportunities and challenges for sustainable public access implementation.

For example, the NIH is spending millions to ensure critical generalist data repositories meet desired technical specifications while fostering culture change and policy compliance (Jennifer Gibson, personal communication, April 2, 2025). The European Commission invested over 5 million euros on the preliminary round of development and operationalization of Open Research Europe, a venue for researchers to make their outputs publicly available in compliance with the Open Access mandate of Horizon 2020 and Horizon Europe (Johnson, 2022).

Research institutions are increasingly investing in local data and publication repositories as well as subscriptions or memberships with third party vendors who help them meet the compliance needs of their researchers. In many regions, these are funded entirely at the institutional level, requiring ongoing care and funding. Mercado-Lara notes that, of the 200 Mexican universities that received funding to build institutional repositories to support public access, only about a third are still active and coordinating.

Those that succeeded had buy-in from university leaders and researchers that provided momentum for ongoing support after national funding ended. US-based institutions that participated in IOI’s Reasonable Costs project expressed uncertainty about whether and how much to invest in campus data storage/hosting and preservation infrastructure given the lack of specificity from federal agencies regarding designated repositories and appropriate formats and technical standards for shared data.

In the US, facilities and administrative (F&A) costs paid by funders have historically supported building and maintaining necessary campus research infrastructure.  On some campuses, proposed federal caps on these rates are already resulting in job eliminations and provoking difficult choices about postponing or cancelling needed infrastructure projects (Jonah McAllister-Erickson, personal communication, March 21, 2025).

Where to invest

• Leveling up. To ensure they can support high- quality, trustworthy, and compliant public access, infrastructure organizations need to invest in feature and service enhancements. In some fields, this work is being supported by direct investments from funding agencies, as in the case of the National Institutes of Health’s Generalist Repository Ecosystem Initiative (GREI),[10] which aims to help a group of widely used data repositories provide robust and consistent service to investigators. Even in areas where guidance and intervention from funding agencies have been less specific, policies are prompting infrastructure organizations to reflect on how well they align with best practices for technology and services.
• Building collectives. Supporting a vast ecosystem of individual infrastructures to operate independently and with redundant functions across the board costs more money than consolidating (Jennifer Gibson, personal communication, April 2, 2025). Despite the challenges of inter-institutional collaboration, Fitzpatrick and others contend that this might be the moment to say “no single institution can or should support a repository that’s robust enough to do all the work that open scholarship requires,” but with pooled resources and collective effort, we can build robust and sustainable solutions.
• Academy-owned cloud. Can research institutions support large-scale open research and public access? Broadly available, academy-owned cloud hosting infrastructure may be one place to start. Research is highly dependent on commercial cloud providers like Amazon Web Services (AWS), another example of “siphoning resources out of the academy into corporate pockets” and generating concerns about data security, privacy, and other academic values that often misalign with corporate practices (Kathleen Fitzpatrick, personal communication, April 2, 2025). Examples of infrastructure hosted on academic servers, rather than via commercial cloud providers are increasingly rare. Recent news that arXiv plans to move to Google Cloud Services (GSC) prompted discussion about the risks of vendor lock-in and increased costs, while also underscoring the difficulty of a single institution maintaining its own modern, reliable hosting infrastructure (Kasanmascheff, 2025). Pooling resources to build necessary hosting infrastructure could allow libraries across entire regions or countries to support the wide array of institutional infrastructure projects, such as repositories, digital collections, publishing platforms, and research software that currently use commercial cloud hosting services.

The cost of publishing

In response to a request for comment on the Nelson Memo in 2022, signatories from the Ivy Plus Consortium in the US wrote, “We both applaud this policy change and are aware that it may result in significant additional costs related to publication, repositories, data management, and staffing which we anticipate will be shouldered by individual researchers and institutions” (“Library Statement on the Nelson Memo,” 2023).

While policies like Plan S explicitly endorse Gold Open Access (the business model where authors pay to publish), others like the Nelson Memo remain ambiguous about the mechanisms for public access (Hampson & Steinhauer, 2023). Some have suggested that it may favour APC-based models (Hampson & Steinhauer, 2023; Crotty, 2022).

A 2023 study of spending by US universities shows that “the majority of states published between 1,000 – 7,000 Gold Open Access publications and spent up to 6 million dollars [on publication fees] in the past 10 years” (Halevi et al., 2023). The financial burden extends beyond covering the APC. Data from a study of 29 universities in the UK shows that when taking into account both the APC and administrative costs, Gold OA publishing costs universities 2.5 times more than Green (repository-based) alternatives (Johnson et al., 2016). Meanwhile, well-resourced commercial publishers can quickly adapt business models, develop new revenue streams, and maintain influential advocacy positions that shape policies in their favour (Jennifer Gibson, personal communication, April 2, 2025).

Research institutions are already shifting limited resources to accommodate these changes, largely by converting portions of their library collections budget to “cover some publication costs, whether via an APC fund available to institutional authors, via Read-and-Publish contracts that cover APCs in bulk, or via direct subsidies to support open access ventures” (Sharp et al., 2023). In regions experiencing stagnating and shrinking university library budgets (such as the US, UK, and parts of Latin America,) new spending needs to be cost neutral. Supporting new publishing models means reducing investment in other initiatives.

Where to invest

• Rethinking scholarly communication. According to Fitzpatrick, the “focus of Nelson Memo on making end products of research as we currently know them freely and openly available” can thwart opportunities to rethink the functions and forms of scholarly communication. Similarly, in the Netherlands, investment since Plan S has largely taken the form of publisher agreements, leaving out alternative models if all the money is going to traditional publishing. Bianca Kramer, Executive Director for the Barcelona Declaration on Open Research Information, notes that great work around Diamond OA continues in the Netherlands though recent open science budget cuts risk stymying progress (personal communication, April 3, 2025). By centering traditional research outputs — namely peer-reviewed journal articles — the policy risks reinforcing entrenched models. Efforts like Plan U, which advocate for the mandatory deposition of preprints as a condition of funding (Sever et al., 2019), offer a different vision: one that enables faster, more transparent scientific exchange decoupled from the prestige factor of “high-impact” journals. Kiermer et al. (2025) similarly argue for a broader reevaluation of the scholarly publishing system, suggesting that a true shift must include reimagining peer review, credit attribution, and the role of community feedback. Embracing diverse research artifacts — such as data sets, code, protocols, and preprints — as primary scholarly outputs could promote new forms of transparency, collaboration, and impact.
• Establishing reasonable costs. In the long term, the capping of grant allocations for publishing fees by large federal agencies may be an effective means of preventing further increase in the cost of publishing (Belles et al., 2023; Gorelick & Li, 2021). But what do “reasonable” caps look like? The Nelson Memo and other policies have prompted more publishers to provide cost and price transparency information, but it has remained difficult to establish fair and objective metrics for gauging reasonable costs (Kemp & Skinner, 2024). IOI’s Reasonable Costs project is establishing benchmarks for calculating costs (i.e., the direct and indirect expenses involved in publishing content) and price (i.e., the fees charged to authors or their institutions to make content public). The openCost[11] project has developed a schema and database to track the costs involved in scientific publishing. This critical work provides funding agencies with the information they need in order to establish allowable costs associated with public access compliance.

The cost of ensuring compliance

Evidence shows that when there’s no clear enforcement, many researchers simply don’t comply with public access policies. In the US, compliance with National Science Foundation policies has been low, partly because there’s not enough oversight (Powell et al., 2025). Research funders incur considerable ongoing costs for paid services that help them monitor whether researchers comply with their requirements (Cobb-Lewis, et al., 2024). In the case of data, ascertaining whether data sharing has been performed in compliance with the investigator’s data management plan can require detailed and time-consuming verification and potentially even domain expertise.

A lack of specific guidelines can create administrative uncertainty and complicate compliance efforts, as institutions interpret broad mandates in various ways. What was meant to be flexible actually ends up creating a patchwork of practices that make it harder to achieve public access goals.

In 2023-24, IOI surveyed 83 representatives of universities, colleges, and research labs in the US as part of our Reasonable Costs[12] project. Eighty percent of respondents said the Nelson Memo had resulted in few or no meaningful changes to the work of their unit. Only 14 percent identified specific ways in which their unit had increased its investment to support activities related to public access to grant-funded publications and data/other outputs as a result of the Nelson Memo. Respondents were frustrated by the lack of specificity from many agencies regarding their requirements, including where research outputs are expected to be deposited and in what formats. As one respondent noted, “We need to know that the regulations won’t continue to be a moving target. We also need better information and consistency from federal agencies.”

Who is ultimately charged with compliance remains unclear, further complicating the question of how policies get enforced and by whom. Do institutions or principal investigators bear primary responsibility for ensuring research outputs are shared in accordance with requirements? Most institutions participating in IOI’s Reasonable Costs project do little to no monitoring of public access compliance. Will this need to change? If so, who bears the costs of such monitoring?

Where to invest

• Reducing friction. “It’s friction,” says Gibson. “If folks don’t know what to do, they’re not going to do it.” Researchers are being asked to divert attention from their core work to learn and implement new systems and procedures. Institutions and open infrastructure organizations need to build new tools and pathways that make it easy for researchers to understand and meet their obligations. This is especially true in the US going forward, as publishers may be less motivated to support automated deposit in funder repositories (which has been a major driver of public access compliance) now that the 12-month embargo period has been lifted (Crotty, 2022). However, IOI’s research found that many academic institutions in the US are taking a wait-and-see approach on the Nelson Memo, delaying changes to workflows, outreach, and internal policies until they understand the level of enforcement and consequences of non-compliance.
• Promoting persistent identifiers (PIDs). Machine-readable funder acknowledgements facilitated by PIDs remain underutilized, especially for data, making it even more challenging to associate research outputs with their funders (Schares, 2024). Funders can help by participating in Crossref’s Grant Linking System (GLS)[13] and Open Funder Registry (OFR)[14] and by requiring grantees to use PIDs in the funding acknowledgements of the outputs they share. Institutions can invest in promoting the adoption and use of ORCID[15] and Research Organization Registry identifiers[16] that facilitate machine- and human-readable attribution.

The cost of politics

When political administrations change, particularly toward more austerity-focused or anti-research positions, open science and public access initiatives become collateral damage.

Policies associated with a particular administration are vulnerable to being dismantled. In Mexico, for example, starting in 2019, “anything associated with the previous administration was condemned, including the programs around the open science policy” (Eunice Mercado-Lara, personal communication, March 6, 2025). The Nelson Memo, strongly associated with the Biden administration in the US, faces an uncertain future, which might include being retracted, delayed, unenforced, or deprioritized.

Abrupt policy shifts and political uncertainty requires frequently adjusting even near-term plans. The disappearance of implementation guidance, even as policies themselves remain in effect, can be equally as disruptive. In the US, for example, the NSTC’s Desirable Characteristics of Data Repositories for Federally Funded Research, an influential set of guidelines for data sharing infrastructure, appear to have been erased from the White House website.[17] Identifying which services, positions, and technologies are critical may depend on unpredictable policy changes, making it difficult for institutions to know where to focus or where to cut when they don’t know which requirements they will need to address (Jonah McAllister-Erickson, personal communication, March 21, 2025).

In Argentina and Chile, cuts to overall science funding have created an environment where open science becomes a lower priority as institutions struggle to maintain basic research operations (de los Ángeles Orfila, 2024). The US faces a similar challenge as proposed federal funding caps on research overhead rates imperil the ability of research institutions to perform their basic functions, let alone invest in the necessary infrastructure and support structures that support public access compliance (White, 2025). The Trump administration’s push to dismantle federal agencies, eliminate research funding, and censor research poses grave risks to public research infrastructure in the US (e.g., ERIC, PubMedCentral) and around the world (Collister et al., 2025).[18] Fitzpatrick cautions that we could see significant US federally funded research platforms crumble and noted the urgency of national and international attention on the implications. Conversations are happening in the US and elsewhere about how to fund and execute a plan to replicate and bring up these research platforms outside of the federal government if and when such action is needed. In Europe, institutions have begun warning researchers to avoid storing data on US-based infrastructure and researchers have launched efforts to rescue at-risk data (Schouppe, 2025; Schapp, 2025).

Even in countries with strong open science foundations, political shifts can threaten progress. Funding cuts in the Netherlands, for example, could undermine years of advancement in a country previously seen as a leader in open science and public access (“Open Science NL budget”, 2024).

Where to invest

• Diversify infrastructure ownership and control. Kramer says that the situation in the US is reinforcing discussions in Europe about digital sovereignty, a conversation that has spread well beyond the academic sphere (Reynolds, 2025). Fitzpatrick notes that Knowledge Commons is thinking hard about what it means to be subject to the whims of a single research institution (Knowledge Commons is fiscally hosted by MSU), a single presidential administration, or a single tech CEO. For researchers outside North America and Western Europe, open source technologies “offer a viable, cost-effective alternative to the technological infrastructure provided by big tech and/or powerful, well-resourced nations” (Steinhart et al., 2024). Supporting the development of community-owned infrastructure, built on open source software, where researchers, academic institutions, and the public have a stake in ownership and governance, can create a more resilient system and insulate against government interference or disruption. This requires establishing sustainable business models for these independent organizations to flourish without being overly reliant on government funding.
• Support productive duplication. Given growing concern about government censorship or manipulation of research results and public data, it is essential to collaborate on and fund projects that are preserving and safeguarding copies in trusted, distributed repositories. Internet Archive,[19] the Data Rescue Project,[20] Environmental Data & Governance Initiative (EDGI)[21] in the US, as well as European organizations like Pangea[22] are working to ensure that the public retains access to critical research data and other outputs produced by the US federal government or with federal funding (Tollefson, 2025).

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Feedback

1. https://investinopen.org/data-room/reasonable-costs/
2. The text of the memo has been removed from the White House website, but is accessible via the Internet Archive’s Wayback machine at https://web.archive.org/web/20250120050644/https://www.whitehouse.gov/wp-content/uploads/2022/08/08-2022-OSTP-Public-Access-Memo.pdf.
3. https://coara.eu/
4. https://www.nature.com/articles/d41586-023-00019-y
5. https://www.unesco.org/en/open-science/about
6. Khisro and Fenlon (2025) reviewed US federal agency plans developed in response to the Nelson Memo and found that few “take equity meaningfully into account as a concept distinct from public access; and among those that do, there is little consensus on the meaning and entailments of equity in public access to research results.”
7. https://libsense.ren.africa/home
8. https://www.gida-global.org/care
9. https://www.openjournalscollective.org/
10. https://datascience.nih.gov/data-ecosystem/generalist-repository-ecosystem-initiative
11. https://www.opencost.de/projekt/
12. https://investinopen.org/data-room/reasonable-costs/
13. https://www.crossref.org/services/grant-linking-system/
14. https://www.crossref.org/services/funder-registry/
15. https://orcid.org/
16. https://ror.org/
17. These guidelines, previously available at whitehouse.gov, are now available at: https://web.archive.org/web/20250116081728/https://www.whitehouse.gov/wp-content/uploads/2022/05/05-2022-Desirable-Characteristics-of-Data-Repositories.pdf
18. https://hechingerreport.org/proof-points-eric-under-threat/
19. https://archive.org/
20. https://www.datarescueproject.org/
21. https://envirodatagov.org/about/
22. https://www.pangaea.de/