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The NIH 2025 Public Access Policy: Immediate access, unequal costs
PLOS Medicine
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Citation: Ryus CR, Raymond King C, Melnick ER (2026) The NIH 2025 Public Access Policy: Immediate access, unequal costs. PLoS Med 23(6): e1005124. https://doi.org/10.1371/journal.pmed.1005124
Published: June 1, 2026
Copyright: © 2026 Ryus et al. This is an open access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited.
Funding: This work was supported by the National Institutes of Health, National Institute on Drug Abuse (K12DA033312 to CR). The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript.
Competing interests: The authors have declared that no competing interests exist.
Abbreviations: AAM, author-accepted manuscript; APCs, article processing charges; NIH, National Institutes of Health.
Introduction
In 2025, the National Institutes of Health (NIH) completed implementation of its updated Public Access Policy, requiring that all NIH-funded research articles be made immediately available upon publication, eliminating the 12-month embargo period previously permitted [1]. This policy fulfills a principle articulated by the open science movement for more than two decades: that the results of publicly funded research should be promptly and freely accessible to scientists, clinicians, patients, and the public.
Public access—the free availability of publicly funded research outputs—is a central goal of the broader open science movement. Open access publishing, in which the final version of record is freely available (often through article processing charges (APCs)), is one mechanism for achieving this goal, but the two are not equivalent.
Unfortunately, an unsolved problem remains: who pays for freely available peer-reviewed research results? This Perspective examines how the NIH policy intersects with contemporary publishing economics. We argue that while public access has expanded who can read science, less attention has been paid to who can afford to produce and publish it, and how the labor sustaining scientific communication is governed.
Scientific labor and publishing economics
The modern open access movement emerged in response to concerns that escalating journal subscription prices were restricting access to scientific literature, even within well-resourced academic institutions. As digital publishing reduced technical barriers to dissemination, economic barriers persisted. Over the subsequent decades, open access expanded rapidly, culminating in the NIH policy eliminating embargo periods [2].
In many open access models, costs have shifted from readers to researchers through APCs. In many selective journals, APCs now routinely exceed $3,000 and may reach upwards of $12,000 [3]. These charges have become a central component of publisher revenue.
Academic publishing remains highly concentrated among a small number of commercial publishers [4] whose profit margins approach 40%, rivaling the most profitable corporations [5,6]. By contrast, nonprofit models operate at substantially lower-cost; for example, per-article download costs have been estimated to be as low as $0.04 for nonprofit publications compared with $1.06 in some for-profit journals under large institutional contracts [7]. Although publishers provide essential services including infrastructure, production, and archiving, the gap between production costs and prices raises questions about how fees are set and revenues distributed [5,6]. When publication fees are charged to federally funded grants, the public may effectively pay multiple times—through direct research funding, publication costs, and institutional overhead (indirect costs).
Scientific publishing depends on extensive expert labor: researchers conduct studies and prepare manuscripts, while peer reviewers and academic editors evaluate work and safeguard the scientific record, largely without compensation. This arrangement inverts the logic of most content industries. In book publishing, for example, publishers pay authors and editors, then charge readers modest prices. In academic publishing, authors pay to publish, reviewers work without compensation, and readers pay substantial fees to access the results—often for a single article. Although the academic community governs what enters the literature, it has little influence over pricing, access models, or publishing contracts [6]. As a result, unpaid scholarly labor underpins a system in which financial returns accrue elsewhere, and control over dissemination is frequently transferred away from the scientists and institutions that produced the work.
The NIH 2025 policy: achievement and constraint
The NIH Public Access Policy addresses a core ethical principle: the public should have timely access to the results of research it funds [1]. The policy strengthens accessibility and accelerates scientific exchange, aligning US policy with global open science initiatives.
Although compliance with the NIH Public Access Policy can be achieved without APCs by depositing the author-accepted manuscript (AAM) in PubMed Central, this zero-cost pathway is only available if the journal permits immediate AAM deposit. Some major commercial publishers have moved to eliminate this option, leaving APC-funded open access as the only compliant pathway for authors publishing in their journals. Other publishers have begun conditioning their own depositing of the final published article in PubMed Central on payment of APCs, despite lacking the authority to restrict authors from depositing their accepted manuscripts [2].
A mechanism already exists to address these constraints: the Federal Purpose License. Under federal grant terms, the US government retains a royalty-free, irrevocable right to reproduce and distribute work produced under its awards. This provision supports authors’ ability to deposit accepted manuscripts in PubMed Central regardless of publisher policies. Yet in practice, researchers often remain responsible for navigating conflicting requirements and absorbing associated costs.
The policy does not address APC pricing, market concentration, or the incentives that shape publication decisions. Although APCs may be allowable grant expenses, funders do not negotiate prices or assess whether fees reflect underlying costs or public value.
Implementation also reflects an asymmetry in enforcement. Noncompliant articles may be flagged in NIH reporting systems, placing responsibility on authors who may have limited control over journal policies or insufficient resources to pay APCs. By contrast, publishers face few direct consequences when compliance pathways are costly or unclear.
In a prestige-driven academic environment, researchers often perceive limited freedom to select lower-cost venues without career risk. Metrics such as journal impact factor and reputation continue to shape hiring, promotion, and funding decisions [8]. Consequently, immediate access mandates may increase reliance on APC-funded publishing while leaving existing pricing power largely intact. Funder-imposed APC caps, while appealing as a near-term intervention, risk functioning as a market floor rather than a ceiling, potentially reducing price competition and deepening inequities between well- and under-resourced institutions and investigators [9]. Structural alternatives, including asserting the Federal Purpose License and investing in nonprofit and community-owned publishing infrastructure, avoid these pitfalls while better aligning with the public interest.
Under current NIH policy, the public access requirement is triggered if any author on a manuscript is supported by NIH funding [1]. This has important implications for trainees and early-career investigators: a K awardee, whose salary support may constitute up to 75% effort, or T32 trainee, can extend this requirement to all work they coauthor, even when the underlying study itself has little or no direct NIH funding. Given that trainee co-authorship is both common and encouraged, this creates a structural tension.
Training and career development awards are explicitly designed to build research experience and publication records, yet they typically provide limited support for direct research costs and little to no support for APCs. In practice, this means early-career investigators write grants to budget for publication fees, negotiate with mentors to cover costs, make strategic publishing decisions based on what they can afford rather than where their work belongs, and spend uncompensated time navigating institutional open access funds, compliance requirements, and deposit procedures, all while performing unpaid peer review for the same journals charging them to publish. As a result, the burden of compliance may fall disproportionately on those with the least financial flexibility, and over time may shape not only who publishes but what kinds of research are feasible to pursue [10–12].
Reaffirming the original vision
The open access movement, including the founding of PLOS, was grounded in the belief that scientific knowledge is a public good and that its dissemination should serve the broadest possible community [13]. Access was a necessary starting point, but not the sole objective.
As public access becomes the norm, attention should turn to how the system is financed and governed. Alternative publishing models, spanning publisher-driven, funder-driven, institution-driven, and culture-driven reforms (Table 1), demonstrate that the core functions of scholarly communication (evaluation, dissemination, sustainability, and maintenance) can happen outside of per-article payment models. Together, these approaches represent not only technical alternatives but also experiments in governance, redistributing financial responsibility while preserving scientific rigor. Aligning these efforts will be essential to move closer to the original goals of open access: expanding access without introducing new barriers to participation.
Conclusions
The NIH’s immediate public access requirement removes a long-standing barrier, ensuring that publicly funded research is no longer locked behind embargoes or paywalls. However, access alone does not guarantee affordability, sustainability, or alignment with the public interest.
As publication costs rise, they risk shaping not only who publishes, but what gets studied, privileging well-funded fields while constraining research in under-resourced areas. In this way, the economics of dissemination can quietly redirect the scientific agenda itself.
Public access was intended to make science available, not to create new barriers at the point of publication. In the NIH 2025 era, that vision and the public access policies meant to advance it, must also ensure that participation in producing and publishing science remains broadly attainable. Without attention to pricing, incentives, and market concentration, public science risks becoming accessible in principle but exclusionary in practice.
Acknowledgments
AI Disclosure
The authors used the large language model ChatGPT (OpenAI, GPT-5.2) to assist with early-stage drafting, language editing, and structural organization of manuscript sections. The tool was used iteratively under direct author supervision to improve clarity, flow, and concision. Grammarly (Grammarly) was used for minor syntax and grammar improvements during manuscript preparation, with all suggested changes reviewed and approved by the authors.
All substantive intellectual contributions, including the conceptual framing, interpretation of the literature, policy analysis, and conclusions, were developed and verified by the authors. The authors critically reviewed, edited, and validated all AI-assisted outputs for accuracy, originality, and appropriate citation of sources. Any errors or omissions are the responsibility of the authors.
No artificial intelligence tools were used to generate or manipulate primary data, analyses, references, or empirical results.
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