NIH Public Access Policy

The NIH Office of Science Policy released a request for information (RFI - NOT-OD-25-138) on article publishing cost limits for NIH-funded manuscripts.

Update Sept. 2025: The RFI period for this notice is closed. We will add an update when a formal policy is announced.

This notice is a follow-up to the announcement (directly below this section of this guide) to limit publishing costs for NIH-funded manuscripts.

Responses to the RFI will shape the limits for article publishing costs that are allowable to be charged to NIH awards, and whether they will be capped per manuscript, per life of the award, or some combination of these limits (or NO allowable publishing costs at all). The NIH is proposing five options for respondents to consider.

Please take some time to visit the proposed APC limit notice and consider submitting a response. The link to the response document is in the notice. 

In a July 8, 2025 NIH news item, the NIH announced they will address the issue of high article publishing charges (APCs) charged by journal publishers:

... As part of its ongoing commitment to scientific transparency and responsible stewardship of taxpayer dollars, the National Institutes of Health (NIH) today announced plans to implement a new policy that will cap how much publishers can charge NIH-supported scientists to make their research findings publicly accessible.

...

To address this imbalance, NIH will introduce a cap on allowable publication costs starting in Fiscal Year (FY) 2026, ensuring that publication fees remain reasonable across the research ecosystem. The policy aims to curb excessive APCs and ensure the broad dissemination of research findings without unnecessary financial barriers.

There is no new policy yet linked to this announcement. 

It is unclear whether the NIH plans to attempt to place a cap on APCs charged by publishers and journals themselves, or if it will place the cap on NIH award recipients' grant budgets for publishing costs. 

We'll update this guide and provide more information as it is released by the NIH. 

A new NIH Public Access Policy was announced December 2024. Beginning in 2025, the new policy will be in place. This new policy requires NIH-funded authors to ensure immediate full text access (in PubMed Central) to manuscripts supported by NIH awards. This replaces the allowable 12 month embargo period on full text access in PubMed Central in the current policy. The new policy began July 1, 2025. This was announced on April 30, 2025 in NOT-OD-25-101.

We encourage users to read the information available at the updated NIH Public Access Policy page in the Grants & Funding section of the NIH website. 

Background and Policy Update Timeline

• August 2022 - the White House Office of Science and Technology Policy released policy guidance (2022 OSTP Memorandum, or "the Nelson memo") to accelerate public access to federally funded journal publications. This guidance removes any embargo periods for federally funded manuscripts and requires them to be immediately accessible in agency-designated repositories.
• February 2023 - the NIH released its NIH Plan to Enhance Public Access to the Results of NIH-Supported Research (NIH Public Access Plan), which outlined updated requirements for authors to make NIH-funded manuscripts available in PubMed Central (PMC) immediately upon publication (first date of publication, whether it is "online ahead of print" or print publication date). This removes the 12 month embargo period which is allowed by the current NIH Public Access Policy. Comments were accepted from the public on this Plan until April 25, 2023.
• June 2024 - considering the public comments from the NIH  Public Access Plan, the NIH released the NIH Draft Public Access Policy.
• December 17, 2024: The NIH announced the new NIH Public Access Policy in NOT-OD-25-047. This notice explains the changes from the 2008 policy to the 2024 policy and provides links to the notice on the Government Use License (with sample language for inclusion in manuscripts) as well as a notice on publication costs. 
• All NIH-funded manuscripts accepted on or after July 1, 2025 must be available in PMC immediately upon publication. Besides immediate full text access, there are other significant requirements and recommendations in the new policy.

This summary of the requirements, compliance, publishing costs and enforcement was provided by SPARC, with some additions by Galter Library.

Overall Requirements and Scope

• The Policy requires immediate public access to articles - embargos are no longer allowed.
• NIH reiterates authors do not have to pay a fee to comply with the Policy (beyond standard article processing fees).
• The Policy applies to manuscripts accepted for publication on or after July 1, 2025. This means the Policy will apply to existing grants if the article is published on or after that date. HOWEVER, if a grant was closed before July 1, 2025, manuscripts accepted after this date are subject to the previous requirements (up to 12 month allowable embargo) - see NIH PA FAQ #4 on Scope and Applicability.
• The Policy requires that final peer-reviewed manuscripts be submitted to PubMed Central (PMC) to be made publicly available immediately upon publication.
• The Policy requires that grantees explicitly grant the NIH the right to make the manuscript available in PMC without an embargo.
• The Policy does not explicitly grant full reuse rights of the manuscript to the public.

Compliance

• NIH will maintain its two existing submission pathways: submission of the final peer-reviewed manuscript to PMC directly or submission of the final published article to PMC from a journal that has a formal agreement with the National Library of Medicine (NLM).

Publication Costs

• Submission of the manuscript to PMC remains free under the Policy.
  • NIH notes that any fee requested during the publication process for submission to PMC is not an allowable cost under the new Policy.
• Authors do not have to pay an article processing charge (APC) to comply with the Policy. However, “reasonable” publication costs are allowed to be requested as direct or indirect costs.
  • NIH does not define what a “reasonable” publication cost is.
  • However, the Guidance provides language encouraging authors and institutions to consider a variety of factors when determining if a publication cost is “reasonable,” including sustainability of library or lab budgets and professional or institutional priorities.
• The proposed Policy and Guidance documents (NOT-OD-25-048) outline additional unallowable publication costs, including:
  • Any fee requested during the publication process for submission to PMC (i.e., article development charges or other attempts to extract payment from manuscript deposit).
  • Costs for which the institution already pays a fee that would cover the publication (e.g., costs to publish in a journal for which the institution already has a “read-and-publish” agreement).
  • Costs that are charged differentially because the author is subject to NIH’s Public Access Policy.
  • Publication costs incurred after the closeout of the award.

Reuse of Publications

• The Policy requires grantees to provide NIH with rights to the accepted manuscript that are equivalent to those of the Federal Purpose License [referred to as the Government Use License by the NIH policy itself] (“A royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes, and to authorize others to do so.”). NIH is not proposing to authorize the public to make broad reuse of the work.

Enforcement

• Non-compliance with the Policy, including failure to acknowledge federal funding in the manuscript, may be considered when making future funding decisions for the grantee or cause a delay in the continuation of non-competing grant awards.