Navigating Publishing Agreements and Funder Requirements

New US Federal Agency Public Access to Publications requirements that no longer allow authors to embargo access to their author-accepted manuscript (AAM) have created uncertainty about how publishers and publication agreements will change, and under what circumstances authors will need to pay a fee for full open access publishing.

We will learn more in the coming months and continue to update this page with new information. Last updated: November 24, 2025

Complying with “Zero-Embargo” Public Access Requirements

If your research is funded by an agency that mandates immediate public access (zero embargo), you have the following options:

1 – Find a publisher that allows immediate public access compliance

2 – Pay for Open Access 

  • You pay the journal’s Article Processing Charge (APC) to make your article openly available from the publisher. This allows you to deposit the AAM in the repository designated by your funder immediately upon publication.
  • Implications: You comply with both your funder requirement and the terms of your publishing agreemet, but it requires securing funding for the APC.

3 – Do Not Pay for Open Access & Deposit Your AAM

  • You agree to the terms of the publisher’s traditional subscription publishing agreement. You agree in those terms not to deposit your AAM without an embargo. Nonetheless, you deposit your AAM in the funder-designated repository without paying for open access publishing
  • Implications: Doing so may violate your publishing agreement. Potential consequences include publisher sanctions, legal disputes, or restrictions on future submissions. For more information, see the Authors Alliance NIH Public Access Policy: Q&A for Authors.

4 – Do Not Pay for Open Access & Do Not Deposit Your AAM

  • You agree to the terms of the publisher’s traditional subscription publishing agreement. You follow the terms of the publisher’s agreement not to deposit your AAM without an embargo.
  • Implications: You will be out of compliance with your federal award agreement, resulting in likely funding delays, reputational impact, and future grant ineligibility for you and the university.

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