The member organisations of IARLA welcome moves towards an open access environment for journal articles and aligned funder policies to achieve this. We are therefore supportive of the overall objectives of Plan S as published by cOAlition S.

We note the iterative nature of the Plan S Guidance and believe that there have been a number of welcome changes since the first version was published. Specifically, we view the following changes as positive:

  1. An extended deadline for implementation to allow greater time for all stakeholders to prepare.
  2. Flexibility on licensing terms – while continuing to prefer CC-BY we welcome the allowance for CC-BY-ND in some cases. This change reflects specific concerns in the arts and humanities communities and acknowledges differences in academic practice.
  3. Greater detail on the support needed to ensure that authors retain the rights they need. We welcome the undertaking that cOAlition S will “develop … mechanisms to ensure that no author needs to negotiate individually with publishers the right to make an article Open Access.”
  4. The explicit statement that un-embargoed deposit in repositories will be a route to compliance. And the relaxation of the initial, overly-stringent technical specifications for compliant repositories.
  5. The addition of the new Principle 10, which commits to moving away from journal metrics as a means for research assessment, and the stated commitment to DORA. We agree there is a clear need to changing the research reward and incentive system in order to reward open scholarship practices.

The research library community would still like to see:

  1. Further clarity on the nature of transformative agreements and description of the expectation of what the next steps will be when hybrid funding ends on 31 December 2024.
  2. Large-scale financial model of the costs of a fully Plan S compliant environment. To date there has not been a sufficiently systematic international modelling of the costs either during the transitional period, or in a post-2024 environment of compliance with Plan S – either in terms of publisher costs or administrative infrastructure costs within and between institutions. We have particular concerns that research-intensive institutions may see significant increases in costs, and that cross-disciplinary research and international collaborations may suffer from complicated financial models.
  3. Modelling of the possible impacts on smaller, mainly arts, humanities and social sciences institutions and publishers and an analysis of the danger of further market consolidation.

The members of IARLA commit to advance open access as put forward in the Plan S Principles within our respective jurisdictions (Australia and New Zealand, Canada, Europe, the United Kingdom, and the United States).

We also offer our support to cOAlition S and other funders in advancing their priority actions, and especially those around:

  1. Transformative publisher agreements. We will work, adhering to library community principles and guidelines, to ensure our agreements with publishers move us towards their stated goal of equitable and sustainable models of full and immediate open access. We will further pursue transparency by advocating for and encouraging registration of Transformative Agreements in the ESAC Registry.
  2. Transparency in pricing. We agree with the call for “full transparency and monitoring of publication costs and fees” and offer our support in the proposed “on-going monitoring to maintain transparency and a clear understanding of costs and prices”.
  3. Monitoring and compliance. The library community holds significant data in areas of interest around compliance – including volume of material hosted in institutional repositions and APC expenditure. We will work with cOAlition S and other funders to ensure that any monitoring frameworks provide measurable results.
  4. Rights retention. We are well placed to work nationally and internationally to help develop practical implementation plans to allow authors and institutions to retain the rights necessary to make their outputs open access.

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