The following was submitted by Hindawi in response to the call for feedback on the implementation guidelines of Plan S by cOAlition S.

Hindawi strongly supports the principles and ambitions of Plan S. That funders have collectively agreed to enforce Open Access with a default CC BY licence for academic articles arising from their grants sends a hugely powerful signal to researchers, publishers, institutions and other actors about the future of of scholarly communication. Plan S represents a line in the sand. Funders are no longer prepared to accept a timeline for change that has largely been dictated by actors with a vested interest in maintaining the status quo. This is its power. The potential disruption the plan causes to the industry has justifiably garnered worldwide attention and raised awareness – and opposition – not only among publishers and funders, but among researchers and their scholarly societies.

The ultimate aim of cOAlition S is to make all research outputs freely available to reuse and to ensure that those outputs are reliable. They want rigorous, trustworthy, impactful science and they want that science practiced openly. They want the opportunity for innovation that such science will allow and the greater return on their investment this will create – they want Open Science. The coalition appreciates that there are three fundamental barriers to overcome: changing the existing subscription business model to one of Open Access; changing the current system by which researchers and other actors are ranked and evaluated; and providing the infrastructure and standards to support these changes. Plan S primarily focuses on the first barrier by embracing the APC model of Open Access and targeting hybrid journals in particular. There is no doubt that providing significantly more Open Access to the scholarly literature would be a huge achievement in and of itself.

Open Access, however, is the tip of the scholarly iceberg. And we want Plan S to be the catalyst for change it deserves to be – the catalyst for Open Science – which is after all just good science practiced in a way that takes advantage of the global reach and technology of our digital age. We therefore support the Coalition’s endeavours to obtain more global agreement on their plan – it cannot succeed without this. We also encourage the Coalition to take this opportunity to provide even closer alignment between the proposed timing of the flip to Open Access and the change to the way researchers are ranked and rewarded. Without coupling the change to Open Access with a parallel change in the evaluation of all research outputs, and the infrastructure to support such change, there is a risk we entrench the existing oligopoly of publishers within a cultural and financial system of scholarship that will continue to exclude the diversity, talent and innovation that science – in its broadest sense – requires to address the profound challenges facing society.

Is there anything unclear or are there any issues that have not been addressed by the guidance document?

1. It is not clear the extent to which hybrid journals are compatible with Plan S or for how long. Privileging the business model of these legacy publishers will put new or established Open Access journals, publishers and platforms (such as those led by the Academy at institutions) at a competitive disadvantage.

The potential risk during any transition in which researchers are allowed to publish in established hybrid journals is caused by the current reward system and an infrastructure that primarily supports the large established oligopoly of publishers (whether commercial or not-for-profit). The longer the transition, the more likely the smaller, newer and more innovative entities will fail.

The coalition intends to model the impact of an APC cap on the market. We also encourage them to look at the impact of the plan on those who are already compliant, regardless of the business model.

2. The implementation guidelines clearly state that funders in support of Plan S will sign DORA and comply with the Leiden principles. What is not clear is the timeline for changing the practice of evaluation in line with these recommendations. Without a robust schedule to change the reward system in parallel with the mandate for researchers to make their work Open Access, the system might flip more quickly but further entrench the existing reward culture. This, perversely, could delay the larger change to the system that the Coalition desires because researchers are not being sufficiently incentivised to fundamentally change how they collaborate, share and communicate their work. It will also not promote Open Science practices by publishers and institutions, or indeed any other actor that is subject to the same perverse ranking of the current system, and will further disadvantage emerging innovative platforms and service providers.

3. Plan S details specific technical requirements that would provide some of the infrastructure to enable linking and discoverability of articles and other types of research outputs. Open Science cannot happen without open infrastructure to support open outputs, and is therefore essential if society is to reap the benefits. We recommend that the technical and infrastructural requirements are extended to ensure wider interoperability and that the data about the processes and practice of research are openly available for independent analysis. This can be achieved through the support and establishment of community-driven open standards, open metadata, open integration, open source software and machine-readable outputs and policies.

Economies of scale mean that most large publishers (whether OA or subscription) are able to comply with the technical requirements currently detailed in Plan S. Smaller publishers, including many scholarly societies and Academy-led initiatives that are already providing new, innovative and open publishing services will be disadvantaged. We encourage the Coalition to seek ways to align and support such publishers so that they are not financially disadvantaged and their services are competitive.

4. We strongly agree that the publishing market needs to be more open and transparent, but we are unclear what the Coalition requires in relation to cost transparency from publishers. Institutions and funders, for example, do not request a break down of costs from the suppliers of scientific equipment to researchers. A risk is that publishers will provide numbers, but these will be essentially meaningless and not comparable between providers (e.g. those incurred by a small society publisher and those from a large commercial entity). Stipulating price transparency for publishing services, including the provision of Open Access (regardless of business model) and appropriate peer review, while ensuring the elimination of non-disclosure agreements and contracts that lock-in funders or institutions to a particular provider, will deliver the competitive market required.

5. Plan S focuses primarily on the APC business model for Open Access publishing and stipulates that waivers or discounts should be given to authors from low- and middle-income countries respectively. While we applaud this aim, and have such a system in place at Hindawi, this could potentially further disenfranchise authors in the global south by increasing the global inequity in both cultural and academic capital, which is, in part, the result of the western reward system. How does the Coalition intend to address this?

Are there other mechanisms or requirements funders should consider to foster full and immediate Open Access of research outputs?

1. There are three additional mechanisms we would like to propose:

Provide an equally robust and timed roadmap for changes to the reward system for researchers so that their careers benefit from publishing in Plan S-compliant journals or platforms. They should not be put at a disadvantage compared with colleagues who are not yet restricted to such journals. This is especially important for Early Career Researchers.

Provide support and resources, including financial, for the open infrastructure required to support Open Access. This is particularly important if either pure OA or smaller publishers who are transitioning to OA are not to be placed at a disadvantage. Currently many of these infrastructure initiatives are community driven and funded on a short-term basis by the same few players – this is not sustainable. For example, initiatives such as DORA help to drive infrastructural as well as cultural change. Plan S and many other international policies point to DORA as a crucial marker of change. DORA is more than a declaration. The single staff member, Steering Committee and International Advisory Committee are working to a roadmap to foster best practice and help implement real change to the reward system. It is not just about the Impact Factor and it is not just about articles but other research outputs as well*

Provide a range of criteria – rules of engagement – drawn up by the Academy for publishers providing services to the scholarly community that creates trust for the academic community in those publishers that meet these standards (such as no non-disclosure deals, no lock in, and open metadata). It is important that such criteria are applied to both commercial and non-commercial publishers.

2. There is also an opportunity for funders to work more directly with the Academy, in particular scholarly societies, to foster full and immediate Open Access. At most small- or medium-sized societies, the publishing decisions are ultimately decided by researchers themselves. They are therefore in a unique position to take a leadership position in both the financial and cultural changes required. Most scholarly societies have not yet done this and many have actively opposed the transition to Open Access and have artificially separated the practice of Open Access and Open Science from ‘good’ science and scholarship. They are in a double bind. The perception is that Open Access is a hit to the genuinely valuable work they do for the Academy because it would potentially undermine their surplus and funding autonomy.

The Coalition can work with scholarly societies and other academic institutions to crack open the debate about the value of their non-publishing activities. If these are valued by the community, they should be supported. The beneficial activities of scholarly societies, however, should not be at the expense of access to and discoverability of research outputs. Scholarly societies have been and are a crucial part of the scholarly landscape – we need them to be part of the future. There is now an opportunity for them to reposition themselves in the digital landscape and help lead the discussion about what ‘quality’ in science/scholarship actually means. In collaboration with funders, they can act as a powerful mechanism for change.

*Note that Hindawi is on the Steering Committee of DORA and has helped fund its re-launch alongside the American Society of Cell Biology, Wellcome, Cancer Research UK, eLife, PLOS, the Company of Biologists and EMBO.

The text in this blog post is by Catriona MacCallum. It is distributed under the Creative Commons Attribution License (CC-BY). The illustration is by Hindawi and is CC0.