Institutional Open Access Policies: A Setup Guide

Most universities already run a repository. Far fewer have a policy that fills it. Here is how to draft, approve and run one that researchers will follow.

Guide · 11 min read · Directive Publications Editorial Team

What an institutional policy adds

Funder mandates already require open access for a lot of medical research. Under the revised NIH Public Access Policy, accepted manuscripts from NIH-funded work accepted on or after 1 July 2025 must be submitted to PubMed Central on acceptance and made public without embargo on the official publication date. UKRI requires research articles submitted from 1 April 2022 to be open access at publication, either in the journal or as a repository copy with no embargo. Funders in cOAlition S use grant conditions that require open access at publication, normally under a CC BY licence.

Those mandates follow the grant, so an unfunded case series or a trainee's first paper falls outside them. An institutional open access policy closes that gap by applying to your authors rather than to their funding.

A well-built policy does two separate things:

• It secures permission. Authors grant the institution a non-exclusive licence to their scholarly articles, ideally before they sign any publishing agreement.
• It sets a deposit habit. Authors, or staff acting for them, deposit the accepted manuscript in the institutional repository.

Keep those two provisions distinct in everything you write. If colleagues still believe open access means paying a fee, deal with that first; our post on open access myths that still mislead research offices gives you the replies.

Step 1: Map the obligations researchers already carry

Before drafting anything, find out what your authors already have to do, so the policy works with those obligations instead of adding a second, conflicting set.

Gather four things:

1. Funder requirements. For each major funder in your grants portfolio, record the version that must be open, the licence, the repository, and whether any embargo is allowed. Jisc Open Policy Finder, which combined the former Sherpa Romeo, Juliet and Fact services, holds funder conditions and journal archiving policies in one place.
2. Repository capability. Confirm the repository can hold dark deposits, release embargoed files automatically on a set date, show metadata while a file is closed, and be crawled by search engines.
3. Publication data. Find out where the institution's list of outputs lives: a research information system, annual faculty reports, or a bibliographic database. You will need it to measure compliance.
4. Publisher agreements. Note any read-and-publish or other transitional agreements the library holds, because they change which route is easiest in particular journals.

Put the results on one page. It becomes the first thing you show faculty.

Step 2: Form a faculty-led working group

The Harvard Open Access Project's Good practices for university open-access policies, written by Peter Suber and Stuart Shieber, recommends that faculty adopt the policy rather than the administration imposing it: the policy affects faculty most, and a grant of rights should rest on their consent. If the idea started in the library or research office, recruit faculty to lead it.

A workable group includes:

• two or three respected researchers, including a clinical academic if you have a medical school
• the repository manager or scholarly communications librarian
• a research office lead who knows the funder landscape
• legal counsel
• someone from graduate education, if students or trainees will be covered

Give counsel the draft implementation plan as well as the policy text. The guide notes that US counsel often object that a later publishing contract will override the policy licence. The answer sits in implementation: section 205(e) of the US Copyright Act gives a non-exclusive licence priority over a later conflicting transfer if it is evidenced by a written instrument signed by the rights holder and taken before the transfer, so US institutions following this model collect a signed affirmation. The guide also cites UK legal advice that reached a similar result through notice to publishers. Take local advice.

Step 3: Choose the policy model

The Harvard guide describes six types of university policy. These four cover the real choice most institutions face:

Decision rule: aim for rights retention with a waiver. If that cannot pass, adopt a deposit mandate with dark deposit. If neither can pass, the guide suggests a policy that encourages deposit, or waiting, rather than an opt-in scheme, which it treats as equivalent to no policy.

That also settles "mandatory or voluntary?" A waiver keeps the decision with the author for every article while the default shifts to open. The guide reports waiver rates below 5% at both Harvard and MIT.

Keep the policy about repository deposit. If you also pay publication fees, run that as a separate fund, as the guide recommends, so no one reads the policy as limiting where they can submit. Our post on APC waivers and funding language covers that guidance.

Step 4: Draft the scope and rights clauses

Short policies pass more easily and age better. A policy adopted by faculty vote is hard to change by another vote, so put only the essentials in it and leave procedures to a named office.

Work through these clauses:

• Grant of rights. Word it as a present grant ("each faculty member grants"), not a future promise ("will grant"), so it applies before any publishing agreement is signed.
• Content. Cover scholarly articles of the kind published in peer-reviewed journals and conference proceedings, not royalty-earning books or non-scholarly writing. Do not limit the grant to "published" or "peer-reviewed" articles: by then many authors have already signed away their rights. Apply that narrowing to deposit instead.
• Authors. Decide whether to cover faculty only, or staff, postdocs and students too. Harvard and MIT began with faculty and later offered a licence other researchers can sign. In medical schools, check whether clinicians employed by affiliated hospitals hold appointments that bring them into scope.
• Time. Forward-looking only. Earlier articles cannot be covered by the grant, though you can invite deposit.
• Version and timing. Require the author accepted manuscript, deposited on acceptance or no later than publication. Link authors to a plain explanation of preprints, accepted manuscripts and versions of record.
• Waiver. Per article, no justification needed, and not revocable by the institution. It waives the licence, not the deposit.
• Embargo option. Let authors delay access for a specific article without waiving the licence. The guide's experience is that many publishers who ask for a waiver will accept an embargo.
• Licence. Decide whether deposited manuscripts will carry an open licence. Funders following the cOAlition S Rights Retention Strategy require CC BY on accepted manuscripts, with CC BY-ND by exception. The guide recommends dropping the "not sold for a profit" proviso found in early Harvard wording where you can, because that gives the institution the rights needed to authorise CC BY.

Step 5: Build the deposit workflow

Design the workflow before the vote, so faculty can see what compliance asks of them.

Three details prevent most problems:

• Accept dark deposits. "Always deposit" is a simpler message than a list of exceptions, and a closed file can be opened when permission arrives.
• Handle the wrong version. If an author uploads the publisher PDF without permission to share it, keep it dark and ask for the accepted manuscript.
• Check clinical content. Before a file goes open, confirm that patient consent and any third-party permissions for figures cover the repository copy, not just the journal version.

Step 6: Approve the policy and notify publishers

Hold open meetings during drafting and before the vote. The Harvard guide's advice is not to rush: keep holding them until faculty stop coming. Make three points plainly:

• the policy is about repository deposit, and authors stay free to choose where they publish
• the waiver guarantees that choice for every article
• a publisher that objects can require a waiver as a condition of publication, so faculty need not vote against the policy to protect a society journal they value

Then take the policy through your faculty governance body, such as an academic senate or faculty council, with legal review complete. The exact route depends on your statutes.

After adoption:

1. Publish the policy and implementation plan on a stable web page.
2. Add the licence affirmation to deposit forms and, where counsel advises, to new faculty agreements, as Harvard does.
3. Notify publishers, which matters most where the legal position depends on publishers having notice.
4. Name the responsible office and give it a contact address.

Step 7: Support authors from the first week

The guide warns that authors who do not deposit at acceptance may be too absorbed in new projects to do it later. Make the right action the easy one.

• A one-line rule. The guide cites Oxford's phrase "Act on Acceptance": save the accepted manuscript and deposit it before moving on.
• A waiver web form. Keep it short and confirm by email, so authors see the process is automatic.
• Funder wording. Authors funded under rights retention conditions may need a statement in their submission. Give them each funder's current text verbatim.
• A publisher-objection script. If a publisher asks for a waiver, the author asks whether an embargo would do, and contacts your office before signing.
• Training at the right moments. Cover the policy in new faculty induction, graduate research training and grant-award onboarding.
• Visible value. Consider inviting readers of repository copies to say how access helped them, a technique the guide credits to MIT.

Step 8: Monitor compliance and review the policy

Counting what is in the repository is easy. The hard part is the denominator: how many covered articles should be there.

Start with the institution's own records, such as a research information system or annual faculty publication lists, broken down by output type. Open data can fill gaps: OpenAlex, for example, lets you filter works by an institution's ROR identifier and group them by open access status.

Track a small set of measures each year:

Report by department and treat low figures as a support problem first. Some institutions go further and only consider repository-deposited articles in internal reviews such as promotion. That is a significant change to research assessment, so decide it separately.

Schedule a formal review after the first full year, and again whenever a major funder changes its conditions.

Where to begin

Start with the one-page map from Step 1. Everything after it follows from choosing a model your faculty will vote for.

Authors covered by your policy who publish with Directive Publications can check journal requirements on the For Authors page before they submit.