A new independent expert report published today by the European Commission highlights that, despite notable advancement, the implementation of open access across the European Research Area remains uneven and fragmented. While progress has been made, persistent barriers continue to hinder widespread open access, and further action is needed.
Over the past decade, European Union soft-law measures, national strategies, funder mandates, and, where applicable, national legislation have advanced open access. However, these efforts have not yet produced a coherent framework across the European Research Area, leaving researchers, institutions, and funders to navigate differing policies.
The report provides a snapshot of the current open access landscape, offering policy recommendations to improve access to scientific publications and research data. It draws on an analysis of all 27 EU Member States and eight non-EU countries.
Uneven progress and the challenge of fragmentation
The report acknowledges real progress in open access adoption but highlights that this progress has been uneven, with fragmentation persisting across the European Research Area. Member States continue to differ substantially in areas such as policy instruments, legal enforceability, embargo periods, copyright mechanisms, repository requirements, funding models, and monitoring systems. This lack of harmonisation creates complexity, particularly for cross-border research collaborations.
What drives success, and where policies fall short
The report identifies key patterns in effective open access implementation. Multi-instrument frameworks, combining national legislation, funder mandates, and institutional support, achieve higher and more consistent uptake than single-instrument approaches. Research assessment-linked mandates drive measurable behavioural change, while policies without institutional operationalisation (such as deposit workflows, library support, or compliance monitoring), often fail to deliver results. The findings also stress how the Diamond Open Access model, which provides free access to research for both readers and authors, is gaining momentum. The fragmentation of open access policies across the European Research Area is also reflected in the degree to which adherence to Findable, Accessible, Interoperable and Reusable (FAIR) principles for research results is operationally enforced and in the diversity and uneven development of monitoring systems, which makes it difficult to track progress and gain a clearer overview.
Persisting barriers: costs, misaligned incentives, and legal uncertainties
Despite progress, significant obstacles remain. Fragmented national policies restrict the free flow of knowledge and create legal and administrative uncertainties. In most Member States, research assessment systems remain insufficiently aligned with open access objectives, often rewarding prestige and closed publication channels over openness. Rising Article Processing Charges (APCs) represent a major concern, both within and beyond Europe, posing a structural barrier that disproportionately affects under-resourced institutions and researchers. The report calls for systematic tracking of APC and read-and-publish expenditure, and for the publication of contract terms where public funding is involved.
A call for concerted action at national and EU levels
As some non-EU countries have moved toward immediate open access and progress within the EU is varied, the report offers recommendations for both the Member State and European Union levels.
At the national level, it is proposed to adopt multi-instrument policy frameworks, implementing mandatory Data Management Plans, and to move in the direction of immediate open access for publicly funded research. The report also recommends giving researchers a secure legal basis for open access, open licensing as the default (with exceptions for some formats), minimum standards for trusted repositories, sustainable funding models, further alignment with research assessment systems, and systematic monitoring. Additionally, it calls for alignment between open access policies and national strategies on research security and internationalisation, treating them as complementary rather than competing agendas.
At the EU level, the report suggests strengthening coordination through National Points of Reference, developing European Research Area-level monitoring frameworks, and using programme design to incentivise uptake. It also recommends leveraging the ERA Act to move toward a more coherent European Union approach. The report further notes that in several Member States the Recovery and Resilience Facility has functioned as a de facto EU-level open science infrastructure fund; this supports the case for sustained, dedicated EU financial and programmatic support for open science infrastructure as part of any ERA Act implementation framework.
The report concludes that decisive action at both national and EU levels is needed to overcome persistent barriers. However, the report also argues that there is no single approach, rather, durable progress requires a combination of binding requirements and incentives, support structures, interoperable infrastructure, and reform of the environment in which researchers are evaluated. Only by addressing fragmentation, misaligned incentives, and rising costs while improving collaboration and monitoring can the European Research Area fully realise the potential of open access.
