How to Reform Publishing Without Dismantling Open Science: A Reply to CRUK

For over 25 years, JMIR Publications has operated on a simple premise: health research should be immediately and freely accessible to all. However, recent policy changes from major funders like Cancer Research UK (CRUK) now threaten to dismantle the very "Full Open Access" model that made this possible. By cutting all APC support, these policies risk stifling independent, scholar-led publishers while leaving the massive revenue streams of legacy publishers untouched. Below, we share our response to CRUK and propose five alternatives that reform the system without sacrificing the progress of the last two decades.

We'd like to hear what you have to say. Please take a moment to add your comments below.

Dear colleagues at Cancer Research UK,

I'm writing on behalf of JMIR Publications, a mission-driven, scholar-led, full open access publisher founded in 1999. JMIR Publications was founded by an academic, Dr Gunther Eysenbach (the most cited health informatics researcher) and remained fiercely independent to this date. We share your critique of the big commercial players which is exactly why we founded the Journal of Medical Internet Research and now over 30 other journals outside of the “big 5” commercial publishers.

While we started as an unfunded journal in 1999 in a university setting (you would now call this a Diamond OA journal), the success and impact ranking of our journal meant that we had to scale up and professionalize our operations, which was not possible in an academic setting, which is why we incorporated as a business in 2011, growing our portfolio of now over 30 journals with focus on Digital Health but also other topics, mostly with a technology angle. Our journals are top-ranked and respected in the community (see our portfolio at jmirpublications.com). For over 25 years, we have been committed to making health research immediately and freely accessible worldwide, without subscriptions or embargoes. We employ a staff of about 100 people who are paid fair salaries and include highly qualified MDs and PhDs.

We have a long history of publishing research funded by Cancer Research UK across multiple journals in our portfolio, including JMIR Cancer, JMIR Public Health, JMIR Research Protocols, and others. This reflects a shared commitment to maximizing the reach, impact, and societal value of publicly and charitably funded research. We actively promote research on our social media channels, write press releases, and invite researchers to talk about their research in our YouTube channel (https://www.youtube.com/@jmirpub). As such, we are complementing CRUK’s mission and what your press office already does, which is disseminating research findings to the public. All for reasonable one-time article processing fees ranging from $950-$3500 for our top journals, which are ranked Q1 in their disciplines.

1. A policy aimed at fixing hybrid publishing will instead damage full open access

We fully recognize—and share—your concerns about the inefficiencies and inequities of the current publishing system, particularly the issue of “double dipping” in hybrid journals (which is actually a triple-dipping if you also consider licensing to AI companies).

However, the decision to withdraw all APC funding, including for fully open access journals, does not target the root problem. Instead, it disproportionately harms the very segment of the ecosystem that already aligns with your stated goals.

Full OA publishers like JMIR:

• do not charge subscription fees
• do not benefit from transformative agreements (because we are already “transformed” or more precisely born open access, libraries do not sign transformative agreements with us)
• rely on a single revenue stream (APCs) to fund peer review, editorial work, and dissemination

By contrast, large legacy publishers retain multiple revenue streams (subscriptions, hybrid APCs, licensing—including to AI companies). Removing APC support weakens independent OA publishers while leaving incumbents structurally intact. If this policy is copied by other funders, it means that funders completely abdicate their role in knowledge translation and quality control, shift costs to institutions and essentially put full open access publishers out of business. Some may argue that research dollars should not support any business whatsoever but then you should extend this policy also to other businesses and vendors in the research ecosystem that support the work of researchers on a for-profit basis, ranging from companies which supply monoclonal antibodies to airlines that fly researchers to conferences, or ban using the products of Microsoft and Apple which have higher profit-margins than publishers.

2. “Green OA” is not cost-free—it shifts costs and entrenches subscriptions. Diamond also is not “free”

Your policy promotes “green open access” (repository deposit after embargo) as an alternative. However, this is not a neutral or cost-saving solution:

• It relies on subscription journals for peer review and validation
• It delays access at the point of highest impact
• It shifts costs to libraries, which must maintain subscriptions indefinitely
• It reverses progress toward immediate open dissemination

In effect, this approach reinforces the subscription system you rightly criticize, rather than disrupting it.

Similarly, the call to publish in “free” venues such as Diamond journals is highly problematic as the funding streams for Diamond journals are unresolved. In principle any Gold OA journal (including ours) can be turned to Diamond if there would be predictable funding. But it is not possible to produce professional journals especially in the medical field without funding. Most Diamond journals published in the social sciences and humanities, are very small and not indexed, and rely on volunteer labor which is not scalable, especially not in the medical field.

3. The policy risks eliminating the “long tail” of independent OA publishers

Much of the discourse focuses on large commercial publishers, yet they represent only a portion of the ecosystem. A significant share of research is published by smaller, independent, scholar-led publishers operating on tight margins.

For these publishers:

• APCs are not profit extraction, but cost recovery
• editorial work is performed by paid professionals (MDs, PhDs, technical staff)
• there is no fallback revenue stream

Removing APC funding does not reform these publishers—it removes their ability to operate.

If adopted more broadly by other funders, this policy risks:

• forcing full OA journals to revert to subscription models, or
• driving them out of existence altogether

This would represent a structural rollback of open access.

4. A small cost with disproportionate impact

Historically, APC funding has represented a very small fraction of total research investment (on the order of ~0.4%), yet it underwrites:

• peer review infrastructure
• editorial quality control
• global dissemination and visibility

Eliminating this funding does not eliminate the need for these functions—it simply displaces the cost elsewhere while reducing access.

5. A more targeted and effective policy approach

If the goal is to address inefficiencies and excessive pricing, there are more precise interventions available:

• Exclude hybrid journals from APC funding
• Introduce APC caps tied to transparent cost structures
• Define eligibility criteria for “sustainable OA publishers” (quality + pricing)
• Support competition among full OA publishers rather than removing their funding base

These approaches would directly address the problems identified—without undermining compliant actors.

6. A shared goal, but a contradictory outcome

We agree with your core objective: a system that is fair, efficient, and serves science rather than profits.

However, the current policy risks achieving the opposite:

• strengthening subscription-based models
• disadvantaging fully open access publishers
• reducing immediate access to research
• consolidating power among the largest incumbents

In short, it emboldens the system it seeks to reform.

Request to amend your policy

We urge Cancer Research UK to reconsider this policy, or at minimum to carve out explicit support mechanisms for fully open access publishers. A differentiated approach—targeting hybrid inefficiencies while preserving full OA—would better align with your mission and avoid unintended systemic consequences. We would welcome the opportunity to engage constructively and explore alternative funding models that achieve shared goals without destabilizing the open access ecosystem.

If adopted by other funders, this model risks systemically dismantling mission-driven full open access publishers such as JMIR Publications and Public Library of Science—organizations that have played a foundational role in advancing open science over the past two decades.

Constructive paths forward

We want to emphasize that we are not merely critiquing this policy—we are committed to working with Cancer Research UK to develop viable alternatives.

At a minimum, we urge consideration of one or more the following policy options:

1. Carve out explicit exceptions for fully open access publishers: Allow APC funding for compliant full OA journals/platforms, potentially as an automatic allocation (e.g., ~0.4% of grant value earmarked for dissemination and quality control).
2. Target the actual problem: hybrid journals: Restrict or eliminate APC support for hybrid journals rather than applying a blanket ban that disproportionately harms full OA. This is the policy that was recently adopted by UK Research and Innovation (https://www.linkedin.com/posts/next-phase-of-open-access-at-ukri-ugcPost-7454463002151391232-ZwEl ). We would also ban APC use for hybrid journals covered by transformational agreements as these agreements are rarely transformative. They are just a way for legacy publishers to sell Read & Publish agreements without a clear commitment to switch to 100% open access. If you want 100% open access, then fund 100% open access. Libraries currently fund the promise of transformation, but not already transformed - or fully open access - publishers.
3. Introduce APC caps and eligibility criteria: Allow APCs but restrict them to full OA publishers with limits. Define what constitutes a “responsible” OA publisher based on transparent pricing, quality standards, and reinvestment in the research ecosystem.
4. Direct institutional reimbursement mechanisms: Work with Jisc or similar bodies to reimburse libraries for publication in approved full OA venues, rather than channeling funds into transformative agreements.
5. Support alternative peer-review infrastructures: Fund peer review and curation directly (e.g., preprint review models), decoupling dissemination from legacy journal cost structures.

We are open to active dialogue on next-generation publishing models, including preprint-first workflows with funded peer review and curation, such as those we are piloting through our JMIRx overlay journals under the Plan P (Publish–Review–Curate) framework, which will be administered through a non-profit open science entity. These models directly address cost, speed, and transparency concerns while preserving immediate open access.

We would very much welcome a direct conversation to explore these options collaboratively.

Sincerely,

JMIR Publications