ONOS’s APC Guidelines: Opening Access or Opening Pockets?

In light of the newly introduced ONOS guidelines on Article Processing Charges, Hafsah takes a closer look at the issues they raise and offers thoughtful suggestions on how ONOS could approach them more effectively. Hafsah Azhar Ansari is a third year student at NALSAR University of Law, Hyderabad.

ONOS’s APC Guidelines: Opening Access or Opening Pockets?

By Hafsah Azhar Ansari

India’s One Nation, One Subscription (ONOS) scheme introduced new guidelines for covering Article Processing Charges (APCs) in “high-quality” open-access journals, which are applicable starting this year. On paper, that sounds like a win for Indian researchers struggling with steep publishing costs. But a closer look at the fine print, and at the patterns bloggers at SpicyIP have been tracking for years (read more here and here), suggests we might be funding openness on the surface while quietly propping up the same publishing structures that made research expensive in the first place.

From ‘Access for All’ to ‘APCs for Some’

When ONOS launched, it promised universal access to research from thirty major publishers for Indian scholars (think of it like a kind of national Netflix for research). The new APC Guidelines extend that promise: the government will cover fees for certain open-access journals.

But the fine print is tricky. Only first or corresponding authors from ONOS-registered institutions qualify, and the journal must be in the top 1% of its Scopus field (a very small, elite club). Applications go through a nodal officer, are verified, and payments flow via PFMS straight to the publisher. It’s first-come, first-served, and authors must confirm no other grant is paying their fees (surprise surprise, could be tricky in practice).

A neat pipeline on paper, but as anyone familiar with government portals knows, it doesn’t guarantee fair access in reality.

The Promise: Lowering Barriers to Publish

APCs have become a real barrier for Indian researchers, that much is obvious. Publishing in reputed open-access journals can cost numbers that would make most public university scholars wince (read more about this IIM-A study, here) . So yes, this scheme could, in theory, make high-impact OA journals financially reachable for the first time.

It also sends an encouraging signal. The Guidelines favour fully open-access journals, not hybrids (where authors pay APCs but the publisher still keeps subscriptions). That’s a subtle but important distinction. It nudges Indian academics toward genuinely open platforms and aligns with the global push to make publicly funded research freely available.

And there’s another possible upside: scale. By creating a national mechanism for APC payments, India could negotiate better rates with big publishers, similar to what the EU did under Plan S and South Africa under SANLiC (read more here, here, here, and here). In fact, when one of our editors at SpicyIP covered the ONOS launch last year (read here), he noted that India’s biggest bargaining chip is the size of its research output. This could give us leverage (if the government actually plays its card right), in a market dominated by Western publishing cartels.

But, (and of course there’s a ‘but’), leverage only matters if the deals themselves are transparent, and perpetual access, archive rights, APCs, copyright terms – none of this is public. Without clarity on what India’s actually buying, scale might just mean we’re making bigger, opaque deals instead of smaller ones (read more at an LSE piece here).

The Problem: Who Defines ‘Good’ Open Access?

The Guidelines define ‘quality’ almost entirely through Scopus, allowing only journals in the top one percent of each subject area to qualify. Since Scopus is owned by Elsevier, a major recipient of ONOS subscription funds, the same publisher effectively decides which journals can access public funding (an obvious conflict of interest!). This mirrors concerns from the UGC-CARE List controversy earlier this year, where reliance on private indices threatened domestic quality checks. As a result, Indian journals, especially regional-language or locally focused ones, are left out, reinforcing a hierarchy favoring Western-indexed, English-language journals. 

That’s not just a philosophical problem, it’s a policy one. UNESCO’s Open Science framework explicitly calls for multilingual and community-driven research ecosystems. If ONOS funnels all its funds into the same handful of global publishers, the (smaller) Indian-language and independent journals will keep struggling. Unless the government supports ‘Diamond OA’ models – where neither authors nor readers pay, this system might widen the gap between elite and regional scholarship.

The Global Lens: Lessons from Plan S and SANLiC

Looking at other countries helps put ONOS in perspective. Europe’s Plan S makes clear that public APC funding requires a ‘CC BY’ licence, letting anyone reuse or adapt the work. Similarly, South Africa’s SANLiC deals also prefer CC BY and insist on price transparency (read here and here). ONOS, however, is silent on this front. That might sound like a technical detail, but without a mandate, publishers can keep restrictive licences like CC BY-NC or even retain copyright (read more about CC licences, here). Which means the government could end up paying for ‘open’ papers that aren’t really open to reuse – essentially buying ‘free-to-read’ access that’s not ‘free-to-use.’

One of our editors had flagged this pattern earlier as well, noting that the ₹1,800-crore budget seemed to cover payments even for OA articles already free to access. If the APC fund repeats that logic, we’re paying twice: once to access the paper, and again to publish it.

The Market Trap: When Everyone Pays, Prices Rise

Economics 101: when buyers stop worrying about price, sellers stop keeping prices low, and APC markets are no different. Analyses show that open-access revenues at six major publishers have tripled since 2019, while the median APC paid by researchers has risen faster than inflation, yet submissions to high-impact OA journals keep increasing (prestige, it seems, beats prudence. Read more, here). This dynamic could repeat under ONOS: first-come, first-served disbursements may favour well-resourced institutions like IITs and IISc, leaving smaller state universities behind. The Guidelines do mention a possible “ceiling per author or institution,” but it’s optional. Maybe it really shouldn’t be.

And there’s another issue of access: ONOS Phase 1 still covers only 30 publishers (out of 70 negotiated), and many colleges haven’t been onboarded yet (read our Editor talking about this earlier, here). But the problem runs far deeper: the APC fund is tied entirely to ONOS-registered institutions. Independent researchers, smaller private colleges, and non-profit research centers are just…. out of luck. If the system paying APCs doesn’t yet guarantee equal reading access, and now leaves entire research communities out of publishing support too, this fund risks creating a small, privileged publishing elite (the very thing ONOS was supposed to break down) (The irony isn’t lost on us).

Implementation Headaches and Legal Safeguards

To be fair, ONOS isn’t ignoring the governance side completely. The APC workflow includes institutional verification, co-author declarations, and direct PFMS payments to publishers, all sensible moves that reduce fraud risk.

Still, the guidelines are silent on what happens when things go wrong. What if a claim is rejected without reason, or a payment delayed? There’s no grievance mechanism, no public APC data, no list of approved journals, no record of disbursements. Now, these are only guidelines, not binding rules – but that’s why the gap matters! With so much public money and research at stake, India needs a framework with clear rights, remedies, and oversight. Without it, accountability risks becoming an afterthought.

Predatory-proofing remains a real concern. While the “top 1%” rule may filter out fake journals at first, journal quality isn’t static. For example, in 2023, Wiley retracted over 8,000 articles from Hindawi journals due to links with paper mills (check, Retraction Watch). Cases like this show that journals can degrade over time. A one-time vetting just isn’t enough; annual reviews are essential. If ONOS wants to truly champion open science, it also needs to practice open governance.    

What ONOS Should Do Differently

So where does that leave us? Here’s what could actually make ONOS work for the people it’s meant to serve:

  1. Mandate open licences. Require ONOS-funded papers to carry CC BY or equivalent licences. Public money should buy public rights.
  2. Publish the data. Make quarterly dashboards public: how many APCs funded, how much paid, which journals, which institutions.
  3. Negotiate price caps. If India can bargain collectively for subscriptions, it can bargain for APC ceilings too. Otherwise, ‘read and publish’ deals risk turning into ‘pay and pay.’
  4. Support diamond and regional OA. Set up a parallel fund for Indian-language or society-run journals, with quality checks akin to UGC-CARE.
  5. Add grievance and audit systems. Create clear and transparent appeal processes and annual independent audits, ideally with participation from academic and civil society.

Closing Thoughts

For the first time, India isn’t just investing in access to read research, it’s also paying to make its researchers heard. That’s progress!! However, infrastructure without true openness can just entrench old systems under a fresh label.

If ONOS wants to live up to its name, it needs to think beyond subscriptions and APCs. It must protect diversity in scholarship, demand open licensing, and resist price inflation. Otherwise, this brave new ‘open’ system might end up doing what old systems always did: open access for some, but mostly opening pockets for everyone else.

I thank Swaraj Sir for his input! 

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