The Canadian Research Knowledge Network (CRKN) has submitted a response to the draft revision of the Tri-Agency Open Access Policy on Publications, emphasizing its importance in establishing open access as the default for Canadian-funded research. In preparing its feedback, CRKN consulted its member institutions across the academic library community, with final input reviewed by its Board of Directors.
CRKN raised concerns about the implications for diamond open access journals under the proposed policy. Since the draft mandates that all funded articles be deposited in institutional repositories (IRs), articles published in fully open access diamond journals—those with no subscription or author fees—would no longer be automatically compliant. This position appears inconsistent with recent updates to the SSHRC Aid to Scholarly Journals program, which supports the diamond model. CRKN noted that Canada maintains a robust ecosystem of diamond journals, particularly in the humanities and social sciences, and recommended that such journals be recognized as compliant without requiring additional repository deposit.
On author rights retention, CRKN welcomed the policy’s explicit support, particularly the requirement for authors to declare rights retention upon submission. This provision is seen as strengthening CRKN’s position in negotiations with commercial publishers. However, the organization expressed concern over the policy’s allowance for depositing pre-print (unrefereed) versions of articles, arguing that this may undermine efforts to secure rights to deposit the version of record (VOR) or author-accepted manuscript (AAM). CRKN warned that the proliferation of unrefereed versions could compromise the quality and trustworthiness of research outputs. To mitigate this, CRKN recommended that the AAM be the minimum version for compliance and urged the Tri-Agency to adopt standardized terminology, such as that in NISO-RP-8-2008, for article versions.
The feedback also addressed practical challenges associated with institutional repository infrastructure. CRKN observed that university libraries, which often serve as IR hosts, will face increased workloads as a result of the policy. Smaller institutions may encounter particular difficulties supporting researchers, creating disparities in compliance capacity. The organization further emphasized that repository discovery remains a known issue in scholarly communications, and without enhanced resourcing, the policy’s goal of public access to research may be undermined. CRKN advised that institutions be encouraged to allocate a portion of their indirect research cost funding to support IR infrastructure.
CRKN also recommended that compliance mechanisms be incorporated into the final policy. Suggestions included requiring researchers to include links to deposited articles in grant reports and future applications, and flagging open access outputs in CVs. These steps, the organization argued, would strengthen accountability and reinforce awareness of the policy. Additionally, CRKN suggested the Tri-Agency consider encouraging universities to adopt institutional open science policies to support broader compliance.
Regarding embargoes, CRKN asked for clarification in the policy to confirm that deposited articles must be made immediately available, without embargo. It argued that explicit language would support negotiations with publishers and assist authors in meeting policy expectations.
Finally, CRKN emphasized the need for consistent use of persistent identifiers (PIDs), including ORCID iDs, DOIs, and funder IDs such as those in Crossref’s Open Funder Registry. Citing existing national coordination through initiatives like ORCID-CA, DataCite Canada, and the Canadian Persistent Identifier Advisory Committee (CPIDAC), CRKN recommended that the policy require use of funder identifiers in acknowledgements and strongly encourage ORCID adoption across the research lifecycle. This, it stated, would improve tracking of publications, streamline compliance processes, and enable better understanding of the dissemination and impact of Canadian research outputs.
Click here to read the original press release.
