The Confederation of Open Access Repositories (COAR) reiterates our support for the goal of Plan S to achieve “immediate Open Access to all scholarly publications from research” and we appreciate the opportunity to provide feedback on the guidance on the implementation of the Plan.

We recognize and agree with the aim of transforming the publishing industry, however to truly improve and transform the system there needs to be a multipronged approach, with a number of actions undertaken concurrently. We would like to stress the importance of repositories as complementary mechanisms for advancing innovation in research communications, as outlined in the COAR Next Generation Repositories report and ensure that their role is adequately reflected in Plan S.

In general, COAR supports the implementation guidelines outlined in Plan S and therefore we will focus our comments on the requirements for repositories. COAR and others in the repository community have significant concerns related to several of the requirements for repositories, a number of which we argue are not necessary and will create artificial barriers to the participation of universities and other research organizations in the scholarly communication system. While some of these recommendations may be ‘nice to have’, they are not prerequisites for robust and interoperable repository services. Instead they could result in driving repository functionality in the wrong direction, create too high of a bar for less resourced institutions, and further centralize research infrastructures and services because they cannot be adopted, leading to a replication of the existing inequalities in the scholarly communication system.

The full response is available here: COAR response to implementation of Plan S