In this blog post, which is written from the perspective of the Funding Task Force of the national Service Centre for Diamond Open Access (SeDOA), we comment on the concept for a Germany Fund for Diamond Open Access (DeFDOA), in which SeDOA is explicitly mentioned and foreseen for certain tasks. Rather than going into all the details of the concept here, we shall focus on several points that we consider especially important. This post does not constitute an official position on the DeFDOA project. 

Originally developed by Bernhard Mittermaier, the DeFDOA concept is currently being discussed in various contexts, inter alia in the task force “Establishment of Scholar-Led Open Access Infrastructures” in the focus area “Digitality in Science” of the Alliance of Science Organisations in Germany. SeDOA is involved in these discussions and contributes its views there.

The national Service Centre for Diamond Open Access (SeDOA), which is funded by the German Research Foundation (DFG), began work in May 2025. Organised as a decentralised network, the project consortium, which is made up of 15 institutions, plans to increase the efficiency of diamond open access publishing in Germany by improving the coordination and visibility of existing, decentralised publication infrastructures; to centrally provide information; and to promote innovations.

The aim is to firmly establish diamond open access publishing within scholarly communication. The planned governance, services, and communications structure will involve all stakeholders in Germany.

In addition, as the German National Capacity Centre (NCC), SeDOA is strengthening international cooperation as part of the European network European Diamond Capacity Hub (EDCH).

In the funding phase lasting until April 2028, SeDOA will therefore focus on supporting, networking, and enhancing the visibility of existing diamond open access infrastructures in Germany. SeDOA does not have any funds to directly support journals, books, or publishing service providers. However, a certain contingent of titles can be published within the framework of the project at the SeDOA institutions Freie Universität Berlin, the University and State Library (ULB) Darmstadt, Technische Universität Berlin, and ZB Med – Information Centre for Life Sciences.

Although the funding of diamond open access publishing services is not part of SeDOA’s current project planning, we recognise the relevance of the topic and have established a Funding Task Force, which is engaging with the topic and discussing, inter alia, the concept for a DeFDOA. Its remit is to engage more intensively with issues and concepts surrounding the funding of diamond open access and to contribute new insights on this topic to the overall project, which can also serve as a basis for its statements and positions.

Developed by Bernard Mittermaier, head of the Central Library at Forschungszentrum Jülich, DeFDOA is a concept for the collective funding of diamond open access publications. Its clearly formulated aim is to make a substantial contribution to addressing the hitherto unresolved question of sustainably funding diamond open access (Mittermaier, 2025, p. 3). In the concept paper, Mittermaier states that the financial support provided by DeFDOA would be complementary to the work of SeDOA, which focuses on governance, standards, and quality (ibid., p. 4).

In a nutshell, the concept envisages that scientific institutions in Germany would contribute to a central fund administered by MPDL Services gGmbH (since renamed DEAL Open Access Services gGmbH). Diamond open access publishing services for journals and books could apply for financial support from this fund. However, this funding would not be intended to cover the full costs. Forum 13+, an independent working group made up of experts from German library consortia, would decide on the funding applications according to specified criteria, while SeDOA would support and advise the applicant organisations (Mittermaier, 2025, p. 4).

We expressly welcome the fact that consideration is being given to how diamond open access can be funded collectively and more sustainably. However, the concept is still in the development phase, and neither all details nor the participants have been finalised. We would therefore like to take this opportunity to participate in the necessary open discussion.

It must be made clear what definition of diamond open access underlies the concept and is used as a criterion for funding. The concept paper refers to CRAFT-OA’s operational criteria for diamond open access journals and to KOALA’s minimum standards for diamond open access journals, while at the same time allowing cooperation with commercial publishers. In particular the latter point is the subject of controversy within the community, and SeDOA itself is still discussing what position the project will take on it. SeDOA has formulated a minimal definition of diamond open access journals and books, which excludes commercial purposes. However, cooperation with a commercial publishing provider is nonetheless conceivable under certain conditions (especially in the case of academic ownership of the title rights) 

We are sceptical whether the fund will be adequately filled if contributions are voluntary. Moreover, the description of a rate of 2% of an institution’s other acquisition and publication expenditure (Mittermaier, 2025, p. 2) is vague and leaves room for interpretation.

The proposal to use the DEAL structures of all things as the basis for organising the funding of diamond open access seems somewhat paradoxical. Under the DEAL agreements, open access publications and reading access are financed via article processing charges (APCs), thereby contributing to making “gold open access” a synonym for APCs. Moreover, the DEAL agreements are agreements concluded with three major commercial publishers. Diamond open access stands for the very opposite: no publication charges and non-commercial purposes.

It is doubtful whether the stakeholders mentioned in the concept will be able to take on the tasks intended for them. As a project, SeDOA has the task of advising and networking all stakeholders in equal measure. The long-term task of advising funding applicants, as evisaged in the DeFDOA concept, would require additional funding and the implementation of the project on a permanent basis. SeDOA considers it feasible to contribute to the elaboration of the DeFDOA concept, for example the development of quality criteria or the like. litäts- oder ähnlichen Kriterien.

The concept does not make it clear who exactly would be eligible to apply for funding – institutions, libraries, or editors/journals? In principle, we would prefer if infrastructures rather than individual journals were supported, which would also facilitate the funding of the publication of diamond open access books. These infrastructures may be university presses, but other non-commercial publishing service providers could also be considered.

Basing funding levels on publication volume is problematic in several respects. Generally speaking, the more articles are published, the higher the workload involved. However, the actual relationship between the two is difficult to determine and depends also on the publishing formats and services. Although the original calculation of funding levels, which was based on publication volume, has been replaced with a more complex calculation aimed at avoiding financial incentives to publish higher numbers of articles, the new calculation in the form of a basic funding amount plus stepwise increases in combination with a cap is very complex and lacks transparency. At the same time, the envisaged maximum funding rate of €1,400 per article is relatively generous and could by all means be lower.

We see the concept as a great opportunity to reflect on the collective, Germany-wide funding of diamond open access, and we are happy to participate in further discussions on this topic. However, we also believe that it is important that a possible implementation of DeFDOA should not be considered the final word in discussions regarding the funding of diamond open access, and that complementary concepts should also be discussed and developed.

Mittermaier, B. (2025). Deutschland-Fonds Diamond Open Access: Konzept. https://doi.org/10.34734/FZJ-2025-04667

Schulz, Katharina (2026). The Concept for a Germany Fund for Diamond Open Access – Some Comments by SeDOA’s Funding Task Force. open-access.network. DOI: 10.64395/51n3n-c1785