The European Commission's proposal for the tenth framework programme arrived on 1 July 2025, and most early coverage fixed on the headline sum: €220 billion over seven years, more than double Horizon Europe's €95.5 billion. A quieter shift sits inside the draft legislation, and it will matter more to working scientists than the budget arithmetic. Open access stops being a compliance chore attached to a project and becomes a contractual default written into the grant agreement. Research integrity stops being a stated value and becomes an obligation with audit consequences.
Then the Commission does something it rarely does in framework legislation: it spells out what happens to the copyright. The FP10 draft says beneficiaries must make peer-reviewed scientific publications available immediately on publication under an open licence. Horizon Europe already asked for that. The new part is that authors keep the rights needed to do it. The grant agreement would override any later publishing contract that tries to take those rights away.
The rule change that reaches every funded paper
For Horizon Europe, immediate open access was already the stated rule for journal articles. What remained fuzzy was enforcement. A researcher could comply by depositing a version somewhere, while a publisher contract still controlled reuse. FP10 changes the emphasis. The proposal makes rights retention a condition of funding: researchers keep the right to make the accepted version public, and the open licence travels with the work.
That detail is the one library consortia have been pushing for since Plan S launched in 2018. It stops a journal from accepting an article and then claiming that the author no longer has the right to share it. In the Commission's draft, the grant agreement stands above any later copyright assignment for the publication. The open licence is not negotiable after the fact.
There is a second pressure point: data. Horizon Europe asked researchers to make data as open as possible and as closed as necessary. FP10 proposes to turn that principle into firmer deposit obligations. Data underpinning a publication should be findable, accessible, interoperable, and reusable. The phrase has been policy for years; FP10 gives it contract-level weight and links it to reporting deadlines, not just final project reports.
What the research integrity clauses do differently
Previous framework programmes treated integrity as a matter for eligibility fine print. FP10 moves it into the operational core. Beneficiaries would have to maintain a research integrity plan, name a person or unit responsible for handling misconduct allegations, and ensure that staff receive training before they touch EU-funded work. The Commission is not proposing to police every lab bench. It is proposing to make institutional systems a precondition, the way financial controls already are.
The draft also strengthens the connection between a country's national integrity framework and access to EU research money. If a Member State lacks procedures for investigating serious breaches, the Commission would have grounds to suspend payments or exclude participants. That is a significant escalation. It means the integrity of the evaluation process, not just the science, becomes part of the funding contract. The full detail sits on the Commission's FP10 proposal page.
For universities, this should sound familiar. The same logic drives the growing use of ORCID identifiers and stronger authorship rules across journals and funders. ORCID mandates have reached peer reviewers and editors, not just submitting authors. FP10 extends that administrative logic deeper into the funding model.
Here's the catch
The problem is not the mandate; it's the invoice. Immediate open access in a research economy still dominated by subscription journals and article processing charges creates a predictable effect: costs move from library budgets to author budgets. The FP10 proposal is firmer on when work must be open than on what counts as a reasonable price for making it open. Without a cap on APCs or a parallel investment in non-profit publishing infrastructure, the same funders that demand openness will pay more to the same publishers for the same papers.
This isn't a hypothetical tension. Plan S has spent years arguing that immediate open access changes little if the publication fee is simply moved to another column. Europe's diamond open access journals, which charge neither readers nor authors, have spent the last two years warning that their model can't absorb the demand. The funding crisis is already visible. If FP10 pushes all EU-funded articles into immediate open access without routing support toward institutional repositories and library publishing, the practical result could be more money flowing to hybrid titles while small open presses close.
There's a second catch. The national integrity requirements sound strong in the legal text, but enforcement depends on Commission desks that are already stretched. A mandate without audit capacity tends to become a box to tick. Universities will write integrity plans because the template exists, not because the culture has changed. The gap between plan and practice is where research misconduct lives.
Hype versus reality
The Commission's communication language is bold: open science becomes the default, integrity becomes a condition. The draft text is more cautious when it comes to money and monitoring. The €220 billion figure gets recycled as evidence of ambition, but much of that total is repackaged existing spending. For open access, there is no new dedicated fund at the scale needed to replace subscription revenue. For research integrity, there is no new inspectorate. What exists is a set of rules and the expectation that national contact points will enforce them.
Reality grade: the rights retention clause is stronger than anything the EU has previously attempted. Horizon Europe told authors to deposit; FP10 tells them they keep the right to decide where. That's a real shift. But the surrounding economics are unchanged, and that is the part that will determine whether the rule produces open knowledge or just relocates the invoice.
What negotiators will fight over
The draft is a proposal, not a law. The European Parliament and the Council of the EU must agree on a final text, and the open access clauses will not survive untouched. Member states that host major subscription publishers will push for exceptions. Universities will lobby for more support for data management. Research organisations will ask for a clearer definition of FAIR data and the right to close data for security or commercial reasons. The final adoption usually comes within a year of the proposal, but EU budget negotiations are rarely quick.
For researchers, the change will land unevenly. A molecular biologist with a data management plan already in place may notice little difference. A humanities scholar bound to a monograph press with restrictive copyright will face a sharper collision. Postdocs and early-career researchers are the ones asked to manage deposits, choose repositories, and clean datasets while their contracts run out on short cycles.
UNESCO's 2021 Open Science Recommendation gave the political frame; FP10 is the legislative instrument that will test it. The Commission can set the rule, but the final push happens at the bench, in the repository, during the grant amendment. What researchers want to know is simpler: when the tenure file opens, will the open version count for as much as the paywalled one? The proposal doesn't yet answer that. And that, more than any embargo policy, is where the promise will be tested.
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