Wellcome Trust — may decline new applications from non-compliant researchers; may suspend institutional funding

The Wellcome Trust's "Complying with our open access policy" specifies that articles not made open access in compliance with the policy result in Wellcome declining to accept new grant applications from the researcher as lead applicant, and in extreme cases, Wellcome may suspend funding to the organization.

For C-0003 and C-0025: Wellcome's enforcement posture extends consequences beyond the individual non-compliant grant to (a) the researcher's future applications and (b) the institution's relationship with Wellcome as a whole. The architecture of consequences is designed to make non-compliance a multi-period and multi-actor cost rather than a single-grant cost, which is the same enforcement architecture the NIH DMS Policy (E-0044) invokes when it states that non-compliance "may be taken into account by NIH for future funding decisions." Combined with E-0044, E-0045, E-0089, and E-0091, this evidence establishes that the major research funders are converging on cross-grant, institution-level enforcement rather than per-grant compliance review.