What cannot be measured cannot be managed - a new EC report makes the case for Open Science monitoring in the ERA Act

A new expert study commissioned by the European Commission's Directorate-General for Research and Innovation, Open Access Policies in EU Member States and Beyond, has just confirmed what many of us working on Open Science monitoring have long argued: progress on Open Access across the European Research Area (ERA) is real, but uneven, fragmented, and hard to track. Authored by Daniel Spichtinger and based on an analysis of all 27 EU Member States plus eight non-EU countries, the report is one of the most comprehensive comparative pictures of Open Access policy we've seen.

Written by Tereza Szybisty

A familiar diagnosis

The report's central finding will sound familiar to anyone following EOSC Track's work: Member States differ substantially in policy instruments, legal bindingness, embargo periods, copyright mechanisms, repository requirements, and critically monitoring arrangements. This fragmentation isn't just an administrative hassle - it actively complicates cross-border research collaboration and makes it nearly impossible to see, at the EU level, whether Open Access policy is actually working.

The report identifies what does work: multi-instrument frameworks (national legislation, funder mandates, and institutional support reinforcing each other) consistently outperform voluntary approaches, and linking Open Access to research assessment drives measurable behavioural change. But it's equally clear about what doesn't: policies without institutional follow-through tend not to move the needle.

Underlying all of this is a line worth sitting with: what cannot be measured cannot be managed. Spichtinger treats an EU-level monitoring and reporting framework not as a nice-to-have, but as a prerequisite for evidence-based governance of the "fifth freedom" - the free circulation of knowledge that the ERA is meant to guarantee.

Where the EOSC Open Science Observatory fits in

This is where the report gets specific in a way that matters directly to us. It describes the EOSC Open Science Observatory as "the most technically advanced EU-level monitoring infrastructure currently operational". The report recognises its three-layer approach: quantitative indicators drawn from the OpenAIRE Graph and Eurostat, structured country narratives co-developed with National Open Access Desks (OpenAIRE national experts), and a developing AI-enabled policy resource registry.

Two of the report's formal recommendations build directly on this. Recommendation EU-6 calls on the Commission to continue investing in the EOSC federation, explicitly including the Open Science Observatory, with clearer bridges to national and institutional repositories and targeted support for Member States with limited infrastructure capacity. Recommendation EU-11, the report's preferred path for implementation, goes further: it proposes using the ERA Act as the binding legislative vehicle to transform the current National Points of Reference (NPR) mechanism (until now a voluntary, self-reporting exercise) into a genuine framework for mutual learning, aligned with the EOSC Open Science Observatory.

"... the EOSC Open Science Observatory is the most technically advanced EU-level monitoring infrastructure currently operational. The Observatory provides a policy intelligence platform that integrates three distinct data layers: quantitative indicators drawn primarily from the OpenAIRE Graph and Eurostat; structured country narratives co-developed with national stakeholders through a consultative process; and a developing AI-enabled policy resource registry that classifies and summarises national OA policies using natural language processing."

Daniel Spichtinger

A grain of salt

The report is also candid about the Observatory's current limitations, and we think it's worth being equally candid back. The report notes that the Observatory, like most national monitors, relies partly on self-reported data and could be clearer about which indicators draw on which sources. Further, the Observatory's quantitative layer draws primarily on the OpenAIRE Graph. The Graph is not a static database but part of Europe's open science infrastructure. It methodically harvests from a wide range of sources, including DBLP for computer science, Europe PMC for life sciences, arXiv and Diamond OA hubs, and it feeds into the EOSC Open Science Observatory. Still, monitoring is only as good as the data coming in. Publications that exist only in proprietary CRIS systems, or on publisher platforms without open DOI-based metadata, are harder to capture. Evidence suggests a mixed but encouraging picture. A recent SciMago comparison of open and commercial bibliographic infrastructures found that, among the open platforms, OpenAIRE has the highest coverage of persistent identifiers (73.2% for DOIs, 59.7% for ISSNs) and the lowest share of records missing affiliations (40.55%). It also flagged issues we need to address, such as duplicated DOIs and unclassified document types

How widely the OpenAIRE Graph is relied on across the monitoring landscape adds another angle. When the Open Science Monitoring Initiative (OSMI) Working Group 2 mapped 90 Open Science monitoring initiatives, the OpenAIRE Graph was one of the most frequently cited data sources, mentioned by 22 of them, while OpenAIRE Monitor instances accounted for another 13 entries. That says nothing about data quality on its own, but it shows how many monitoring efforts are already built on this infrastructure.

The report also asks us to be clearer about which indicator draws on which source, and we agree. Improving the transparency of our methodology and looking at how to bring more institutional and national data sources into the picture, so coverage extends further, is an active work in progress. We're also putting real effort into hearing directly from the people who use the Observatory: over the summer, we launched a feedback survey to understand what's working, what's missing, and what would make the platform more useful for researchers, institutions and policymakers alike. That feedback is already shaping what we prioritise next.

Help us improve the EOSC Open Science Observatory – fill out feedback form

Full circle: back to the ERA Act

None of this is new territory for us. When the European Commission opened its Call for Evidence on the ERA Act, EOSC Track submitted feedback arguing precisely this. We argue that Open Science should not be a side pillar of the ERA but embedded at its core, and that a dedicated set of co-created Open Science indicators belongs in the ERA's governance framework. We backed that position with early lessons from our own monitoring work in a policy brief published alongside our submission.

This new, independent study reaches much the same conclusion and its central recommendation, EU-1, spells out what that framework should look like: a systematic, periodic ERA-level monitoring and reporting mechanism, built on a common indicator framework with standardised definitions and collection methods, with all monitoring data public, machine-readable, and openly licensed.

That's the direction we've been pushing toward, and it's encouraging to see it laid out so explicitly in an EC-commissioned study. If you want to see what EU-level Open Science monitoring can look like in practice today, the Observatory is open to explore.

Explore the EOSC Open Science Observatory

References:

European Commission: Directorate-General for Research and Innovation and Spichtinger, D., Open access policies in EU Member States and beyond – Final report, Publications Office of the European Union, 2026, https://data.europa.eu/doi/10.2777/8921907

Szybisty, T. (2025). Monitoring Open Science across ERA: Early Lessons from the EOSC Open Science Observatory [EOSC Track Policy Brief]. Zenodo. https://doi.org/10.5281/zenodo.16991651