Pathways to Compliance: consultation outcomes and next steps

We’re excited to share a progress update following our open consultation on the draft Pathways to Compliance best practice guidelines. The consultation ran from early December 2025 to early February 2026 and we had a good selection of responses. Huge thanks to everyone who provided feedback! The responses offer a clear direction in many areas, with only two points needing extra discussion.

Consensus points

The consultation revealed overwhelming agreement (85%+) on several key points:

• All respondents agreed to adopt the eligibility criteria for ‘small publishers’ that we proposed in the draft recommendations.
• Everyone also agreed that Pathway publishers will only need to provide the COUNTER reports. That means the PR, DR, TR, and IR, as relevant, with all attributes by default. That means no standard views.
• Another unanimous point was that Pathway publishers should be exempt from formal audits. As we said in the consultation, we’ll be making updates to the Registry to make Audit and Pathway statuses clearly visible.
• Denial metrics weren’t quite unanimous, but a solid majority (86%) of respondents were comfortable with denial metrics being optional.

Areas for discussion

Two areas saw a significant split in responses: report formats, and search metrics. They’ll be the focus of the working group’s next steps.

Respondents were really divided on the JSON format, delivered through the COUNTER API (sushi). Many librarian and consortia respondents strongly advocated for JSON reports delivered through the COUNTER API. Further questions suggest that it’s the delivery mechanism that is the stumbling block. Manual harvesting and converting tabular to JSON is seen to be too time consuming. By contrast our small publisher respondents said that requiring JSON and the COUNTER API immediately would make the Pathway non-viable for them. The working group agrees that tabular reports are better than no reports, but we’ll need to flesh out requirements about how they should be shared with librarians.

Search metrics also split our respondents. 59% agreed that search metrics should be optional, and 41% stated that they’re absolutely necessary for database providers. At the moment, the working group is suggesting that we should make search metrics recommended but not mandatory in the Database Report for relevant Host Types, but allow other publishers on the Pathway to exclude search metrics if they need to.

Next steps

The working group is finding the best way forward on our areas for discussion, and will prepare a best practice guide for the Executive Committee to review. Stay tuned for more updates as we finalize the guidelines!