I don't see that the playing field is levelled - if that were truly the case, and author wishing to publish with JMIR Publications would have to pay the exact same amount (or nothing) than an author wanting to publish with Wiley, Springer or Elsevier. This is not the case. Can the author give more details on the procurement process for publishing services?

There is an underlying assumption in this statement that assumes that "established" journals are the journals published by legacy publishers and researchers do not want to publish with pure open access journals. As an example, JMIR Publications journals are fully open access for over a quarter of a century and are very established. Authors want to publish here. But Project DEAL made a deal with the 3 biggest publishers and assumes that that this is where they want to publish

I agree with this - reading and publishing fees need to be disentangled. But what Bibsam is also doing is to preferentially make publishing agreements with pure open access publishers, rather than focussing on so-called "transformative" publishers.

That's exactly what it is: TAs are a mechanism designed to entrench the position of legacy subscription publishers.

This is a very shortsighted view. Please name a single publisher who has actually fully transformed as a result of transformative agreements. Economists clearly see that "research institutions seem to be 'trapped' in transformative agreements. Instead of being a bridge towards a fully Open Access world, academia is stuck in the hybrid system. This endows the legacy (non-Open Access) publishing houses with substantial market power. It raises entry barriers, lowers competition, and increases costs for libraries and universities." (https://arxiv.org/abs/2409.20224)

The statement suggests that TAs “shifted the scholarly publishing landscape.” In practice, most TAs repackage existing subscription spending rather than fundamentally restructuring publishing economics by opening up the publishing market. Repacking existing subscription spending overlooks that existing open access publishers are not even on the radar screen of librarians. TAs merge payment streams administratively, but do not necessarily transform the underlying market structure or cost model. Libraries may administer the agreements, but market control largely remains with dominant publishers. By linking OA payments to historical subscriptions, TAs structurally favor publishers that already have large subscription portfolios, strong negotiating positions with consortia and established “big deal” relationships.

Publishers that were already fully open access, and therefore had no subscription base to convert, are excluded from these agreements. As a result, TAs often reward publishers that transitioned slowly (or not at all) while disadvantaging early adopters of OA.

The gap in revenue between OA and subscriptions is the reason why legacy publishers want to maintain their subscriptions and why TAs will cement a hybrid model where OA journals are created as garbage cans for rejected papers from subscription titles. A true reform to 100% open access can only happen through copyright reforms or funder/institutional mandates which outlaw locking away research results behind paywalls.

If you want a true reform, you need to cancel subscription journals and redirect funds to open access without subsidies for those who resisted OA for the longest time. TAs are sustaining legacy publishers that "promise" to transition to open access while neglecting to support authors who wish to publish with publishers that have already made that transition. This is not supporting open access; it is cementing existing oligopolies and locking libraries into hybrid or “conditional” models (like S2O). More importantly, it undermines the viability of fully open access publishers that made the transition decades ago or were born open access. TAs are a trap (https://arxiv.org/abs/2409.20224).

The author seems to think that authors only published in full open access journals because of mandates? To be clear: Full open access journals are not part of transformative agreements, because there is nothing to transform. Hence, from a perspective of an author whose favorite journal or publisher is fully open access, transformative agreements are doing exactly that: Forcing a behavior change to publish with legacy publishers where APCs are covered as part of the TA. JMIR Publications journals are ranked #1 in their field and researchers have to find alternative funding to publish here.