Published October 26, 2026 | Version v1
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Consultation submission on the research outputs subsidy system: Response to DHET Communiqué 3 of 2026

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Description

This document is my individual submission in response to the Department of Higher Education and Training’s (DHET) Communiqué 3 of 2026, which proposes measures against gaming and research-integrity problems in South Africa’s research outputs subsidy system.

The submission critically examines the proposed publication ceilings, journal accreditation requirements, eligibility rules for postgraduate publications, authorship and institutional affiliation rules, publisher verification, sanctions for research misconduct and institutional publication incentives. It pays particular attention to the evidence offered for each intervention, the consequences each could have for legitimate research productivity, and what follows for research quality, academic freedom and procedural fairness.

Its central argument is that strengthening research integrity depends on separating unusual publication patterns from verified subsidy ineligibility and from substantiated misconduct. The submission asks whether publication ceilings could create unintended incentives that affect scholarly quality, interdisciplinary collaboration and postgraduate participation in research. It also assesses alternatives: risk-based verification, quality-sensitive funding arrangements, independent disciplinary assessment and proportionate enforcement.

The document sets out twelve principal recommendations and proposed regulatory provisions to inform policy deliberation. The central recommendation is that DHET disclose the empirical evidence behind the proposed measures, compare their likely consequences with those of feasible alternatives, and adopt transparent, proportionate and evidence-based implementation procedures.

I have published the document to support scholarly discussion, public transparency and informed engagement with the consultation, which is still under way. It reflects my independent academic views and is not an official institutional position.

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Consultation submission on the research outputs subsidy system.pdf

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Dates

Other
2026-10-26

References

  • [1] Department of Higher Education and Training (DHET). (2015). Research Outputs Policy 2015. Government Notice 188, Government Gazette 38552, 11 March; implementation from 1 January 2016. Specific policy clauses 2.2–2.8, 3.1–3.4, 4.2–4.5, 5.6, 6.2, 6.8–6.13 and 9.1–9.3.
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