South Africa needs stronger safeguards against research misconduct. The proposed changes to research-output subsidies may, however, penalise legitimate scholarship, disadvantage postgraduate researchers and weaken the incentive to produce good research. These risks should be examined before any new restrictions take effect.

Two cases help to frame the issue.

A doctoral student carries out independent research, writes an article and publishes it with no supervisor as co-author. Should the article lose its subsidy eligibility because no university staff member appears on the author list?

Now take an academic who has spent three years working on several papers. Peer review is slow, and after long delays several of them appear in the same calendar year. Should that count trigger a financial penalty when the research behind it is sound?

Both cases arise from the Department of Higher Education and Training’s (DHET) Communiqué 3 of 2026, which proposes measures against the gaming of South Africa’s research-output subsidy system. I have written a detailed individual submission in response. My position is simple: research integrity must be protected, but rules aimed at misconduct should not also catch legitimate research.

The problem is real, but are the solutions justified?

DHET has good reason to tighten oversight of research-output claims. Predatory publishing, fraudulent affiliations, questionable authorship and the splitting of one body of work into many thin publications all erode public confidence in the subsidy system, and each calls for effective verification and appropriate consequences.

My concern is narrower. It is whether the proposed restrictions are targeted enough to separate these practices from ordinary research activity. The communiqué proposes, among other measures, individual publication ceilings, stricter eligibility rules for postgraduate publications, tougher treatment of journals and publishers, and sanctions for repeated violations. Each could have large consequences, yet the communiqué does not set out enough empirical evidence for readers to judge whether each measure would work or whether it is proportionate. That does not show that DHET lacks the evidence. It does mean the evidence should be open to independent scrutiny during the consultation.

When does a publication ceiling penalise legitimate research?

The proposal to cap the number of publications an individual academic can submit for subsidy troubles me most. Publication volume is not a direct measure of either quality or misconduct. Academics work under very different conditions: some carry heavy teaching and administrative loads, while others have protected research time, funded projects or large collaborative networks. Publication timing also depends on editorial processes that researchers do not control. An annual ceiling could therefore penalise the date on which a paper happens to appear and reveal nothing about how the research was done.

A second issue is what, exactly, would be counted. DHET already uses subsidy units when allocating research-output funding to universities. It is unclear whether a new individual ceiling would rest on publications or on author-attributed subsidy units, and how that attribution would work. The answer matters for collaborative research, for authors with more than one institutional affiliation and for disciplines with different authorship conventions. Before introducing a ceiling, DHET should state what would be counted, how the threshold would be set and how many otherwise eligible publications it would exclude.

Could ceilings weaken incentives for quality research?

Research-output funding should do more than encourage publication. It should support credible scholarship and strengthen the research capacity of public universities. A rigid annual ceiling may work against that aim. Once a researcher reaches the limit, further eligible publications could stop generating subsidy for the university, whatever their scholarly merit. Whether this would push universities towards stronger research, or make them less willing to back additional demanding work, cannot be assumed and needs empirical examination.

Differentiated funding weights, tapered ceilings or independently assessed exceptions might preserve incentives for valuable research, but these alternatives need the same scrutiny. Journal rankings such as Q1 and Q2 say something about the standing of a publication outlet, but not about the quality of an individual article. Credible African, regional, specialist and African-language journals should also not be disadvantaged because international citation databases cover them poorly. Any quality-sensitive approach would need disciplinary safeguards, transparent criteria and a careful look at how it interacts with publication ceilings.

Postgraduate researchers should not need unnecessary co-authors

The proposed rules for postgraduate publications deserve particular attention. Doctoral and master’s students can make independent scholarly contributions. Some formulate their own research questions, conduct the analysis and write publishable articles, with a supervisor contributing nothing that would justify co-authorship. A requirement that staff co-author a paper before it earns subsidy could create an incentive to add academics who do not meet authorship standards. That sits uneasily with DHET’s own concern about gift authorship.

Timing is a related problem. Research done during registration may not appear in a journal until months or years after the student has graduated. Eligibility rules should allow for this, and graduation should not be read as evidence that the institution no longer has a legitimate claim to the research. Institutional affiliation and research origin can be verified without making staff co-authorship compulsory.

Stronger verification offers another route

My submission proposes a framework that separates unusual publication patterns from verified eligibility problems and from substantiated research misconduct. Unusually high output could trigger proportionate verification. Specific concerns about authorship, originality or questionable outlets should be assessed substantively by suitably qualified reviewers. The framework also requires transparent decisions, a chance to respond, proportionate sanctions and independent appeal.

Financial ceilings should be assessed separately from misconduct controls. A limit on subsidy funding does not identify misconduct, and an academic whose output exceeds a threshold should not automatically be treated as having acted improperly. Before choosing an intervention, DHET should compare the costs, accuracy and distributional effects of the alternatives against the problems it has documented.

A chance for meaningful consultation

Communiqué 3 of 2026 gives South Africa an opportunity to rethink how it protects research integrity while supporting legitimate scholarly productivity. For the consultation to mean anything, the evidence behind the proposals must be accessible, in particular the findings of the Publication Quality Framework Project and the methods proposed for setting publication or subsidy-unit ceilings. Postgraduate researchers, early-career academics, established researchers, research offices and disciplinary communities should also be heard.

The choice is not between unchecked publication growth and automatic restrictions. The task is to design a system that can identify misconduct without treating legitimate productivity as suspect. That is the central argument of my submission.

The conversation should continue

I would welcome the views of academics and research managers on three questions:

  1. How should DHET tell unusually high but legitimate productivity apart from publication practices meant to game the subsidy system?
  2. Could annual ceilings affect incentives to produce high-quality research, particularly in collaborative disciplines?
  3. How can the subsidy system protect independent postgraduate scholarship while ensuring that institutional claims are legitimate?

These questions concern the future of research assessment and public research funding in South Africa, and they deserve discussion beyond formal institutional consultations.

Read the full submission

Consultation Submission on the Research Outputs Subsidy System: Response to DHET Communiqué 3 of 2026.

https://zenodo.org/records/23652172

The full document provides detailed policy analysis, discussion of the relevant research and funding literature, twelve principal recommendations, and proposed regulatory provisions.

This commentary presents my views as an individual academic and does not constitute an official position of Nelson Mandela University.

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