Abstract
As policies, good practices and mandates on research data management evolve, more emphasis has been put on the licencing of data, which allows potential re-users to quickly identify what they can do with the data in question. In this paper I analyse a pre-existing collection of 840 Horizon 2020 public data management plans (DMPs) to determine which ones mention creative commons licences and among those who do, which licences are being used. 
 I find that 36% of DMPs mention creative commons and among those a number of different approaches towards licencing exist (overall policy per project, licencing decisions per dataset, licencing decisions per partner, licensing decision per data format, licensing decision per perceived stakeholder interest), often clad in rather vague language with CC licences being “recommended†or “suggestedâ€. Some DMPs also “kick the can further down the road†by mentioning that “a†CC licence will be used, but not which one. However, among those DMPs that do mention specific CC licences, a clear favourite emerges: the CC-BY licence, which accounts for half of the total mentioning of a specific licence. 
 The fact that 64% of DMPs did not mention creative commons at all is an indication for the need for further training and awareness raising on data management in general and licencing in particular in Horizon Europe. For those DMPs that do mention specific licences, 60% would be compliant with Horizon Europe requirements (CC-BY or CC0). However, it should be carefully monitored whether content similar to the 40% that is currently licenced with non- Horizon Europe compliant licences will in the future move to CC-BY or CC0 or whether such content will simply be kept fully closed by projects (by invoking the “as open as possible, as close as necessary†principle), which would be an unintended and potentially damaging consequence of the policy.
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