Will EU beat UK in open access?

Today's Scientist carries a news article on the issue of open access to research in Europe. In early April the EU published a report (112 page pdf) urging funders to guarantee open access to research, but there's still no RCUK policy in sight. RCUK announced their draft policy on open access last June, but was met with stiff opposition from publishers and learned societies, and has since been in protacted negotiations with publishers, scientists and government with aim of refining its position.