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The Open Access (OA) publishing model that is based on article processing charges (APC) is often associated with the potential for more transparency regarding the expenditures for publications. However, the extent to which transparency can be achieved depends not least on the completeness of data in APC monitoring systems. This article investigates two blind spots of the largest collection of APC payment information, OpenAPC. It aims to identify likely APC-liable publications for German universities that contribute to this system and for those that do not provide data to it. The calculation combines data from Web of Science, the ISSN-Gold-OA-list and OpenAPC. The results show that for the group of universities contributing to the monitoring system, more than half of the APC payments are not covered by it and the average payments for non-covered APCs is higher than for APCs covered by the system. In addition, the group of universities that do not contribute to OpenAPC accounts for two thirds of the number of APC-liable publications recorded for contributing universities. Regarding the size of these blind spots, the value of the monitoring system is limited at present.