NIH Data Management and Sharing

Update to NIH Data Management and Sharing Policy

On February 25th, 2026, NIH released NOT-OD-26-046: Updated Elements of an NIH Data Management and Sharing Plan. Effective May 25, 2026, applicants are required to use the updated NIH Data Management and Sharing (DMS) Plan format. The revised format standardizes DMS Plans across NIH Institutes, Centers, and Offices (ICOs), reduces redundancy, and streamlines review and reporting requirements.

On July 29, 2026, NIH issued NOT-OD-26-100: Implementation Update: NIH Data Management and Sharing Plan Requirements, which provides additional guidance regarding implementation of the updated format and transition requirements for existing awards and applications.

FY2027 Transition to the Updated DMS Plan Format

Beginning in Fiscal Year (FY) 2027, NIH requires all applications and awards subject to the NIH Data Management and Sharing Policy to align with the updated DMS Plan format, regardless of when the original application was submitted.

Required Transition Timeline

Competing Applications Submitted on or After May 25, 2026

Applicants must submit a DMS Plan using the updated NIH format as part of the application package.

Competing Applications Submitted Before May 25, 2026 (Not Yet Awarded)

Applicants will be required to provide a revised DMS Plan using the updated format during the Just-in-Time (JIT) process.

Awards Already Issued Under the 2023 DMS Policy

Recipients with active awards will transition to the updated format through the next applicable Research Performance Progress Report (RPPR).

Active Awards Subject to the 2023 NIH DMS Policy

Recipients must submit a revised DMS Plan using the updated format with the next RPPR.
If the FY2026 RPPR has already been submitted, transition to the updated format will occur in the FY2027 RPPR.

Active Awards Subject to the 2003 NIH Data Sharing Policy

All active awards expected to generate scientific data, including awards originally subject to the 2003 NIH Data Sharing Policy (applications submitted before January 2023), must submit a DMS Plan using the updated format with the FY2027 RPPR.

Changes to Approved DMS Plans and Reporting Requirements

Effective October 1, 2026NIH recipients are no longer required to obtain prior NIH approval to modify an approved DMS Plan.

Examples of changes that may be reported through annual progress reporting include:

• Changes in scientific direction.
• Changes to selected repositories.
• Revisions to data sharing timelines.
• Modifications to access controls or data protections.
• Other updates affecting implementation of an approved DMS Plan.

NIH plans to retire the DMS Prior Approval Request process previously available through the eRA Commons Prior Approval Module.

RPPR Reporting Requirements

Beginning October 1, 2026, recipients must use the Research Performance Progress Report (RPPR), Section C.5.c., to:

• Report progress on data management and sharing activities.
• Notify NIH of modifications to approved DMS Plans.
• Describe challenges affecting implementation.
• Report any delays in meeting data sharing commitments.
• Document data sharing activities conducted during the reporting period.

Investigators should ensure that RPPR submissions accurately reflect current data management and sharing practices.

DMS Plan Format

The new DMSP format can be viewed on the Data Management and Sharing Plan Format page.

Budgeting

Budget expectations have not changed under NOT OD 26 046 or NOT-OD-26-100.

Any costs necessary to carry out the DMSP can be included as a line item in the budget. Additionally, the budget justification must include a short synopsis of the DMSP. The budget justification will justify any costs associated with long term storage of the data for which you are requesting the sponsor to pay. While completing this portion of the DMSP, please reference the NIH provided lists of allowable and unallowable costs.

Note that all allowable costs submitted in budget requests must be incurred during the performance period (before the end of the grant), even for scientific data and metadata preserved and shared beyond the award period. For instance, if a DMS plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid before the end of the period of performance.

For further assistance, please reference the NIHM Data Archive (NDA) cost estimation tool.

DMS costs must be listed as a direct cost in section F. Other Direct Costs of the R&R Budget form, specifically identified as “Data Management and Sharing Costs,” and should be included in the budget justification. For modular budgets, the costs for data management need to be justified as an additional narrative justification.

Please be aware peer reviewers may comment on the appropriateness of the budget justification as part of the unscored budget section.

If you do not need funds because you have the active storage space, data curation expertise and/or are depositing the data and/or metadata into a free federal repository recommended by NIH, your justification will address the areas below and state, “no funds are needed to support DMS.”

Data Sharing

Where to share your data:
Consent is absolutely required if you are conducting research with human subjects, even if data will be de-identified. Please reference the NIH's guidance on privacy protections and AI/AN populations. Please do not share your data if doing so would violate privacy protection or applicable laws. To improve the FAIRness (Findable, Accessible, Interoperable, and Re-usable) of the data, the NIH recommends sharing datasets through established data repositories. See Supplemental Information to the NIH Policy for Data Management and Sharing: Selecting a Repository for Data Resulting from NIH-Supported Research for more detailed information.

When to share your data:
Your data should be accessible as quickly as you are able. Additionally, you can use relevant requirements and expectations (i.e. data repository policies, award record retention requirements, or journal policies) to determine when to make your data sets available. The NIH requires that you share your data when you publish your work or before your performance period ends, whichever comes first, regardless of journal or repository policies.

Leveraging Lab Archives for Data Sharing

OSU CHS provides LabArchives Electronic Lab Notebooks (ELN) to all personnel and students. Scientific data can be organized in a designated notebook, to separate it from the ELN and shared using one of the data publishing workflows available within the ELN.  Metadata can be added as an entry on the page containing the scientific data to be shared.  This may include methodology and procedures, protocols, data labels, definitions, or any other information that will aid in reproducing and understanding the data.  Further, when publishing data via the ELN with the creation of a DOI, additional metadata can be added to include authors, grant or funding IDs, and ORCID.  A DOI is created and assigned to the shared data as a permanent digital identifier that can be referenced elsewhere and provides a link back to the data.  Once published with the DOI, the scientific data is publicly available to anyone with access to the DOI. More information about LabArchives can be found here.

Frequently Asked Questions

Start by viewing this informative list of FAQ's from NIH.

Compliance & Institutional Oversight

NIH expects researchers and institutions to implement data management and sharing practices as described in their approved DMS Plan. Once a grant has been awarded, the approved Data Management and Sharing Plan becomes part of the award's terms and conditions.

Failure to comply with an approved DMS Plan may result in:

• Additional terms and conditions placed on the award.
• Delayed funding actions.
• Suspension or termination of the award.
• Consideration during future NIH funding decisions.

Beginning October 1, 2026, NIH will primarily monitor implementation of approved DMS Plans through annual RPPR reporting. Recipients must use the RPPR to report progress on data sharing activities and identify modifications made to approved DMS Plans.

When in doubt, investigators should consult their NIH Program Official regarding institute-specific expectations or unique project circumstances.

Responsibility for implementing and overseeing DMS Plans is shared among investigators, institutional offices, and oversight committees:

• Principal Investigators are responsible for ensuring implementation of approved DMS Plans and compliance throughout the award period.
• Institutional Review Boards (IRBs) are responsible for ensuring consistency between informed consent documents, participant protections, and proposed data sharing activities.
• Principal Investigators are responsible for ensuring appropriate data use agreements, privacy protections, and security controls are established before sharing sensitive data.