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Introduction to NIH Data Management and Sharing Policy and Plans

UPDATE: As of July 29, 2026, NIH announced that beginning in FY 2027 (starting October 1, 2026), it will require all existing awards and applications subject to the NIH DMS Policy to transition to the updated (2026) plan format. Competing applications submitted must use the updated format at submission; earlier submissions must provide a revised plan during Just in Time (JIT) or at the next RPPR, if already awarded.

All active awards, whether under the 2023 or 2003 DMS policies, must adopt the updated DMS Plan format in the FY2027 RPPR. Please refer to NIH’s Notice of Implementation Update: NIH Data Management and Sharing Plan Requirements for more information.

The Policy: The 2023 NIH Data Management and Sharing Policy promotes the appropriate sharing of scientific data, by planning for sharing, and using repositories to preserve and provide access to data.

Format for the plan: the NIH Data Management and Sharing Plan Format Page provides

We’ve provided a checklist below to assist you with creating a plan. Contact us if you would like a review of your plan before submitting it to NIH.

Checklist for creating a Data Management and Sharing Plan

This checklist may help you address the seven required elements in the NIH DMS format.

Refer to the NIH format as you go through this checklist, and check for other sharing policies outlined by the ICO, and in NOFOs.

1. Will there be maximum appropriate sharing?

  • Data sharing may be restricted for legal, technical, or ethical reasons

☐   If maximal sharing is not appropriate, compose a brief justification (with specific legal, technical, and/or ethical reasons) which should go in Element 4

2. Will data sharing begin according to the required schedule?

  • For articles published prior to grant close-out, data underlying the article must be shared at the time of the article’s publication.
  • For data related to findings reported in the final Research Performance Progress Report (RPPR), that data should be shared by the time of that final RPPR as part of closeout, if it has not already been shared at the time of an article’s publication.

☐   If data will not be shared on the required schedule, compose a brief justification (with specific legal, technical, and/or ethical reasons) which should go in Element 4

3. Will shared data stay available as long as the repository or journal maintains it?

☐   Consult the repository’s documentation to determine the repository’s anticipated preservation period. Iowa Research Online will preserve data for a minimum of 10 years after the grant performance period.

☐   If data will not remain available for the specified preservation period, compose a brief justification (with specific legal, technical, and/or ethical reasons) which should go in Element 4

4. Justifications for “no” answers and/or explanations for other limitations

Describe what restrictions or modifications to data sharing will be applied, in 300 words or less.

☐   If Elements 1, 2, 3, 7a, or 7b were answered no, add an explanation here

☐   For each reason limiting the extent or timeframe of sharing, determine whether the reason is:

    • Legal;
    • Technical; or
    • Ethical

☐   Describe any other anticipated limitations on sharing, e.g. if you plan to transform or clean the data beyond minimum processing before sharing.

5. Are you prepared for human subjects protections, if applicable?

☐   If you have human subjects data, consider how you will protect the privacy, rights, and confidentiality of study participants (de-identification, use of a restricted access repository, etc.).

☐   If human subjects data protections will limit or prevent sharing, mark this Yes and describe the restrictions in Element 4. If human subjects protections prevent all sharing, indicate “no” in Element 1.

☐   Consider whether data can be shared with access controls rather than openly available.

6. Data types and repositories

Create a table with two columns [100 words maximum]

Expected Data Types Repository or Established Repository Example
List first data type here. Name the repository that will archive and share each data type here.
List second data type here. If no repository has been identified then use the guidance below to identify an appropriate repository or repositories.

Column 1 (6.a). List the key types of scientific data to be generated during the project.

☐   A brief list of the anticipated types of data, including:

    • Organism/source of the data, e.g. mouse, human
    • Modality of data generation, e.g. fMRI; survey; biometrics

Column 2 (6.b) Identify one or more qualifying data repositories for each type of data (or group(s) of data that will be deposited into the same repository)

☐   Name the repository(ies) where data will be archived.

7. Genomic Data and Sharing (GDS)

If you are sequencing human DNA, including SNPs or methylation studies, consider whether you are subject to the genomic data sharing policy.

7a. Will there be sharing of the genomic data, using the accelerated GDS timing and recommended GDS repositories?

☐   Consult the genomic data sharing submission and release schedule for each level of data processing

7b. Will you be able to obtain institutional certification for the genomic data?

☐   Check with the IRB about the process for issuing Institutional Certification

Sample Plans

Only a few sample plans have been shared so far, and these are specific to the Institute and type(s) of data to be collected and shared.

Budgeting for Data Management & Sharing

Investigators can include costs for data sharing in the proposal budget.

NIH provides guidance, and Frequently Asked Questions about budgeting for data sharing.

Here’s a quick overview by FASEB about budgeting for data management in NIH proposals:

Video by FASEB (Federation of American Societies for Experimental Biology).

Get Help

We’ve assisted many UI researchers with their data management and sharing plans. Contact us with your questions or for a review of your plan.

Sources
The checklist was created by a Working Group on NIH DMSP Guidance