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Introduction to NIH Data Management and Sharing Policy and Plans

Beginning in FY 2027 (starting October 1, 2026), NIH will require all existing awards and applications subject to the NIH Data Management and Sharing (DMS) Policy to transition to the 2026 plan format. The policy announced in 2023 remains in effect, but the format of the plan has changed.

Competing application submissions must use the updated format; 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.

This table from NIH summarizes the transition and reporting requirements for adoption of the updated DMS Plan Format
(NOT-OD-26-100)

Stage of Award

Expected Transition to the Updated DMS Plan
Competing applications submitted on or after May 25, 2026 Submit a DMS plan in the updated format with the application, as described in NOT-OD-26-046.
Competing applications submitted prior to May 25, 2026 (not yet awarded) Provide a revised DMS Plan using the pdated format during the Just-in-Time (JIT) process.

  • If the competing application has already been awarded, the recipient will be required to transition to the updated DMS Plan format at the next Research Performance Progress Report (RPPR).
Active awards subject to 2023 DMS policy (see
list of NIH activity codes subject to the DMS Policy		 Provide a revised DMS Plan using the updated format at the next Research Performance Progress Report (RPPR).

  • If the FY2026 RPPR has already been submitted, the recipient will be required to transition to the updated format in the FY2027 RPPR.
All active awards expected to generate scientific data (see
list of NIH activity codes subject to the DMS Policy including those subject to the 2003 DMS Policy (i.e., applications submitted before January 2023).		 Provide a DMS Plan in the updated format with 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

The checklist below can guide you with creating a plan in the new format.

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

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, provide a brief justification (with specific legal, technical, and/or ethical reasons) 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. For instance, Iowa Research Online (IRO) 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, provide a brief justification (with specific legal, technical, and/or ethical reasons) 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, provide an explanation here.

☐  Describe the limitations and the ethical, legal, or technical factors for them. Your response should specify a particular reason(s) for limiting sharing.

☐   Describe any other anticipated limitations on sharing, e.g. if raw data will not be shared but you plan to transform or clean the data beyond minimum processing before sharing. For example: video interviews will not be shared because of ethical considerations: they can not be de-identified to protect participants; but anonymized transcripts will be shared.

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 and describe in Element 4.

☐   Consider whether data can be shared with access controls, such as in a restricted access repository, or by Data Use Agreement, rather than openly available.

6. Data types and repositories

Create a table with two columns [100 words maximum]

Expected Data Types Repository
List first data type here. Name the repository that will archive and share each data type. Use the guidance below to identify an appropriate repository or repositories.
List second data type here. Name the repository that will archive and share each data type here. Use the guidance below to identify an appropriate repository or repositories.
List the third data type… Name the repository…

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.
Include:

    • 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