NIH format for Data Management and Sharing Plans (2026).

Format  | Checklist |  Sample Plans  |  Budgeting for Data  |  NIH Policy  |  Assistance

The New 2026 format

The NIH Policy released in 2023 is still in effect, but the Plan will now use a different format.

See the NIH Data Management and Sharing Plan Format Page for:

Data Management and Sharing Plan Checklist1

This Data Management and Sharing (DMS) Plan Checklist addresses the required elements, numbered 1-7b 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.

☐   Be certain to have specific justifications grounded in regulations, ethical concerns, legal issues, or technological limitations before marking “No” to any yes/no elements.

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 that will be created or used as part of the study, 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?

☐   Consult your institution’s human research protection office, the chair of the IRB, or the institution’s research integrity officer (RIO) about your institution’s process for issuing Institutional Certification

Sample Plans

Only a few sample plans have been shared so far, but more may become available.

These plans may be 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).

NIH Policy

The policy released in 2023:

  • Applies to all awards that generate scientific data, regardless of the funding amount or mechanism.
  • Requires a data management and sharing plan for all proposals.
  • Requires that data must be shared at the time of associated publications, or by the end of the grant performance period, whichever comes first.
  • Strongly encourages researchers to use repositories for sharing data.
  • Institutes, Centers, and Offices may have more specific requirements than the broader NIH policy, so review the Funding Opportunity Announcement (FOA) that you are applying to.

Assistance

We’ve assisted many UI researchers with their data management and sharing plans. Feel free to contact us for assistance or a review of your plan.

Sources

Working Group on NIH DMSP Guidance