Significant Changes to the NIH Data Management and Sharing Plan requirements starting in May

Starting May 25, 2026 the NIH will require researchers to submit a data management and sharing plan based on updated elements. See for more details – NOT-OD-26-046

The background for the changes as listed in the guide is “to clarify common areas of confusion in the research community while streamlining and simplifying DMS Plans. Since the DMS Policy went into effect in 2023, NIH Institutes, Centers, and Offices have evaluated over 1,100 DMS Plans and found that while the majority were acceptable either initially or after minor revisions, many included extraneous details and exceeded the recommended DMS Plan length. NIH is revising DMS Plan elements and requiring the use of the corresponding format page to aid compliance monitoring.”

If you have questions about the new format or general data management questions, email askdata@uc.edu.

Here is a comparison of the current and the updated version questions.

2020 versionAfter May 25, 2026 version
Data Type: briefly describe the scientific data to be managed, preserved, and shared[100 words max] Asks for the key types of scientific data anticipated to be generated during the project to be included in a table, along with information on the repository (or an example repository) where the scientific data may be managed and shared.  
Related Tools, Software and/or Code: specify if needed 
Standards: indicate what standards will be applied to the scientific data and associated metadata  
Data Preservation, Access, and Associated Timelines:  describe what repository will be used, persistent identifiers to use, and when the data will be available.Element 1. Answer Yes or No: Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)?  
Access, Distribution, or Reuse Considerations: describe any applicable factors affecting subsequent access, distribution, or reuse of scientific dataElement 2. Answer Yes or No: Will the scientific data underlying peer-reviewed publications be shared by the time of publication or, for other findings, by the end of the period of performance, which includes no-cost extensions?   Element 3. Answer Yes or No: Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies?
New Element for 2026 – Element 4: [300 words maximum] If you answered “NO” to elements 1, 2, or 3, or if you anticipate that sharing will be limited in some other way, please describe these limitations and the ethical, legal, or technical factors for them (see for example FAQ B.5 and other relevant FAQs). Your response should specify a particular reason(s) for limiting sharing.
Oversight of Data Management and Sharing: indicate how compliance with the Plan will be monitored and managed, frequency of oversight, and by whom (e.g., titles, roles).Answer Yes or No: If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213, including whether any scientific data will be shared using access controls? 
New Element for 2026 – For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data): Answer Yes, No, or Not Applicable: Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy?. If “no,” address in element 4. If “no,” address in element 4. Answer Yes, No, or Not Applicable: Do you anticipate that when sharing large-scale human genomic data that you will be able to meet the expectations of the Institutional Certification in the GDS Policy (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-124.html; IV.C.5)? If “no,” address in element 4.