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.

UC Resources to help you navigate the new NIH Policy

The New NIH Policy for Data Management and Sharing and What it Means for You at the University of Cincinnati 

Tiffany Grant and Amy Koshoffer 

Co-leaders UC Libraries Research & Data Services 

NIH Policy UC_Resources document

Introduction 

“Data without context are inert, but data within contexts become information, knowledge (1).” 

Researchers submitting for funding through the National Institutes of Health (NIH) on or after January 25, 2023, should be aware of the requirement to submit a Data Management and Sharing Plan (DMSP) for any NIH-funded or conducted research that will generate scientific data. Previously, the NIH only required grants with funding of $500,000/year or greater in direct costs to provide a short explanation of how and when data resulting from the grant would be publicly shared. However, this new mandate requires all grant applications or renewals to include a detailed plan for data management and sharing for the funded period. This requirement is mandated through the Final NIH Policy for Data Management and Sharing that emphasizes the importance of good data management practices and establishes the expectation for maximizing the appropriate sharing of scientific data generated from NIH-funded or conducted research. The NIH defines scientific data as the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings, regardless of whether the data are used to support scholarly publications. The NIH has long championed the proper management and sharing of scientific data to accelerate biomedical discovery through the promotion of data reuse for future research studies.  

The NIH encourages data management and sharing that is consistent with the FAIR (Findable, Accessible, Interoperable, and Reusable) Data Principles. The FAIR Data Principles are a concise set of principles designed by representatives from academia, industry, funding agencies, and publishers, that serve to support and enhance reuse of data (2). In the first formal paper documenting the FAIR Principles, the authors suggest that good data management is critical not only for knowledge, discovery, and innovation, but also for the integration and reuse of data post-publication. The FAIR principles refer very specifically to data that is “open”. Open data is simply defined as “data that anyone can access, use, and share (3)”. The NIH has a long-standing commitment to open data to increase the utility of data produced by federal funding and has done so through mandating data management and sharing initiatives. Proper management and sharing of research data have numerous benefits to researchers. Authors found that articles that include statements that link to data in a repository were associated with an up to 25% higher citation impact (4). In another study, the authors showed a 69% increase in citations when data was made publicly available, and this increase was independent of impact factor, publication date, or the author’s country of origin (5). Citations are a type of currency in the scholarly community, as they can be directly tied to research funding, promotion, and notoriety in the respective field by facilitating increased visibility of the author’s works. Moreover, allowing for greater access to data can foster collaboration opportunities, increase transparency in research, and maximize the reuse of data all while meeting funder and publisher requirements.  

 This document will serve as a single resource for researchers at the University of Cincinnati to learn about the new NIH Data Management and Sharing Policy that went into effect on January 25, 2023. Researchers can use this document and the embedded links to find information on what is required of them as they prepare to submit NIH grant proposals and what resources UC has available to them to facilitate the process. Throughout this document, researchers will find links to information and tools that will aid them as they prepare Data Management and Sharing Plans as well as information about available data repositories for data sharing.  

Continue reading