NIH Data Management and Sharing

Update to NIH Data Management and Sharing Policy - February 2026, effective May 2026

On February 25th, 2026, NIH released NOT-OD-26-046: Updated Elements of an NIH Data Management and Sharing Plan(DMSP). Effective May 25, 2026 applicants will be required to use the new DMSP form, with NIH intending to pilot it for a year and make changes as need arises.

The new form aims to simplify the process and reduce redundancy in DMSPs. Additionally, the intent is all ICs to use the same form and no longer have unique individual requirements. NIH has indicated that the DMSP FAQ and other resources will be updated in time for implementation.

All NIH-funded research generating scientific data must now include:

• A short, standardized DMSP following the updated NIH format.
• Answers to three required yes/no questions that describe:
  1. Whether scientific data will be shared to the maximum appropriate extent.
     
  2. Whether data will be shared by publication or by the end of the period of performance.
  3. Whether data will remain available for at least as long as required by repository or journal policies.
• A brief explanation (up to 300 words) if sharing is limited for ethical, legal, or technical reasons.
• A short table (≤100 words) listing expected data types and the repository (or example repository) where data may be shared.
• A required yes/no question on protections for human participant data, including access controls and protections consistent with NOT-OD-22-213
• Additional yes/no items for projects subject to the NIH Genomic Data Sharing (GDS) Policy.

DMSP Templates and Samples

The new DMSP format is currently under OMB review and can be viewed on the Data Management and Sharing Plan Format page.

DMP Tool is an open-source, online application that helps researchers create data management plans (DMPs). It provides a click-through wizard for creating a plan that complies with funder requirements. It also has direct links to funder websites, help text for answering questions, and data management best practices resources. DMPTool will be incorporating the new format into its template options once finalized. Using the DMPTool to create and manage all your plans will help you stay organized. Use your OKEY credentials to login.

Budgeting

Budget expectations have not changed under NOT OD 26 046.

Any costs necessary to carry out the DMSP can be included as a line item in the budget. Additionally, the budget justification must include a short synopsis of the DMSP. The budget justification will justify any costs associated with long term storage of the data for which you are requesting the sponsor to pay. While completing this portion of the DMSP, please reference the NIH provided lists of allowable and unallowable costs.

Note that all allowable costs submitted in budget requests must be incurred during the performance period (before the end of the grant), even for scientific data and metadata preserved and shared beyond the award period. For instance, if a DMS plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid before the end of the period of performance.

For further assistance, please reference the NIHM Data Archive (NDA) cost estimation tool.

DMS costs must be listed as a direct cost in section F. Other Direct Costs of the R&R Budget form, specifically identified as “Data Management and Sharing Costs,” and should be included in the budget justification. For modular budgets, the costs for data management need to be justified as an additional narrative justification.

Please be aware peer reviewers may comment on the appropriateness of the budget justification as part of the unscored budget section. Your entire DMSP is only reviewed by the Program Officer.

If you do not need funds because you have the active storage space, data curation expertise and/or are depositing the data and/or metadata into a free federal repository recommended by NIH, your justification will address the areas below and state, “no funds are needed to support DMS.”

Data Sharing

Where to share your data:
Consent is absolutely required if you are conducting research with human subjects, even if data will be de-identified. Please reference the NIH's guidance on privacy protections and AI/AN populations. Please do not share your data if doing so would violate privacy protection or applicable laws. To improve the FAIRness (Findable, Accessible, Interoperable, and Re-usable) of the data, the NIH recommends sharing datasets through established data repositories. See Supplemental Information to the NIH Policy for Data Management and Sharing: Selecting a Repository for Data Resulting from NIH-Supported Research for more detailed information.

When to share your data:
Your data should be accessible as quickly as you are able. Additionally, you can use relevant requirements and expectations (i.e. data repository policies, award record retention requirements, or journal policies) to determine when to make your data sets available. The NIH requires that you share your data when you publish your work or before your performance period ends, whichever comes first, regardless of journal or repository policies.

Leveraging Lab Archives for Data Sharing

OSU CHS provides LabArchives Electronic Lab Notebooks (ELN) to all personnel and students. Scientific data can be organized in a designated notebook, to separate it from the ELN and shared using one of the data publishing workflows available within the ELN.  Metadata can be added as an entry on the page containing the scientific data to be shared.  This may include methodology and procedures, protocols, data labels, definitions, or any other information that will aid in reproducing and understanding the data.  Further, when publishing data via the ELN with the creation of a DOI, additional metadata can be added to include authors, grant or funding IDs, and ORCID.  A DOI is created and assigned to the shared data as a permanent digital identifier that can be referenced elsewhere and provides a link back to the data.  Once published with the DOI, the scientific data is publicly available to anyone with access to the DOI. More information about LabArchives can be found here.

Frequently Asked Questions

Start by viewing this informative list of FAQ's from NIH.

Compliance & Institutional Oversight

NIH expects researchers and institutions to implement data management and sharing practices as described in their approved Plan. Once the grant has been awarded, the Data Management and Sharing Plan becomes part of the award's terms and conditions. Non-compliance may result in:

• Additional terms and conditions to the award
• Cancellation of the award
• The potential to affect future funding decisions

When in doubt, ask your NIH program official. They are well-versed in the requirements for the plans and can help assist you with interpretations of specific institute rules and your specific circumstances.

Responsibility for overseeing the implementation of DMSPs is flexible with the NIH policy. Although the specifics may vary depending on the project, the following general responsibilities apply:

• Overall responsibility is attributed to the PIs who are required to ensure the execution of DMSP.
  
• The consistency of sharing of data concerning human subjects between the DMSP and informed consent is ensured by the IRB.
  
• PIs and OSU CHS Office of Research ensure the correct data use agreements are established before sharing sensitive data.