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Priority review Guidance Amended Final

NIH Updates Data Management and Sharing Plan Elements

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Published February 25th, 2026
Detected March 7th, 2026
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Summary

The National Institutes of Health (NIH) has updated the required elements for Data Management and Sharing Plans (DMS Plans) for research applications. Effective for due dates on or after May 25, 2026, a new, simpler format page will be required. This update aims to streamline the process and reduce applicant burden by clarifying common areas of confusion and removing extraneous details.

What changed

The National Institutes of Health (NIH) has issued a notice (NOT-OD-26-046) updating the required elements for Data Management and Sharing (DMS) Plans. This revision supersedes previous guidance (NOT-OD-21-014) and aims to simplify the plan by focusing on four key questions regarding data sharing. The NIH has observed that many submitted DMS Plans contained extraneous details, leading to increased applicant burden. The updated guidance will be accompanied by a new, simpler DMS Plan Format Page, which will be mandatory for applications submitted on or after May 25, 2026.

This change requires researchers applying for NIH funding that generates scientific data to adopt a more streamlined approach to their DMS Plans. Compliance officers should ensure that their research teams are aware of the new required elements and the mandatory use of the updated format page for applications submitted from May 25, 2026, onwards. While the policy itself is not new, the specific elements and format have been simplified to improve efficiency and aid compliance monitoring. No specific penalties are mentioned for non-compliance with the format, but adherence to the DMS Policy is a requirement for funding.

What to do next

  1. Review updated NIH Data Management and Sharing Plan elements.
  2. Prepare to use the new, simpler DMS Plan Format Page for applications due on or after May 25, 2026.
  3. Ensure research teams are aware of the revised requirements for DMS Plans.

Source document (simplified)

Updated Elements of an NIH Data Management and Sharing Plan Notice Number: NOT-OD-26-046

Key Dates

Release Date: February 25, 2026

Related Announcements

October 29, 2020 - Supplemental Information to the NIH Policy for Data Management and Sharing: Elements of an NIH Data Management and Sharing Plan. See Notice NOT-OD-21-014.

October 29, 2020 - Final NIH Policy for Data Management and Sharing. See Notice NOT-OD-21-013.

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

The National Institutes of Health (NIH) Data Management and Sharing Policy requires applicants to submit a Data Management and Sharing Plan (DMS Plan) for any NIH-funded or conducted research that will generate scientific data (See NIH Grants Policy Statement 8.2.3.1). As part of its ongoing efforts to increase efficiency and minimize applicant burden, NIH is updating the required elements of a DMS Plan. This notice supersedes NOT-OD-21-014.

A DMS Plan must reflect the proposed approach to data management and sharing at the time it is prepared and must be updated throughout the life of the project, as appropriate. NIH encourages data management and sharing practices to be consistent with the FAIR (Findable, Accessible, Interoperable, and Reusable) data principles and reflect best practices within specific research communities.

A DMS Plan must address the elements described below. An updated DMS Plan Format page will be made available upon receipt of OMB clearance. A draft can be viewed here: Data Management and Sharing Plan Format Page. Effective for applications submitted for due dates on or after May 25, 2026, applicants and recipients are required to utilize the new, simpler format. NIH is implementing this updated format page as a pilot and will evaluate the need for additional updates over the next year.

Background:

This Guide Notice is intended to update DMS Plan elements 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.

Data Management and Sharing Plan Elements should include only the following:

  1. 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)? [YES/NO]
  2. 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? [YES/NO]
  3. Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies? [YES/NO]
  4. 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. [300 words maximum]
  5. 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? [YES/NO]
  6. In the table below, please list [100 words maximum]:
  7. Key types of scientific data anticipated to be generated during the project, including the species and modality, if known (e.g., “human genomic data,” “rat functional magnetic resonance imaging data”). NIH recognizes that not all data types expected to be generated in the study will meet the definition of scientific data or can be anticipated in advance.  If a data type does not appear on the list, it does not imply that that data type will not be shared if it is generated in the study.
  8. The repository or an example of a repository where the scientific data may be managed and shared, if the scientific data is known at time of application. NIH expects the use of established repositories for preserving and sharing scientific data when they are available.

| Expected Data Type | Established Repository or Example |
| | |

  1. For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
    1. 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. [YES/NO/Not Applicable]. If “no,” address in element 4.
    2. 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)? [YES/NO/Not Applicable] If “no,” address in element 4. NIH websites, FAQs, and other resources are being updated to reflect these new elements.

Inquiries

Please direct all inquiries to:

NIH Office of Policy for Extramural Research Administration
[email protected]

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Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Various Federal Agencies
Published
February 25th, 2026
Compliance deadline
May 25th, 2026 (72 days)
Instrument
Guidance
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Drug manufacturers Pharmaceutical companies Healthcare providers
Geographic scope
National (US)

Taxonomy

Primary area
Education
Operational domain
Research Operations
Topics
Data Management Scientific Data Sharing Grant Applications

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