Open access
The object can be shared publicly under the controlling consent, rights, ethics, and policy conditions.
Record: Repository, license, identifier, release date, documentation, and integrity check.
Data sharing requirements and release record
What do NIH and NSF require for data sharing in 2026?
The current NIH DMS Plan elements, how NIH plan changes are reported from October 1, 2026, and NSF's Research.gov plan requirement, each linked to its source. Then a six-step record for releasing each data object.
Manusights · Evidence checked October 1, 2026 · Four-page working record · CC BY 4.0
Start the record / Decision 01
Data object
What exact files, variables, code, documentation, and derived outputs support the result?
Evidence to keep: Named objects, formats, approximate size, provenance, and a responsible owner.
Work through the decisionsSources and scope · Guide reviewed October 1, 2026
- Coverage
- NIH data-management and sharing policy, the 2026 DMS Plan elements, post-award plan changes and the move of existing awards to the 2026 format, NSF's Research.gov DMSP requirement, access-tier reasoning, repository records, release timing, and stewardship
- Source basis
- Seven current NIH primary sources and NSF's PAPPG 24-1 Supplement 2; repository names, costs, journal mandates, and FAIR labels are not presented as universal or permanently current
Prepared by the Manusights editorial team. Publisher and institutional instructions take precedence.
Use this in the work
Download the Data sharing release record
Print it, complete it with collaborators, or adapt the original framework with attribution. The PDF is generated from the same reviewed evidence record as this page.
- Edition
- 2026.09.15-data-1
- Format
- License
- CC BY 4.0
- Evidence reviewed
- October 1, 2026
What NIH requires in a 2026 DMS Plan
For applications submitted for due dates on or after May 25, 2026, NIH requires its new, simpler DMS Plan format. NIH says the plan should include only the elements below; they replace the 2023 elements in NOT-OD-21-014. Source C and Source D.
1. Sharing
Will there be maximum appropriate sharing of the scientific data underlying peer-reviewed publications and other findings from the award, including preprints and papers reported at conferences?
Answer: Yes / No
2. Timing
Will data underlying peer-reviewed publications be shared by the time of publication, and data for other findings by the end of the period of performance, including no-cost extensions?
Answer: Yes / No
3. Duration
Will shared data stay available for at least as long as the repository's or journal's policy requires?
Answer: Yes / No
4. Limitations
If you answered no to 1, 2 or 3, or sharing will be limited in another way, describe the limitation and the specific ethical, legal or technical reason for it.
Answer: 300 words maximum
5. Human participants
If data from human participants will be shared, will participants' privacy, rights and confidentiality be protected as set out in NOT-OD-22-213, including whether any data will be shared under access controls?
Answer: Yes / No
6. Data types and repositories
A table of the key types of scientific data expected (with species and modality if known) and the established repository, or an example repository, for each.
Answer: 100 words maximum
7. Genomic data
Only for studies under the NIH Genomic Data Sharing Policy: two questions on sharing large-scale human genomic data in an NIH-designated repository on the GDS timelines, and on meeting the GDS Institutional Certification expectations. Explain any no in element 4.
Answer: Yes / No / Not applicable
The wording above is our summary; use the questions exactly as they appear on the NIH format page. The policy itself has not changed: NIH still requires a DMS Plan for research that will generate scientific data, with the exceptions in the DMS Policy. Source F.
Changing a plan after award, from October 1, 2026
Recipients no longer need NIH's prior approval to modify an approved DMS Plan, and NIH plans to retire the DMS prior approval request in the eRA Commons Prior Approval Module. From October 1, 2026, recipients use the RPPR, Section C.5.c, to report progress on data sharing and to tell NIH about changes to an approved plan, such as a change in scientific direction, repository or sharing timeline. Source F.
When existing applications and awards move to the 2026 format
From FY2027, NIH requires every existing award and application under the DMS Policy to move to the 2026 format, whenever the application was submitted. Source F.
Competing application submitted on or after May 25, 2026
Submit the plan in the 2026 format with the application.
Competing application submitted before May 25, 2026
If not yet awarded, provide a revised plan in the 2026 format during Just-in-Time. If already awarded, move to the 2026 format at the next RPPR.
Active award under the 2023 DMS Policy
Provide a revised plan in the 2026 format at the next RPPR. If the FY2026 RPPR has already been submitted, do it in the FY2027 RPPR.
Any other active award expected to generate scientific data, including awards under the 2003 policy (applications before January 2023)
Provide a plan in the 2026 format with the FY2027 RPPR.
Career development (K) awards: NIH has said K applications will no longer require a DMS Plan, as part of K program changes beginning with due dates on or after October 12, 2027. Source G.
What NSF requires
NSF proposals must include a Data Management and Sharing Plan (DMSP) created with the tool on Research.gov, which NSF released on April 27, 2026. Proposals submitted before that date used a PDF upload. NSF recipients are required to share all data supporting NSF-funded publications at the time of publication, and any exception must be described and justified in the DMSP. Directorate- or program-specific requirements apply where NSF publishes them. Source H.
Choose the release route
Open is one responsible outcome, not the only responsible outcome
Start with the exact object and its controlling terms. Sensitivity, size, complexity, and expected requests can change the appropriate access method and repository. Source B.
Controlled access
Qualified access is possible but direct public release would create privacy, consent, contractual, or security risk.
Record: Access committee or process, eligibility, agreement, review time, safeguards, and contact.
Restricted or unavailable
A controlling constraint prevents sharing the object in a responsible form.
Record: Specific constraint, decision authority, shareable metadata or synthetic alternative, and review date.
Original Manusights framework
Trace the shareability chain
Complete the chain for each meaningful data object. If one link is unresolved, the final availability statement is not ready.
- Link 1
Data object
What exact files, variables, code, documentation, and derived outputs support the result?
Evidence: Named objects, formats, approximate size, provenance, and a responsible owner.
- Link 2
Rights and participant terms
What do consent, ethics review, agreements, law, and third-party rights permit?
Evidence: Controlling document, allowed uses, prohibited uses, and unresolved restrictions.
- Link 3
Access tier
Can the object be open, controlled, or not shared publicly?
Evidence: Risk rationale, access decision, review authority, and any conditions for access.
- Link 4
Repository and metadata
Where will the preserved object and its documentation live?
Evidence: Repository fit, persistent identifier plan, metadata, README, data dictionary, and code environment.
- Link 5
Release trigger
What event and date make the object available?
Evidence: Publication or performance-period trigger, deposit status, embargo if permitted, and verification owner.
- Link 6
Stewardship
Who answers access requests and maintains the record?
Evidence: Named role, retention period, versioning, withdrawal process, and contact route.
Current NIH control
Use the 2026 DMS Plan format
The simplified format applies to applications due on or after May 25, 2026. Use the live NIH format page, reflect the actual approach, and update the plan when the approach changes. From October 1, 2026, report those changes in the RPPR rather than through a prior approval request. Source C, Source D and Source F.
Timing control
Name the release trigger
Under the NIH policy, covered scientific data should be shared as soon as possible and no later than the associated publication or the end of the performance period, whichever comes first. The DMS Plan and any award terms remain controlling. Source A.
Statement construction
Write only what the release record can support
Open example
De-identified analysis files, code, a data dictionary, and a frozen environment record will be deposited in [repository] under [license] by [trigger].
Controlled example
Qualified researchers may request access through [process] subject to [agreement and review]. Metadata and the request route will be public at [location].
Restricted example
The underlying records cannot be publicly shared because [specific controlling constraint]. [Metadata, code, or a bounded alternative] is available at [location].
These are fictional structures, not compliant statements. Replace every bracketed field with a verified project decision and follow the target journal, funder, repository, ethics, and institutional instructions.
Evidence record
Sources, method, and limits
We reconstructed the page around the decisions NIH says a sharing approach must address. The original release chain makes each object traceable from its controlling rights through access, deposit, release, and stewardship.
NIH Policy for Data Management and Sharing
NIH Office of the Director. Locator: Policy requirements, timing, and repositories.
Supports: The DMS Plan requirement, sharing timing, and NIH preference for established repositories.
Open official sourceData Sharing Approaches
NIH Office of Extramural Research. Locator: Repository selection and sharing considerations.
Supports: Considering sensitivity, size, complexity, expected requests, and access method when selecting a sharing approach.
Open official sourceUpdated Elements for NIH Data Management and Sharing Plans
NIH Office of Extramural Research. Locator: Implementation date and updated elements.
Supports: The simplified format for applications due on or after May 25, 2026 and the need to update plans when the approach changes.
Open official sourceData Management and Sharing Plan Format Page
NIH Office of Extramural Research. Locator: Current DMS Plan format.
Supports: The current 2026 DMS Plan format and official planning instructions.
Open official sourceDesignating Scientific Data for Controlled Access
NIH Office of Extramural Research. Locator: Controlled-access considerations.
Supports: Factors for determining when controlled access is appropriate for scientific data.
Open official sourceImplementation Update: NIH Data Management and Sharing Plan Requirements, NOT-OD-26-100
NIH Office of the Director. Locator: Transitioning to the Updated DMS Plan Format; Revisions to DMS Plans and Reporting Requirements.
Supports: The end of prior approval for DMS Plan changes, RPPR Section C.5.c reporting from October 1, 2026, and the schedule for moving existing awards to the 2026 format.
Open official sourceNotice of NIH Updates to Career Development (K) Award Programs, NOT-OD-26-098
NIH Office of the Director. Locator: Program Update 2: Data Management and Sharing Plans No Longer Required for K Awards.
Supports: K award applications will no longer require a DMS Plan, as part of K program updates beginning with due dates on or after October 12, 2027.
Open official sourceImplementation of Policy Changes to PAPPG 24-1, Supplement 2
U.S. National Science Foundation. Locator: Section 3: Data Management and Sharing Plan (Chapter II.D.2.(i).(ii)).
Supports: NSF proposals must include a DMSP created with the Research.gov tool released April 27, 2026, and recipients must share data supporting NSF-funded publications at the time of publication.
Open official sourceLimit: This guide does not determine whether a dataset is de-identified, satisfy consent or law, select a repository for every discipline, approve controlled access, write an award-specific DMS Plan, or replace an institutional privacy, ethics, security, legal, records, or grants review.
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