NOT-OD-26-100: Implementation Update: NIH Data Management and Sharing Plan Requirements

Implementation Update: NIH Data Management and Sharing Plan Requirements

Notice Number:

NOT-OD-26-100

Key Dates

Release Date:

July 29, 2026

Related Announcements

February 25, 2026 – Updated Elements of an NIH Data Management and Sharing Plan. See Notice NOT-OD-26-046.
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

This Guide Notice provides an update to the research community on forms changes when NIH transitions to the updated Data Management and Sharing (DMS) Plan format which includes reporting changes to previously approved DMS Plans.

Background

The NIH Data Management and Sharing (DMS) Policy ensures that the benefits of taxpayer funded research are maximally shared to advance research, improve health outcomes, and cultivate trust in the biomedical research enterprise. When released in 2023, NIH issued supplemental information outlining desired elements of a DMS Plan. After several years of implementation experience, NIH issued Notice NOT-OD-26-046, Updated Elements of an NIH Data Management and Sharing Plan, to provide a structured template and format across all NIH Institutes, Centers, and Offices (ICOs.) NIH is finalizing implementation of this new format to ensure NIH's data sharing goals are achieved while reducing administrative burden and improving reporting efficiency. The planned updates to the DMS Plan format do not constitute a change in NIH policy.

The NIH Data Management and Sharing (DMS) Policy continues to require applicants to submit a DMS Plan for any NIH-funded or conducted research that will generate scientific data, with limited exceptions as described in the DMS Policy (See, NIH Grants Policy Statement 8.2.3.2 and the list of NIH activity codes subject to the DMS Policy).

Transitioning to the Updated DMS Plan Format

Beginning in FY 2027, NIH will require all existing awards and applications subject to the NIH DMS Policy to transition and align with the updated DMS Plan format. This requirement applies regardless of when the competing application was submitted.

Expected Transition and Reporting Requirements for Adoption of the updated DMS Plan Format:

Stage of Award	Expected Transition to the Updated DMS Plan Format
Competing applications submitted on or after May 25, 2026	Submit a DMS plan in the updated format with the application, as described in NOT-OD-26-046.
Competing applications submitted prior to May 25, 2026 (not yet awarded)	Provide a revised DMS Plan using the updated format during the Just-in-Time (JIT) process. If the competing application has already been awarded, the recipient will be required to transition to the updated DMS Plan format at the next Research Performance Progress Report (RPPR).
Active awards subject to 2023 DMS policy (see list of NIH activity codes subject to the DMS Policy)	Provide a revised DMS Plan using the updated format at the next Research Performance Progress Report (RPPR). If the FY2026 RPPR has already been submitted, the recipient will be required to transition to the updated format in the FY2027 RPPR.
All active awards expected to generate scientific data (see list of NIH activity codes subject to the DMS Policy) including those subject to the 2003 DMS Policy (i.e., applications submitted before January 2023).	Provide a DMS Plan in the updated format with the FY2027 RPPR.

Revisions to DMS Plans and Reporting Requirements

Consistent with NIH burden reduction efforts and the implementation of the updated DMS Plan format, recipients will no longer be required to obtain prior approval to modify an approved DMS Plan. As such, NIH plans to retire the DMS Prior Approval Request type in the eRA Commons Prior Approval Module.

Effective October 1, 2026, recipients must use the RPPR (Section C.5.c.) to report progress on data sharing activities and notify NIH of changes to an approved DMS Plan, such as changes in scientific direction, data repositories, or sharing timelines.

NIH websites, FAQs, and other related resources will be mofified to reflect the transition to the updated DMS Plan format and the revised reporting requirements described in this Notice.

Inquiries

Please direct all inquiries to:

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