NIH requirements

Data Management and Sharing Plan Guidelines

The National Institutes of Health (NIH) has released the final format of the 2026 Pilot Data Management and Sharing Plan.  This simplified format is required for all new competing and non-competing applications with due dates on or after May 25, 2026. 

The pilot DMS Plan format consists primarily of Yes/No questions addressing core data sharing expectations, along with brief justifications if data sharing may be limited due to legal, ethical, or technical considerations. A concise table identifying anticipated data types and repositories is also required.

In NOT OD 26 046, NIH indicates that the streamlined DMS Plan format in being implemented as a pilot initiative designed to reduce administrative burden and improve consistency across submissions. The format will be evaluated and refined as appropriate in the coming year. Instructions and guidance for writing a Data Management and Sharing plan are available on the NIH website. 

The NIH-wide Policy 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.”

Your Data Management and Sharing Plan should also be referenced in:

  • Budget, if costs are associated;
  • Budget Justification (no more than two paragraphs--this is the only part of the DMSP that reviewers will see);
  • Background and Significance (especially for large databases); and
  • Human Subjects (for confidentiality assurances)

Sharing methods should be specific to the type of data being produced and can include publishing, researcher efforts, a data enclave or archive, or a mix of these. If intellectual property is anticipated to be developed as a result of the proposed research, investigators should consider patent issues, potential proprietary information, and possible restrictions for privacy laws (HIPAA, etc.).

In all cases, protecting the rights and privacy of human subjects should be a top priority.

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