Agency Changes to Data Management and Sharing Plan Requirements

NIH: A More Structured, Simplified Format

The most significant change to the NIH DMS Plan format is the shift from a narrative-based plan covering six elements to a structured format with Yes/No questions requiring explanations only for “No” responses or when sharing will be limited. While this simplifies the writing process, it also shifts the focus toward clear commitments and compliance rather than descriptive planning.

1. Maximum appropriate sharing
   1. You should generally answer “Yes,” meaning data will be shared as openly as possible and as restricted as necessary. If sharing is limited (e.g., controlled access), provide justification in Question 4.
2. Timing of data sharing
   1. Data must be shared either:
      1. By the time of publication or,
      2. By the end of the period of performance (including no-cost extensions)
3. Data availability duration
   1. This refers to whether data will remain available according to repository policies. In practice, this means aligning data sharing and storage that meets Harvard Retention Requirements (e.g., 7 years)
4. Justification for limiting sharing of data (200 words maximum)
   1. Use this section to explain any restrictions on sharing, including ethical, legal, or technical reasons. Refer to FAQ: What are the justifiable reasons for limiting sharing of data.
5. Human participant protections
   1. This confirms compliance with NOT-OD-22-213. A “No” response would indicate non-compliance, so investigators should familiarize themselves with NOT-OD-22-213 and plan accordingly.
6. Data type and repository table (100 words maximum)
   1. This is the most important new element. Investigators must list:
      1. Data types, including species and modality (e.g., human scRNA sequencing data, mouse flow cytometry data, etc.)
      2. Associated repositories
   2. For selecting a suitable data repository for your data type, please refer to our resources for finding a repository.
7. Genomic Data Sharing (GDS) Policy compliance
   1. This question applies to studies subject to the NIH Genomic Data Sharing (GDS) Policy (e.g., large-scale human genomic data). It asks whether data will be shared in a NIH-designated repository according to GDS timelines and whether you will meet the expectations of the Institutional Certification requirements outlined in the GDS policy (NOT-OD-14-124).

Review NIH Data Management and Sharing Plan Guidance

NSF: Internal Form for Streamlined Tracking

NSF released revised language to specify the requirements on Research.gov for applicants to follow for submission of their data management and sharing plans. This new form may include the standard sections recommended in a DMSP, but it will only be accessible on Research.gov. The Research.gov tool will be released on April 27, 2026. Proposals submitted before that date should continue preparing the DMSP as a PDF upload.

Review NSF Data Management and Sharing Plan Guidance

Please Don’t Skip the Planning and Implementation

While a structured format reduces applicant burden, it may also reduce the intentional planning process that narrative plans encouraged.

The process of thinking through how data will be managed, documented, and shared across the research lifecycle is still essential. The new format does not replace the need for careful planning, it simply standardizes how that information is reported.

As data sharing becomes increasingly mandatory and scrutinized, following best practices for data management is more important than ever. Thoughtful planning helps ensure that data can be shared smoothly and in alignment with FAIR (Findable, Accessible, Interoperable, and Reusable) principles.

We recommend drafting a robust DMS Plan for any research project (regardless of funding status). Having a strong, comprehensive DMS Plan supports effective data management practices throughout the entire project lifecycle, and sets research teams up for success for streamlined data sharing and compliance.

We are here to help! The Countway Library Data Services provides free DMS Plan writing and review services. We also:

• Help identify appropriate data repositories
  • Domain-specific solutions
  • Generalist and institutional repository options, including:
    • Harvard Dataverse Repository
    • Open Science Framework
• Provide guidance on documentation and metadata
  • Help identify appropriate standards
  • Use of Electronic Lab Notebook solutions
  • Use of protocols.io for developing and sharing reproducible, citable research methods

We are happy to meet with you to review customized guidance for your needs.

Request a Consultation

Start Preparing Now

Although the new formats are not effective yet, now is the ideal time to prepare.

DMP Tool is expected to implement these updates when they are finalized:

• Updated NIH DMSP template aligned with the new format, consolidating the existing NIH templates currently available in the platform.
• Updated NSF DMSP template reflecting the final version of the Research.gov form.

We will offer webinars to walk through the new templates once they become available.

Contact us if you have questions about the new format, data management planning, or general data management questions!

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References

Content of this post was compiled from additional resources:

• DMP Tool Blog: Evolving Data Management Plans: Adapting to news from NSF and NIH
• FORCE11 Upstream Blog: What is the Future of Data Management Plans?
• Bernard Becker Medical Library: NIH DMS Plan Format Updates, 2026 Edition: What to Know
• University of Cincinnati Libraries: Significant Changes to the NIH Data Management and Sharing Plan requirements starting in May