Background to the Change
Since 2023, the National Institutes of Health (NIH) Data Management and Sharing (DMS) Policy has been promoting public access to NIH-funded research by requiring that its grantees share the data outputs of their studies to the maximum extent possible. As part of this policy, researchers are required to submit a prospective Data Management & Sharing (DMS) Plan as part of their grant application.
When the policy was first launched, the NIH did not require any particular format or template to be used for the DMS Plan, but they described 6 key elements that had to be addressed within the plans.
In February 2026, the NIH released a notice that intended to “clarify common areas of confusion in the research community while streamlining and simplifying DMS Plans.” With this notice, they outlined 7 new elements that future DMS Plans should address, and they also shared a new required Data Management and Sharing Plan Pilot Format Page.
What This Means for Researchers
The new DMS Plan format is required for use in all NIH grant applications submitted on or after May 25, 2026. As noted above, the changes represent a simplification of the DMS Plan itself. However, the underlying expectations and requirements of the NIH DMS Policy remain the same. As such, researchers must still consider many complex, data management issues in order to answer the simplified questions accurately.
The new format contains 7 key elements, 5 of which are now simple yes/no questions:
- Maximum appropriate sharing of scientific data
- Data sharing timeline
- Data availability timeline
- Additional context for questions 1, 2, and 3. This response is a narrative limited to 300 words and gives researchers an opportunity to explain and provide justification for any anticipated limitations on sharing.
- Human subjects data
- Expected data and associated repository(s). This response must be formatted in a table and is limited to 100 words. Researchers will have to list out the different types of data they expect to collect and designate a repository where this data will be shared.
- Genomic data
Additional help is available
The Health Sciences Library will be co-hosting a webinar on the new NIH DMS Plan Format on Thursday, May 14, 2026 at 1 p.m. This session will be held in collaboration with the Ohio State University Libraries Research Commons and the Office of Sponsored Programs.
For more information on the NIH Data Management & Sharing Policy and how to write a compliant DMS Plan, check out the HSL's NIH Data Management & Sharing Policy Guide or the NIH Data Management and Sharing Policy webpage.
