NIH Data Management and Sharing Plan: What It Requires

The NIH Data Management and Sharing (DMS) Policy requires a DMS Plan for essentially every NIH-funded or NIH-conducted project that will generate scientific data, with only limited exceptions. It took effect for competing applications, renewals, and resubmissions with due dates on or after January 25, 2023, replacing the narrower 2003 data-sharing policy that applied only to awards of $500,000 or more in direct costs in a single year. The current policy has no such dollar threshold — it applies by data generation, not award size.

Last verified 25 August 2026 against NIH’s Data Management and Sharing Policy Overview, the NIDDK and NIEHS guidance pages on writing a DMS Plan, and NIH’s April 2026 announcement of the simplified pilot plan format.

Who Has to Submit One

A DMS Plan is required for any NIH-funded or NIH-conducted research, regardless of funding level, that will generate scientific data — defined broadly as the recorded factual material commonly accepted in the scientific community as necessary to validate and replicate research findings. This reaches far beyond the wet-lab and clinical-trial awards the old policy mostly touched: R01s, program projects, and many other mechanisms that generate any scientific data now need a plan. Data NIH explicitly does not expect to be shared as “scientific data” include lab notebooks, preliminary analyses, case report forms, drafts of scientific papers, plans for future research, peer reviews, and communications with colleagues.

Some awards fall outside scope entirely — research and development contracts (governed instead by FAR/HHSAR clauses), Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) awards where sharing requirements are set by contract terms rather than this policy, and training, fellowship, construction, or conference grants that do not themselves generate scientific data. Applicants uncertain whether a specific mechanism is in scope should confirm with the relevant NIH Institute or Center rather than assume either way.

The Six Required Elements

NIH’s standard DMS Plan format asks applicants to address six elements. NIH recommends keeping the plan to roughly two pages.

1. Data Type

What scientific data the project expects to generate — and, separately, which of that data will be preserved and shared, since not everything generated has to be shared. Includes related metadata, and the estimated scale (approximate volume, for context).

2. Related Tools, Software, and/or Code

Whether specialized tools, software, or code are needed to access or manipulate the shared data — including custom-written analysis code — and whether that code itself will be made available.

3. Standards

What data and metadata standards will be applied, covering file formats, data identifiers, definitions of variables, and other formatting conventions, consistent with those used in the relevant scientific community where such standards exist.

4. Data Preservation, Access, and Associated Timelines

The name of the repository (or repositories) where data will be archived, how long it will be preserved, and when it will be made available — NIH’s expectation is no later than associated publication or the end of the performance period, whichever comes first.

5. Access, Distribution, or Reuse Considerations

Any factors affecting subsequent access, distribution, or reuse — informed consent language, privacy protections for human subjects data, controlled-access requirements, or other legal/ethical restrictions — and whether a data use agreement will govern secondary use.

6. Oversight of Data Management and Sharing

How the plan’s implementation will be monitored, and who at the institution or within the project is responsible for that oversight.

Submission and Review

The DMS Plan is submitted as an attachment with the application (in the “Other Plan(s)” attachment field), not negotiated separately after award the way some earlier NIH plans were. NIH Institute and Center program staff — not peer reviewers on study section — assess the plan for scientific and technical merit as part of the funding decision, and reviewers are explicitly instructed not to factor the DMS Plan into the application’s overall impact score. Once an award is made, the DMS Plan becomes a term and condition of the award, and grantees are expected to comply with the plan as submitted (or as subsequently updated with NIH concurrence).

The 2026 Simplified Pilot Format

NIH announced a pilot DMS Plan format in April 2026 that replaces most narrative elements with structured yes/no and short-answer questions, intended to reduce applicant burden and produce more consistent, machine-actionable plans. Applications and awards with due dates on or after May 25, 2026 are required to use the new format; earlier submissions continue to use the original six-element narrative structure described above. Research administrators supporting NIH applicants should confirm which format a given funding opportunity now expects before an application goes in, since both formats will be in active use during the transition.

How This Differs from a Generic Data Management Plan

Many funders now require some form of data management plan — see CASRAI’s UKRI Data Management Plan guide for the UK funder’s version — but NIH’s DMS Plan has its own required elements, its own submission mechanics (an application attachment reviewed by program staff, not peer reviewers), and its own scope rules tied to “scientific data” as NIH defines the term. A plan written to satisfy one funder’s template will not automatically satisfy another’s; research administrators managing multi-funder portfolios should treat each funder’s plan as a distinct compliance requirement rather than assume one plan transfers.

Frequently Asked Questions

Does every NIH grant need a Data Management and Sharing Plan?

Every NIH-funded or NIH-conducted project that will generate scientific data needs one, regardless of budget size — there is no dollar threshold under the current policy. Mechanisms that do not generate scientific data (most fellowships, training grants, and conference grants) and awards governed by separate terms (R&D contracts, SBIR/STTR) fall outside the policy’s scope.

When is the NIH DMS Plan due?

It is submitted as part of the application, in the Other Plan(s) attachment, not negotiated after award. It applies to applications, renewals, and resubmissions with due dates on or after January 25, 2023.

Is the DMS Plan peer reviewed?

No. NIH Institute or Center program staff assess it separately from scientific and technical peer review; study section reviewers are instructed not to factor it into the application’s impact score.

What happens if a grantee doesn’t follow its approved DMS Plan?

The approved plan becomes a term and condition of the award. NIH expects compliance with the plan as submitted or as subsequently modified with NIH’s concurrence, and can address noncompliance through the same award-management mechanisms it uses for other terms and conditions.

What changed with the 2026 pilot format?

NIH introduced a simplified format built around structured yes/no and short-answer questions rather than open narrative, required for applications and awards with due dates on or after May 25, 2026, to reduce burden and standardize plans across the agency.

References

• National Institutes of Health, “Data Management and Sharing Policy Overview,” Office of Science Policy / Grants & Funding.
• National Institute of Diabetes and Digestive and Kidney Diseases, “Guidance for Writing a DMS Plan.”
• National Institute of Environmental Health Sciences, “Data Management and Sharing Plan Development.”
• NIH Office of Intramural Research, “2023 NIH Data Management & Sharing Policy.”
• National Institutes of Health, “2026 Pilot Data Management and Sharing Plan Format Available,” NIH Extramural Nexus (April 2026).