The Office of Science and Technology Policy (OSTP) is a small White House office with an outsized influence on research administration in the United States. It does not fund research, run programs, or enforce compliance directly — but the policy memoranda it issues become, within a year or two, the terms and conditions attached to federal grant awards at every research institution in the country. This guide explains what OSTP is, the specific policy instruments it has issued that research administrators need to track, and how a White House memo actually turns into an obligation your institution has to meet. The most recent statement of OSTP’s own posture is Science: A New Golden Age, the 123-page report to the President it published on 21 July 2026.
What OSTP is
OSTP was established as a statutory office within the Executive Office of the President by the National Science and Technology Policy, Organization, and Priorities Act of 1976. Its statutory mission is to advise the President and others within the Executive Office on the scientific, engineering, and technological aspects of domestic and international affairs, and to lead interagency coordination of federal science and technology policy.
OSTP is led by a Director who, when Senate-confirmed, also holds the title Assistant to the President for Science and Technology. OSTP staffs and coordinates two related bodies that research administrators will also see referenced in agency guidance:
- The National Science and Technology Council (NSTC) — a Cabinet-level council, chaired by the President, that coordinates science and technology policy across federal agencies. Much of the substantive work behind OSTP memos (including the public access and scientific integrity policies covered below) is done through NSTC subcommittees and interagency working groups.
- The President’s Council of Advisors on Science and Technology (PCAST) — an advisory council of outside experts that reports directly to the President; OSTP provides its staff support.
For a research administrator, the operative fact is simple: OSTP itself does not regulate your institution. Individual funding agencies — NIH, NSF, DOE, NASA, DOD, and others — do that, through their own regulations, notices, and award terms. OSTP’s role is to set government-wide policy direction that those agencies are then directed to implement, each on its own timeline and with its own specifics.
The policy instruments research administrators actually need to track
Four OSTP-originated policy instruments account for most of the compliance obligations that trace back to this office. Each is a memorandum or presidential memorandum, not a self-executing regulation — agencies still have to translate each one into their own rules.
The 2013 Holdren memo: the 12-month-embargo era
In February 2013, OSTP Director John Holdren issued the memorandum “Increasing Access to the Results of Federally Funded Scientific Research,” directing federal agencies with more than $100 million in annual research and development expenditures to develop plans for public access to the peer-reviewed publications and, where feasible, the underlying data resulting from their funded research. Agency implementation plans that followed — the NIH Public Access Policy’s 2008 mandatory phase among them — generally permitted publishers a 12-month embargo before public deposit was required. This is the policy environment most current researchers grew up under: publish, then a manuscript becomes publicly available roughly a year later.
The 2022 Nelson memo: zero embargo
On August 25, 2022, OSTP (under Alondra Nelson, then serving as Acting Director) issued “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research,” commonly called the Nelson memo. It directed all federal agencies that fund research and development — not just the larger agencies the 2013 memo covered — to update their public access policies to require immediate, zero-embargo public access to both peer-reviewed publications and the underlying scientific data, with agency policies required to take effect no later than December 31, 2025.
Agencies have implemented this on staggered timelines: NIH’s 2024 Public Access Policy applies to manuscripts accepted for publication on or after July 1, 2025 (see CASRAI’s guide to the NIH Public Access Policy); NSF’s implementation is its Public Access Plan 2.0 (see the NSF Public Access Repository guide); other agencies, including DOE and DOD, have issued or updated their own plans on similar timelines. As of mid-2026, there is credible trade-press and congressional-appropriations reporting that OSTP may be reconsidering or rolling back the Nelson memo’s zero-embargo mandate under the current administration. That process was not settled at the time of writing. Research administrators should verify the current status of both the memo and their specific funding agencies’ public access policies directly against agency guidance rather than assuming the description above remains current indefinitely.
NSPM-33: research security
On January 14, 2021, the White House issued the Presidential Memorandum on United States Government-Supported Research and Development National Security Policy, universally referred to by its numeric designation, NSPM-33. It directs federal research funding agencies to strengthen and standardize disclosure requirements for researchers’ sources of support and affiliations, and to require research-performing institutions that receive more than $50 million per year in federal research funding to certify that they have established a formal research security program.
OSTP and NSTC subsequently issued implementation guidance (January 2022) and a further “Research Security Programs Standard Requirement” guidance document (July 2024) spelling out what those institutional research security programs must actually contain. See CASRAI’s dedicated guide on NSPM-33’s four mandated research security program elements for the detail; related pages cover the standardized current and pending support disclosure format, the definition of a “covered individual” under the policy, and insider threat program mechanics.
Scientific integrity policy
On his first full day in office in January 2021, President Biden issued a Presidential Memorandum on “Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking,” which directed OSTP to convene an interagency task force, under NSTC, to review and strengthen federal scientific integrity policies. That task force’s work produced the Framework for Federal Scientific Integrity Policy and Practice, delivered to agency heads by then-OSTP Director Arati Prabhakar on January 12, 2023. The framework sets a common definition of scientific integrity, a model policy agencies are expected to adapt, and evaluation tools — and it prohibits political interference in the design, conduct, management, or communication of federally funded research and scientific activities. Individual agencies (NIH, NSF, EPA, NOAA, and others) have since issued or revised their own scientific integrity policies against this common framework.
What this means operationally for research administrators
None of the four instruments above is, itself, the thing your institution has to comply with — each becomes a compliance obligation only once translated into agency policy and award terms. In practice, that translation touches several concrete parts of the research administration workflow:
- Data management and sharing plans. The Nelson memo’s data-access directive is a major reason funder data management plan requirements have tightened across agencies since 2022 — plans increasingly need to specify not just whether data will be shared, but how it will meet zero-embargo timelines.
- Persistent identifiers and metadata. Agencies implementing both the public access and research security directives lean heavily on persistent identifiers — ORCID iDs for researchers and ROR IDs for institutions — to link disclosures, publications, and datasets together and to reduce duplicate or inconsistent reporting across current-and-pending-support forms.
- Repository deposit. Zero-embargo public access means author-accepted manuscripts and, increasingly, underlying datasets need a defined repository destination (an agency repository such as PMC or NSF-PAR, or an institutional or disciplinary repository that meets the agency’s criteria) built into the workflow from the start, not arranged after acceptance.
- Publication-cost handling. As embargoes disappear, institutions and PIs are seeing more attention to how article processing charges and other publication costs are budgeted and allowed on federal awards, since “green” embargoed deposit is no longer an option some agencies permit as a lower-cost alternative to paying for immediate open access.
- Institutional research security program elements. For covered institutions, NSPM-33 compliance means a documented program spanning cybersecurity controls, foreign travel security procedures, insider threat awareness, and export control coordination — see CASRAI’s guide on export control compliance fundamentals for how that overlaps with existing export-controlled research obligations.
How an OSTP memo becomes an actual obligation
The propagation path is consistent across all four instruments above, and understanding it is the single most useful thing a research administrator can take from this page:
- OSTP issues a memo setting government-wide policy direction, typically after NSTC interagency working-group development.
- Each funding agency writes its own implementation plan or policy — NIH’s Public Access Policy, NSF’s Public Access Plan 2.0, agency-specific research security policies, and so on — on its own timeline, with its own scope and specifics. Agencies are not required to implement identically, and in practice they don’t.
- The agency policy becomes a term and condition of individual awards — referenced in funding opportunity announcements, grants policy statements, and notices of award. This is the actual compliance object: the award’s terms and conditions, not the original OSTP memo.
A frequent, avoidable error is citing the OSTP memo itself as the compliance requirement in an internal policy or a PI-facing guidance document. The memo describes intent; the agency’s own policy, as reflected in your specific award’s terms and conditions, is what your institution is actually bound by, and that is also what changes first if a memo is later revised, delayed, or rescinded.
Frequently asked questions
Is OSTP a regulatory agency?
No. OSTP is a policy and coordination office within the Executive Office of the President. It has no independent grant-making, rulemaking, or enforcement authority over research institutions. Its memoranda direct other federal agencies, which do hold that authority, to act.
Does the OSTP Director need Senate confirmation?
The Director position, when filled on a Senate-confirmed basis, also carries the title Assistant to the President for Science and Technology. The office can also be led by an Acting Director without Senate confirmation, as was the case when the 2022 Nelson memo was issued.
Do the Holdren and Nelson memos both still apply?
The Nelson memo’s zero-embargo requirement effectively superseded the Holdren memo’s 12-month-embargo allowance for agencies implementing it. Given the reported 2026 reconsideration of the Nelson memo discussed above, institutions should check current guidance from OSTP and their specific funding agencies rather than assuming either policy’s status is fixed.
Does NSPM-33 apply to every research institution?
The formal research-security-program certification requirement applies to institutions receiving more than $50 million per year in federal research funding; the standardized disclosure requirements for research support and affiliations have broader reach across federally funded senior/key personnel generally. See the dedicated research security policy and research security dictionary entries for the fuller picture, including the role of a research security officer.
Where can I find the current text of these memos?
OSTP publishes its policy documents at whitehouse.gov/ostp; individual funding agencies publish their own implementation policies on their respective public access and research security pages. Because implementation dates and specifics change, always confirm current requirements against the funding agency’s own guidance for the specific award or program in question rather than relying on a secondary summary, including this one, for compliance decisions.
How well agencies are implementing the 2022 OSTP public-access directive is now on the federal audit record. In May 2026 the Government Accountability Office published GAO-26-107738, the first major audit of agency implementation, finding that federal science agencies have not adequately planned for the publishing cost increases the shift to public access brings.







