The Tri-Agency Research Data Management Policy is the joint policy of Canada’s three federal granting councils — the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC), and the Social Sciences and Humanities Research Council of Canada (SSHRC) — setting shared expectations for how researchers and institutions receiving Tri-Agency funding manage, document, and share their research data. The agencies adopted it in March 2021. It sits alongside the other pieces of shared Tri-Agency policy — TAGFA for financial administration, the Tri-Agency Open Access Policy on Publications, and TCPS2 for research ethics — that apply uniformly across all three councils rather than varying by which agency funds a given grant. For the wider system this policy sits inside, see Canada’s Tri-Agency Research Funding System.
The three requirements
The policy has three distinct components, and they are not all at the same stage of implementation. Confusing “the policy exists” with “every part of the policy is currently in force” is the single most common misunderstanding research administrators run into.
| Requirement | Who it applies to | Status |
|---|---|---|
| Institutional RDM strategy | Every postsecondary institution and research hospital eligible to administer CIHR, NSERC, or SSHRC funds | In force — due date was March 1, 2023 |
| Data management plan (DMP) at application | Applicants to specific funding opportunities designated by each agency | In force, but rolling out incrementally opportunity by opportunity since spring 2022 — not yet universal |
| Data deposit into a digital repository | Grant recipients, for data/metadata/code underlying published research conclusions | Not yet in force — implementation approach still being finalized as of 2026 |
Requirement 1: institutional RDM strategies
Every postsecondary institution and research hospital eligible to administer CIHR, NSERC, or SSHRC funds was required to create an institutional RDM strategy, describing how the institution provides its researchers with an environment that enables and supports research data management, and to publish that strategy on its own website while also notifying the three agencies. The deadline for this was March 1, 2023. That date has now passed, and the agencies maintain a public list of institutions that have published a strategy, available on the Government of Canada’s science.gc.ca site. For a research administrator, this means the practical question today is no longer “will my institution need to do this” but “has my institution’s strategy actually been kept current” — the policy establishes the strategy as an ongoing institutional commitment, not a one-time compliance exercise, even though the published-by-2023 deadline itself is now behind us.
Requirement 2: data management plans at application
For certain funding opportunities, applicants must submit a Data Management Plan (DMP) to the relevant agency as part of the application. This requirement began rolling out incrementally starting in spring 2022 and has continued to expand since — it is not, and was never designed to be, a single flip-the-switch date after which every Tri-Agency competition suddenly required a DMP. Which specific competitions currently require one is set by each agency and can change between competition years, so the only reliable way to confirm whether a given opportunity requires a DMP is to check that opportunity’s own funding notice rather than assume based on agency or program type. For worked-through examples of what a compliant DMP actually contains, see Data Management Plan Worked Examples; for how the Tri-Agency’s approach to DMPs compares with the two major US funders’ approaches, see NIH vs. NSF Data Management Plans.
Requirement 3: data deposit — current status
The third component requires grant recipients to deposit the digital research data, metadata, and code that directly support the conclusions in a resulting journal publication or preprint into a digital repository, consistent with FAIR (Findable, Accessible, Interoperable, Reusable) principles and relevant disciplinary norms — “where ethical, cultural, legal, and commercial requirements allow.” That final qualifier matters in practice: it is the policy’s own acknowledgment that not all research data can or should be deposited openly, and it is where considerations like Indigenous data sovereignty and the OCAP Principles (Ownership, Control, Access, and Possession) intersect with a funder data policy that otherwise defaults toward openness.
Unlike the institutional-strategy requirement, the data deposit requirement is not yet in force. As of 2026, the agencies have not finalized how it will be implemented or phased in. They have run a formal community engagement process on the deposit requirement specifically — publishing a “What We Heard” report summarizing feedback — and continued inviting further community input on implementation into 2026, with the stated intent of phasing the requirement in only after reviewing institutional readiness. There is no confirmed date yet by which grant recipients will actually need to comply. Research administrators should treat this component as a real, upcoming obligation to plan for, not as something currently enforceable — and should re-check the Tri-Agency RDM Policy pages directly before advising researchers on a firm deposit deadline, since this is the one part of the policy still actively in motion.
One narrower deposit-type requirement does already exist independent of this policy: CIHR’s own participation in the 2015 Tri-Agency Open Access Policy on Publications has, since 2008, required CIHR-funded researchers to deposit bioinformatics, atomic, and molecular coordinate data into the appropriate public database immediately upon publication of research results relying on that data. That obligation predates and sits alongside the newer, broader RDM Policy deposit requirement rather than being replaced by it.
What this means in practice for research administrators
- At the institutional level: confirm your institution’s RDM strategy is published, accurate, and reflects current practice — not just that it was posted once in 2023.
- At the proposal-development stage: check every funding opportunity notice individually for a DMP requirement rather than assuming one applies (or doesn’t) based on past experience with that program.
- At the award and publication stage: the data deposit requirement isn’t yet mandatory Tri-Agency-wide, but researchers depositing data voluntarily now, aligned with FAIR principles, are ahead of where the policy is clearly heading — and CIHR-funded researchers working with bioinformatics or molecular coordinate data already have a live, separate deposit obligation to meet regardless.
- Watch for updates: the deposit requirement is the actively-changing part of this policy. Institutional RDM offices and sponsored-programs offices are the right internal source to monitor for when (and how) it moves from planned to mandatory.
How it compares to other funders’ data policies
The Tri-Agency RDM Policy is structurally similar to, but not identical to, the major funder data-management mandates elsewhere. The US National Institutes of Health’s Data Management and Sharing (DMS) Policy and the National Science Foundation’s directorate-level DMP requirements both require a data management plan at application time, broadly comparable to the Tri-Agency’s second requirement — but neither the NIH nor the NSF policy is paired with a companion requirement that the funded institution itself publish a public institutional data-management strategy, which is distinctly a Tri-Agency feature. See NIH vs. NSF Data Management Plans for a direct comparison of those two, and Data Sharing Policy for how a funder-level data policy like this one differs from a bilateral data sharing agreement governing one specific dataset transfer.
Frequently asked questions
Is the Tri-Agency Research Data Management Policy the same thing as a Data Management Plan?
No. The policy is the overarching framework with three components (institutional strategies, DMPs at application, and data deposit); a Data Management Plan is one specific document a researcher may be required to submit under the policy’s second component, for a specific funding opportunity.
Do all Tri-Agency grant applications currently require a DMP?
No. DMP requirements apply only to specific funding opportunities designated by each agency, and the list has expanded incrementally since spring 2022 rather than applying universally from day one. Always check the individual funding opportunity notice.
Is the data deposit requirement enforceable yet?
Not as a general Tri-Agency-wide requirement. As of 2026 the agencies are still finalizing the implementation approach, following a community engagement process and a published “What We Heard” report. A narrower, pre-existing CIHR requirement for bioinformatics and molecular coordinate data deposit does already apply independently.
What happens if an eligible institution never published an RDM strategy by the March 1, 2023 deadline?
The policy ties institutional eligibility to administer Tri-Agency funds to having a published strategy; institutions should confirm their strategy is live on their own website and was shared with the agencies as required, rather than treating this as a deadline that only mattered in 2023.
Does this policy apply to Canada Foundation for Innovation (CFI) grants?
No. CFI is a separate, non-Tri-Agency federal funder for research infrastructure and capital equipment, administered independently of CIHR, NSERC, and SSHRC, so the Tri-Agency RDM Policy does not itself govern CFI awards.
For the broader system this policy operates within, see Canada’s Tri-Agency Research Funding System. For the general lifecycle of research data this policy governs, see The Research Data Lifecycle and Data Stewardship and the Data Curator Role. For CASRAI’s full grants-management coverage, see the Grants Management pillar.
