The Horizon Europe Data Management Plan (DMP) template is a seven-section document — data summary, FAIR data, other research outputs, resource allocation, security, ethics, and other issues — that the European Commission recommends beneficiaries use to show how project data will be made Findable, Accessible, Interoperable and Reusable. It is due as a project deliverable within the first six months of a grant and must be kept current for the project’s duration.
A Data Management Plan is a living document describing how research data and other outputs are generated, documented, secured, and shared, both during and after a funded project. Under Horizon Europe, the plan is not a formality: it is the mechanism through which the Commission’s FAIR data mandate under the Horizon Europe Programme Guide (Open Science, Article 17) is operationalised at project level.
- What the Horizon Europe DMP template covers
- Section by section: what each part requires
- When the DMP is due, and whether the template is mandatory
- Common questions about the Horizon Europe DMP
- What this means for research administrators
What the Horizon Europe DMP template covers
The Commission’s recommended template, published on the Funding & Tenders Portal, structures the plan around seven headline sections. Each section exists to answer a specific compliance question the Commission needs resolved before, during, and after data generation.
The data summary section opens the document. It requires beneficiaries to state whether data will be newly generated, reused from existing sources, or both; to describe expected data types, formats, and volumes; to explain how the data relates to the project’s objectives; and to identify who outside the consortium might find the data useful. If reuse of existing data was considered and rejected, that decision must be justified in writing.
Section by section: what each part requires
The template’s largest section — FAIR data — is split into four sub-parts that map directly onto the FAIR acronym. This is where most of the compliance burden, and most drafting errors, sit.
Making data findable
Beneficiaries must state whether data and metadata will receive a persistent identifier such as a DOI, which metadata standard will be used (for example Dublin Core or a discipline-specific schema), and whether search keywords will be added so the dataset can be indexed by data catalogues and harvested by aggregators such as OpenAIRE.
Making data accessible
This sub-section requires naming the trusted repository, stating whether data will be openly accessible by default, and — where access is restricted — providing a documented justification tied to legitimate interests, GDPR, security, or intellectual property constraints. Metadata should remain openly accessible under a CC0 licence even when the underlying dataset is closed.
Making data interoperable
Here the plan must name the vocabularies, ontologies, or methodologies used so the data can be combined with other datasets and read by non-project tools without manual reformatting.
Increasing data reuse
The final FAIR sub-section covers licensing terms (CC BY or CC0 by default, following the “as open as possible, as closed as necessary” principle), data provenance documentation, and the quality-assurance processes applied before deposit.
Beyond FAIR data, three further sections complete the template:
| Section | Core requirement | Primarily maps to |
|---|---|---|
| 3. Other research outputs | Software, models, workflows, protocols and physical samples managed under the same FAIR logic as data | Findable, Reusable |
| 4. Allocation of resources | Costs of making data FAIR, named responsibility for data management, long-term preservation funding | Accessible |
| 5. Data security | Secure storage, backup, recovery provisions, and secure transfer of sensitive data | Accessible, Reusable |
| 6. Ethical aspects | Handling of personal or sensitive data in line with GDPR and the project’s ethics review | Accessible |
| 7. Other issues | Any procedure or standard not captured elsewhere (e.g. national/funder-specific rules) | All four FAIR pillars |
Beneficiaries should also confirm that deposited datasets carry the minimum metadata fields the Commission expects: author(s), a description or abstract, the deposit date, the licence, embargo terms if any, and the grant project name, acronym, and number.
When the DMP is due, and whether the template is mandatory
The European Commission states plainly on the template’s own download page that “the template is recommended but not mandatory” — beneficiaries may use their own format provided it still satisfies the underlying research-data-management obligations in the Grant Agreement.
The timeline itself is fixed regardless of format:
- Proposal stage: a short, typically one-page DMP outline is required as part of the proposal; a full DMP is not expected yet, except where a Work Programme calls for one at signature (for example, public-emergency topics).
- Month 6: the full initial DMP must be submitted as a formal project deliverable.
- During the project: the DMP is a living document; for projects running longer than 12 months, at least one updated version must be submitted.
- Project end: a final DMP records how data were actually managed, preserved, and shared.
Trusted repositories for deposit are those holding certifications such as CoreTrustSeal, Nestor Seal DIN 31644, or ISO 16363, or domain-specific repositories widely endorsed by the relevant research community. A 2024 metadata-readiness review commissioned by the European Research Council (Lazzeri, 2024) found that only a handful of repositories — including Zenodo, DANS, and HAL — met the Commission’s “Essential” metadata-readiness level outright, with several others still retrofitting mandatory fields. This is a practical planning risk: naming a repository in Section 2.2 that later turns out metadata-incomplete forces a DMP revision mid-project.
Common questions about the Horizon Europe DMP
Is the Horizon Europe DMP template mandatory?
The template itself is optional; beneficiaries can use another format. What is mandatory, under the Grant Agreement, is establishing a DMP by month 6, keeping it updated, and depositing data in a trusted repository consistent with FAIR principles.
When is the Data Management Plan due in Horizon Europe?
A full initial DMP is due by month 6 of the project as a formal deliverable. A brief DMP-like outline is required earlier, at proposal stage, and the plan must be updated again for projects longer than 12 months.
What do the FAIR data principles require in a Horizon Europe DMP?
FAIR requires data to be Findable via persistent identifiers and rich metadata, Accessible through a trusted repository with a clear access policy, Interoperable using recognised standards or vocabularies, and Reusable under a documented licence with provenance and quality information.
Does the DMP need to be updated after submission?
Yes. The Commission treats the DMP as a living document. Any material change — a new dataset, a changed repository, an altered access decision — must be reflected in an updated version submitted as a subsequent deliverable.
What this means for research administrators
For UK institutions, the compliance picture has a domestic wrinkle worth flagging: the UK re-associated to Horizon Europe from 1 January 2024, and UK-based participants funded via the UKRI Horizon Europe Guarantee are still contractually bound by the same DMP and FAIR data obligations as any other beneficiary — the Guarantee changes the funding route, not the data-management requirements. Research offices supporting UKRI-guaranteed grants should apply the Horizon Europe template rather than a UKRI-native one.
Institutions preparing their first Horizon Europe DMP can reduce drafting time using ARGOS, OpenAIRE’s free tool built around Horizon Europe’s own template structure, which prompts for each of the seven sections with contextual guidance. Because Section 4 requires naming a responsible individual and Section 5 requires named security measures, research administration teams should treat DMP drafting as a cross-functional task involving the data steward, the ethics lead, and the finance officer who costs the resource-allocation section — not a document a single researcher completes alone. Institutions with broader research administration workflows should build DMP review into the same grant-management checkpoints used for ethics and finance sign-off, rather than treating it as a stand-alone open-science task.
The direction of travel across EU funding is toward more structured, field-level FAIR reporting rather than narrative compliance statements — institutions that build DMP drafting into standard grant-lifecycle checkpoints now will spend less time on ad hoc revisions as reporting expectations tighten.
