Canada’s Tri-Agency Research Data Management Policy requires postsecondary institutions and research hospitals that administer funds from CIHR, NSERC and SSHRC to publish an institutional research data management (RDM) strategy, to attach data management plans (DMPs) to specified grant applications, and to prepare for a phased-in data deposit requirement. Launched in March 2021, it is Canada’s first cross-agency RDM mandate.
The Tri-Agency Research Data Management Policy is a joint funder mandate issued by 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) that sets out institutional and researcher obligations for managing publicly funded research data.
- What is the Tri-Agency Research Data Management Policy?
- What are the policy’s three pillars?
- How do CIHR, NSERC and SSHRC requirements differ?
- How does it compare with UKRI, NSF and Horizon Europe?
- What must institutions do to comply?
- Frequently asked questions
- Implications and outlook
What is the Tri-Agency Research Data Management Policy?
The policy was announced jointly by CIHR, NSERC and SSHRC on 18 March 2021, following consultation on a 2018 draft. Its stated objective is to support Canadian research excellence by promoting sound RDM and data stewardship practices across the postsecondary and hospital-based research sectors that receive federal funding.
Unlike a single-agency requirement, it applies uniformly across all three funding councils, making it the first unified Canadian federal RDM mandate. The agencies chose incremental implementation rather than a single compliance date, phasing obligations in over several years to give institutions and researchers time to build capacity.
What are the policy’s three pillars?
The policy rests on three distinct requirements, each with its own timeline and audience. Together they move Canadian-funded research toward the FAIR principles — Findable, Accessible, Interoperable and Reusable — as defined by SSHRC’s guidance for applicants.
- Institutional strategies: eligible institutions had to develop and publicly post an RDM strategy, then formally notify the agencies of completion by 1 March 2023.
- Data management plans (DMPs): researchers applying to an initial, agency-specified set of funding opportunities must submit a DMP describing how project data will be collected, documented, stored and shared.
- Data deposit: grant recipients must eventually deposit digital research data, metadata and code that directly support published conclusions into a recognised repository; the agencies are phasing this in based on the sector’s readiness rather than enforcing it on a fixed date.
The policy also embeds Indigenous data governance explicitly: institutional strategies must recognise the data sovereignty of First Nations, Métis and Inuit communities, with SSHRC pointing applicants to the First Nations OCAP® principles and the CARE Principles for Indigenous Data Governance.
How do CIHR, NSERC and SSHRC requirements differ?
All three agencies operate under one shared policy text, but they do not require DMPs on the same grants. Each agency independently designates which of its own funding opportunities carry a mandatory DMP, published on the shared Science.gc.ca research data management page rather than in a single combined list.
- CIHR has applied DMP requirements to specific health-research competitions, reflecting added sensitivity around personal health information and research ethics board obligations.
- NSERC has targeted DMPs at select discovery and strategic programmes in the natural sciences and engineering.
- SSHRC requires DMPs for designated social sciences and humanities opportunities and publishes the most detailed applicant-facing guidance, including a section-by-section drafting template covering data collection, documentation, storage, sharing, responsibilities and legal compliance.
Institutions are expected to track which of their researchers’ target competitions are in scope, since the DMP obligation is opportunity-specific rather than blanket across every Tri-Agency grant.
How does it compare with UKRI, NSF and Horizon Europe?
Canada’s approach sits between the narrower, opportunity-specific model used historically in the UK and the near-universal mandates now standard in the United States and the European Union. The table below sets out the structural differences institutions moving between these funding systems need to track.
| Framework | Steward | DMP scope | Data deposit approach |
|---|---|---|---|
| Tri-Agency RDM Policy | CIHR / NSERC / SSHRC (Canada) | Required only for agency-specified funding opportunities | Phased in based on sector readiness; not yet universal |
| UKRI Common Principles on Data Policy | UK Research and Innovation, across its constituent councils | Expected for research councils such as MRC, NERC and EPSRC, per council-specific policy | Data expected to be made available and accessible at the point of publication |
| NSF Data Management Plan requirement | US National Science Foundation | A DMP has been mandatory for every NSF proposal, across all directorates, since 2011 | Sharing plan required; no single universal deposit mandate across directorates |
| Horizon Europe Model Grant Agreement | European Commission | DMP mandatory for participating projects, typically due by month 6 | Open access to research data “as open as possible, as closed as necessary” |
The practical distinction for institutions with international collaborators is scope: NSF and Horizon Europe treat the DMP as a near-default project requirement, while the Tri-Agency policy and UKRI’s council-by-council approach both still gate the DMP requirement to specific competitions rather than every grant.
What must institutions do to comply?
Institutional research offices carry most of the compliance burden, since the policy places the strategy obligation on the institution rather than the individual researcher. Compliance work typically covers four areas.
- Publish and maintain an institutional RDM strategy on a publicly accessible page, with a named contact for enquiries.
- Build institutional capacity: training, data storage infrastructure, and support for researchers drafting DMPs, often via the DMP Assistant tool operated by the Digital Research Alliance of Canada.
- Track which specific CIHR, NSERC and SSHRC funding opportunities carry a mandatory DMP so applicants are not caught unprepared at submission.
- Prepare repository infrastructure and researcher guidance ahead of the phased data deposit requirement, including institutional or national options such as the Federated Research Data Repository.
Institutions that have not yet published a strategy remain out of step with a requirement the agencies set for 1 March 2023, which is a governance gap research offices should treat as a priority remediation item.
Frequently asked questions
When did institutions have to publish their Tri-Agency RDM strategy?
Institutions eligible to administer CIHR, NSERC or SSHRC funds were required to develop, publicly post and notify the agencies of their institutional RDM strategy by 1 March 2023. This is the only fixed compliance date within the otherwise incrementally phased policy.
Does every Tri-Agency grant require a data management plan?
No. Each agency designates its own initial set of funding opportunities that require a DMP at application; the requirement is not blanket across all CIHR, NSERC or SSHRC competitions, so applicants must check the specific programme guidelines before submitting.
What do institutions need to know about FAIR data under the policy?
SSHRC’s applicant guidance directs researchers to manage data, where ethically and legally possible, according to the FAIR principles — Findable, Accessible, Interoperable and Reusable — while explicitly noting that grant recipients are not required to openly share data if legal, ethical or Indigenous data sovereignty obligations prevent it.
How does the policy treat Indigenous research data?
Institutional strategies must recognise Indigenous data sovereignty, and SSHRC points applicants to the First Nations OCAP® principles and the CARE Principles for Indigenous Data Governance when data involves First Nations, Métis or Inuit communities and their collections.
Implications and outlook
For institutions, the Tri-Agency policy converts research data management from a discretionary practice into a governance obligation with a named public strategy, a training mandate and eventual deposit infrastructure requirements. Research offices that treat the 2023 strategy deadline as complete, rather than as a living document, risk falling behind as the agencies phase in data deposit.
For researchers collaborating internationally, the comparison with UKRI, NSF and Horizon Europe matters operationally: a DMP built for an NSF-funded partner project, where a plan is mandatory for every proposal, will not automatically satisfy a Tri-Agency opportunity where the DMP requirement is competition-specific — and vice versa. Institutions running multi-funder projects should map DMP and deposit obligations per funder rather than assuming one plan transfers across systems.
As Canada’s data deposit requirement moves from phased design toward implementation, institutions with mature repository infrastructure and clear researcher guidance will be better positioned than those still relying solely on their 2023 strategy document. This sits within the wider discipline of research administration, where funder RDM mandates increasingly intersect with data governance, ethics review and open-access policy.