March 12, 2026
The NIH recently released Notice NOT-OD-26-046, which updates the required elements of the NIH Data Management and Sharing (DMS) Plan.
This notice introduces a revised and simplified format for DMS Plans intended to clarify expectations and reduce unnecessary detail in submissions. NIH evaluated more than 1,100 DMS Plans since the policy took effect in 2023 and found that many included extraneous information or exceeded recommended length. The updated format is designed to streamline the review and compliance process while maintaining alignment with FAIR (Findable, Accessible, Interoperable, and Reusable) data principles.
Key Points
- The notice updates the required elements and format of the NIH DMS Plan.
- Applicants will respond to structured questions regarding data sharing, timelines, and any limitations.
- A brief description of anticipated data types and repositories will also be required.
- If data sharing will be limited, investigators must provide a justification (up to 300 words) explaining ethical, legal, or technical constraints.
- Additional questions address privacy protections for human participant data and, where applicable, large-scale genomic data sharing expectations.
Effective Date
The new DMS Plan format will be required for applications with due dates on or after May 25, 2026.
Investigators planning NIH submissions after this date should familiarize themselves with the updated requirements and begin incorporating them into proposal preparations.
An updated DMS Plan Format page will be made available upon receipt of OMB clearance, but a draft can be viewed here: Data Management and Sharing Plan Format Page.
Resources
The WCM Library provides comprehensive resources and guidance on the NIH Data Management and Sharing Policy here. The page will be updated as the implementation date approaches and as NIH releases additional information.