Changes to Federal Data Management and Sharing Plans

Data management and sharing policies are seeing some changes in 2026 and the CDVS Data Management team is here to help you!

NIH

On February 25, 2026, the NIH released NOT-OD-26-046 announcing a new abbreviated Data Management and Sharing Plan (DMSP) format. The updated format is intended to reduce applicant burden and support more consistent compliance monitoring by changing narrative responses primarily to yes/no answers. Beginning May 25, 2026, applicants will be required to use this new, shorter, standardized format.

The revised DMSP focuses on a concise set of required elements:

Three yes/no questions addressing whether the scientific data will be shared and associated timelines/retention information.

A brief explanation (up to 300 words) if data sharing is limited for ethical, legal, or technical reasons.

A yes/no question on protections for human participant data, including the use of access controls, consistent with NOT-OD-22-213 (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-22-213.html).

A short table (100 words maximum) listing anticipated data types and the repositories (or example repositories) where data may be shared.

Two additional yes/no items for projects subject to the NIH Genomic Data Sharing (GDS) Policy.

NSF

NSF has also released their revised Public Access 2.0 Policy with new expectations for data management and sharing plans (PAPPG 24-1, Supplement 2) that went into effect in January 2026. The NSF policy revisions in relation to data sharing focus on the following:

All data supporting NSF funded manuscripts will be expected to be shared at the time of manuscript publication

Exceptions to data sharing must be specifically requested

The DMSP is a record of intended data sharing and becomes a terms and condition of the award

The new DMSP will be a structured survey in Research.gov with questions focusing upon Data and Research Products, Access Policies and Limitations, Data Standards and Metadata, Public Archiving in Repositories, Retention Times, Data Sources, and Accountability/Responsibility. (Note: This survey tool in Research.gov is not yet live, it is supposed to be launched on April 27, 2026 and may be subject to change)

Tips

While these new formats may require less effort to complete, the primary intention – ensuring maximum sharing of publicly funded data – remains the same. Here are just a few things you can do to be prepared to share your data:

Identify an appropriate data repository/ies as early as possible because they have differing levels of complexity around submission requirements, data preparation and format expectations (including de-identification), and long-term storage costs that affect your budget and publishing data on time. If you are trying to identify a repository, one option might be the Duke Research Data Repository.

Accurately budget for the costs of data management including preparation for archiving data in repositories

When sharing data from human participants, make sure your informed consent allows for data sharing explicitly (see the DUHS IRB data sharing example language)

Train graduate students and other project personnel on procudures for curating and preparing for data sharing early in the project.

If you need help navigating these new funder policies, identifying appropriate data sharing options, or developing data management practices for your team, contact us at datamanagement@duke.edu.