NIH Implementation Update: Data Management and Sharing Plan Requirements

NOT-OD-26-100

Is the transition to the updated Data Management and Sharing (DMS) Plan format beginning in FY 2027.

The updated requirements apply to existing awards and applications subject to the NIH DMS Policy, regardless of when the competing application was submitted. Depending on the application or award stage, investigators may need to submit a DMS Plan in the updated format with an application, during Just-in-Time (JIT), or with an upcoming Research Performance Progress Report (RPPR).

In addition, beginning October 1, 2026, recipients will no longer be required to obtain NIH prior approval to modify an approved DMS Plan. Changes to approved plans and progress on data sharing activities must instead be reported through Section C.5.c. of the RPPR.

The UCSF library has updated its DMS plan page with the latest information from the NIH Notice.

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