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NIH: Implementation Update: NIH Data Management and Sharing Plan Requirements


ORPA-L: Thu, 13 Aug 2026

Dear University of Rochester Research Community,

As we previously shared, the NIH has released a new 2026 Pilot Data Management and Sharing Plan format with the intention of reducing applicant burden and simplifying required elements.

The NIH has provided additional guidance on the transition including updating previously approved DMS plans on NOT-OD-26-100.

Starting October 1, 2026, the NIH will require all existing awards and applications subject to the NIH DMS Policy to transition to the updated DMS Plan format. This requirement applies regardless of when the competing application was submitted.

Here are the requirements for transitioning to the updated format:

  • Applied on or after May 25, 2026: Send the DMS plan with your main application package.

  • Applied before May 25, 2026 (not awarded yet): Send the DMS plan during the Just-in-Time (JIT) stage.

  • Active awards subject to 2023 DMS policy: Switch to the new plan at your next yearly progress report (RPPR). Here is a list of NIH activity codes subject to the DMS policy.

  • Already under the 2023 Policy: Switch to the new plan at your next yearly report (RPPR). If you already sent your 2026 yearly report, switch during your 2027 yearly report.

  • Under the old 2003 policy (started before Jan 2023) and make data: Switch to the new plan during your 2027 yearly report (RPPR).

You can use the updated NIH DMS Plan template from the University of Rochester Libraries' Data Services team. Please contact the UR Libraries Data Services team if you have any questions about the template or you would like help prepariing your data and management sharing plan.

Investigators and research teams preparing NIH applications should review NIH's 2026 Pilot DMS Plan format and coordinate with their ORPA Research Administrator and the Libraries' Data Services team as needed. You can contact ORISE for help with data integrity and ethics questions.

Sincerely,

The Office of Research and Project Administration (ORPA)
The University of Rochester Libraries
The Office of Research, Integrity, Stewardship and Ethics (ORISE)