On May 25, 2026, NIH grant applicants were required to use a new abbreviated Data Management and Sharing (DMS) Plan format described in NOT-OD-26-046. The updated format replaces most narrative responses with structured yes/no questions to reduce administrative burden and support more consistent compliance monitoring.
On July 29, 2026, NIH released additional implementation guidance in NOT-OD-26-100. The new guidance expands the use of the updated format beyond new applicants and establishes a pathway for pending and active awards to transition to the structured DMS plan format.
What Researchers Need to Know
Beginning in FY 2027, NIH expects all DMS plans to align with the new format, regardless of when the original competing application was submitted.
- Competing applications submitted on or after May 25, 2026 should use the updated DMS Plan format at the time of submission.
- Competing applications submitted before May 25, 2026 that have not yet been awarded must provide a revised DMS plan in the updated format during the Just-in-Time (JIT) process.
- Applications submitted before May 25, 2026 that have already been awarded should transition to the updated format in their next Research Performance Progress Report (RPPR).
- Active NIH awards should provide a plan in the updated format with their next RPPR.
- Prior approval is no longer required to modify an approved DMS Plan. NIH plans to retire the DMS Prior Approval Request option in the eRA Commons Prior Approval Module.
- Beginning October 1, 2026, changes to an approved plan, such as change in a repository, sharing timeline, or scientific direction, should be reported in Section C.5.c. of the RPPR.
Why this matters: Even if your application was submitted before May 25, 2026, you may still need to update your approved Data Management and Sharing Plan to the new NIH short format at Just-in-Time or during your next RPPR.
Researchers should review NIH’s Data Management and Sharing Plan Format Page for the updated template, implementation details, and additional guidance.
If you have any questions, please contact medical-librarian@duke.edu
To meet with a Duke University Libraries data management consultant, email datamanagement@duke.edu. Consultants can assist with writing your DMS plan, informed consent language related to data sharing, curation practices, and end-user licensing or data use agreements.