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Who's Requiring Data Management Plans

Who Requires Data Management Plans?

In order to promote open access to research data, many funding agencies require that research data produced as part of a funded project be made publicly available and/or have instituted requirements for formal data management plans.

The Office of Management and Budget (OMB) Circular A-110 provides the federal administrative requirements for grants and agreements with institutions of higher education, hospitals and other non-profit organizations. In 1999 Circular A-110 was revised to provide public access under some circumstances to research data through the Freedom of Information Act (FOIA).

These data management and sharing policies have not been implemented uniformly, and there are variations in requirements from one agency to another, as well as within a single agency.  Some of the major funding agency data guidelines are summarized below.

National Science Foundation (NSF)

NSF policies can be found in the revised NSF Proposal & Award Policies Guide.  It advocates for researchers to "... share with other researchers, at no more than incremental cost and within a reasonable time, the data, samples, physical collections and other supporting materials created or gathered in the course of the work."

Proposals to the NSF are required to include a Data Management Plan of no more than two pages, which describes how the proposal will conform to NSF policy on the dissemination and sharing of research results.  According to AAG Chapter VI.D4 ( this may include:

  • The types of data, samples, physical collections, software, curriculum materials, and other materials to be produced in the course of the project;
  • The standards to be used for data and metadata format and content;
  • Policies for access and sharing including provisions for appropriate protection of privacy, confidentiality, security, intellectual property, or other rights or requirements;
  • Policies and provisions for re-use, re-distribution, and the production of derivatives;
  • Plans for archiving data, samples, and other research products, and for preservation of access to them.

Data management requirements and plans specific to the Directorate, Office, Division, Program, or other NSF unit, relevant to a proposal are available at:

National Institute of Health (NIH)

NIH Data Sharing Policy  states that:

"All investigator-initiated applications with direct costs greater than $500,000 in any single year will be expected to address data sharing in their application...

In some cases, Program Announcements (PA) may request data sharing plans for applications that are less than $500,000 direct costs in any single year...

The rights and privacy of people who participate in NIH-sponsored research must be protected at all times. Thus, data intended for broader use should be free of identifiers that would permit linkages to individual research participants and variables that could lead to deductive disclosure of the identity of individual subjects. When data sharing is limited, applicants should explain such limitations in their data sharing plans."

NIH data sharing guidance can be found in Key Elements to Consider in Preparing a Data Sharing Plan  < >


Other Federal Funding Agencies that require Data Management Plans include:

Centers for Disease Control and Prevention

Department of Energy

Department of Defense

Environmental Protection Agency

Institute of Museum and Library Services


National Endowment for the Humanities

National Institute of Justice

National Institute of Standards and Technology

United States Department of Agriculture

United State Department of Education


Many academic journals have also begun to require data sharing as part of the submission process.  For a partial list of journals with data sharing mandates for their published articles, see the following:

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