Funder mandates are shifting from self-reported plans to programmatic verification

Research-funder compliance regimes are converging from "did you write a data management plan?" toward "did you actually deliver on it, and can you prove it?" The shift is documented across multiple major funders simultaneously and is not specific to any single agency.

• The NIH Data Management and Sharing Policy took effect January 25, 2023 as a term and condition of award; annual progress reports must document what data has been shared, where, and by what unique identifier (S-0067).
• The May 25, 2026 simpler Data Management and Sharing Plan format replaces narrative descriptions with structured yes/no questions designed to make compliance review machine-actionable (S-0067).
• The Gates Foundation contracted OA.Works in January 2025 to perform programmatic compliance review at funder scale (S-0068).
• Horizon Europe makes FAIR data mandatory with no opt-out, enforceable through Grant Agreement Article 17 which ties compliance to payments (S-0069).
• The Wellcome Trust may decline to accept new applications from non-compliant researchers and may suspend funding to the institution in extreme cases (S-0070).
• The OSTP Nelson Memo (August 2022) directed all federal agencies to require immediate open access to federally funded research and data covering ~$90B in annual federal research funding (S-0072).

Most institutions cannot answer the second question — "did you do it, and can you prove it?" — by inspection on Tier 0/1/2 architecture. The shift from a regime that cannot programmatically detect non-compliance to one that can is the converging condition under which the Section 5 latent liability surfaces.