NIH DMS Policy effective Jan 2023 + simpler standardized format effective May 2026

The National Institutes of Health Data Management and Sharing Policy took effect on January 25, 2023 as a term and condition of award, enforceable under the same mechanism as any other grant condition. As of October 2024, annual progress reports must document what data has actually been shared, what repository was used, and by what unique identifier (S-0067).

A simpler Data Management and Sharing Plan format scheduled to take effect for applications due on or after May 25, 2026 is intended to aid compliance monitoring. The format replaces narrative descriptions with three structured yes/no questions plus a data-type-and-repository table and a privacy attestation for human-subjects data.

The format is forward-looking, designed to make compliance review machine-actionable. It does not yet require independent verification that the data described in the plan exists, that it resides at the location the plan specified, that it has not been altered since deposit, or that access controls match the plan's stated terms. But the architectural direction is clear: structured, queryable plans demand structured, queryable infrastructure to back them.

This is the strongest single piece of evidence for C-0025's claim that the funder verification regime is shifting toward programmatic verification. The May 2026 effective date is loaded — institutions with current Tier 1 deposit workflows will face mandate-driven verification queries against architecture that cannot answer them by inspection.