Quick Reference - What You Need to Know
Bottom Line: By end of 2025, ALL federally funded research must make articles and data publicly available immediately upon journal publication - no waiting periods allowed. Data management plans are required before getting funding and sharing costs must be included in budgets.
What Changed and Why
The Old Rules (2013):
- Only applied to agencies spending $100+ million on research
- Allowed 12-month delays before making articles public
- Limited data sharing requirements
The New Rules (2022 + 2025):
- ALL federal agencies with any research spending
- NO delays - immediate public access required
- Expanded scope: additional types of peer-reviewed scholarship and data must be shared
- New data management requirements, including pre-specification of a repository for sharing
Why the change? Two key policy updates drive these requirements:
- 2022 White House memorandum on public access to federally funded research
- 2025 "Restoring Gold Standard Science" executive order
Find Your Agency Requirements
Last Updated: 2026-02-18
Federal agencies are responsible for developing policies and procedures to implement the directives of the White House Office of Science and Technology Policy. The table below provides an overview of key implementation strategies by agency:
| Agency | Effective | Article Requirements | Data Sharing Requirements |
|---|---|---|---|
| NIH | Publications: July 2025 (new and existing awards) Data: January 2023 (new awards only) | Submit to PubMed Central (via NIH Manuscript Submission (NIHMS) system) upon acceptance | Data underlying articles: Available by publication date All other data: Available by end of award |
| NASA | December 2022 (new awards only) | Submit to PubSpace (via STI Contact Form) by publication date | Data underlying articles: Available by publication date All other data: Available by end of award |
| DOE | Publications: October 1, 2024 (new and existing awards) Data: October 1, 2025 (new awards only) | Submit to DOE PAGES (via OSTI E-Link) upon acceptance | Data underlying articles: Available by publication date All other data: Available in a timely manner |
| NSF | Publications: January 22, 2026 (new awards only) Data: December 8, 2025 (new awards only) | Submit to NSF Public Access Repository (Research.gov) by publication date | Data underlying articles: Available by publication date All other data: Available in a timely manner |
| DOD | TBD | Submit to Defense Technical Information Center (via DTIC Submit) – timeline forthcoming | TBD |
| USDA | TBD | Submit to National Agricultural Library (via PubAg Manuscript Submission) – timeline forthcoming | TBD |
For a comprehensive comparison across agencies, see the SPARC Publication and Data Sharing Requirements resource.
Need help navigating federal research sharing requirements? Each agency has its own systems, deadlines, and procedures for implementing the new public access mandates. Whether you're submitting to PubMed Central, preparing a data management plan, or figuring out compliance requirements, understanding your specific agency's approach is crucial for successful grant management and avoiding funding issues.
Learn more about agency-specific guidance to help Ohio State researchers meet federal sharing requirements and maintain compliance throughout the research lifecycle.
What You Need to Do
Before You Apply for Funding
- Write your data management plan: Look for updated templates and requirements, like use of a public repository for sharing
- Budget properly: Include costs for publication fees, data deposit fees, and personnel
- Identify repositories: Decide where you'll share your data
- Review agency specifics: Each agency has different systems and requirements
When You Publish
- Read your author agreement: Understand whether the publisher allows for immediate public access and negotiate your rights if needed
- Submit immediately: Use your agency's manuscript submission system and start the process early to avoid delays. Ensure your article becomes publicly available immediately upon the official publication date
- Share your data: Upload underlying data to the public repository you outlined in your data management plan
- Document access: Include data access instructions in your publication
- Report compliance: Be prepared to include progress in your required reports to the agency
Important Notes
- Includes more than articles: Sharing requirements vary by sponsor and may include book chapters, editorials, and conference proceedings
- Compliance matters: Non-compliance can affect future funding decisions
- Requirements don’t expire: You are responsible for public access even after the award term ends
Ohio State Resources
University Libraries and the Enterprise for Research, Innovation, and Knowledge co-sponsored a working group to research and develop resources for Ohio State investigators who are subject to the updated public access policies. This initiative has produced the following resources for investigators and their support teams:
Getting Help:
- Informational sessions held throughout 2025-26 academic year
- Working group resources developed specifically for Ohio State investigators
Publishing Resources
Data Management and Sharing Resources
NIH
Additional Information
- For questions related to public access compliance, please contact Sponsored Programs at OSP-Pub-Access-Compliance@osu.edu
- For questions related to data management and sharing, please contact University Libraries at datamanagement@osu.edu