Funder requirements

Many external agencies that fund research require sharing articles and/or data that results from research they fund.

Public access to publications

U.S. federal bodies and some private organizations that fund research have policies that require grantees to share publications and/or data resulting from the research they fund.  

U of M researchers are responsible for knowing their relevant agency’s requirements and complying with them. 

Federal funders

The largest U.S. federal grant-funding agencies have had public access policies outlining requirements for sharing publications and data resulting from research conducted using federal grant funding for many years. An August 2022 memorandum from the White House Office of Science and Technology Policy directed all federal bodies to update existing or draft new policies for immediate sharing of publications and data. 

Federal policies rely on depositing articles into the specified repository. They do not require researchers to pay a fee (article processing charge, or APC) to publish their article open access, although these costs can be written into grant proposals.

Existing policies remain in effect, and new policies are required to be in place by January 1, 2026. This space will be updated as new policies are put in place. SPARC has created a site for browsing publication sharing requirements by federal agency.

Agency Directorate Effective date Sharing requirement Sharing venue
Consumer Product Safety Commission December 31, 2025 Yes PubMed Central
DOD n/a 2015 Yes Defense Technical Information Center PubDefense
DOE n/a October 2024 Yes OSTI Pages (video demonstration)
DoEd IES 2012 Updated plan effective FY2025 for new grants Yes ERIC
DOT n/a 2015 Yes National Transportation Library
HHS Centers for Medicare & Medicaid Services December 31, 2025 Yes
EPA n/a January 2, 2025 Yes PubMed Central
HHS AHRQ December 18, 2024 Yes PubMed Central
HHS ACF December 31, 2025 Yes PubMed Central
HHS ASPR 2015 Yes PubMed Central
HHS ACL Updated policy goes into effect December 31, 2025 Yes PubMed Central
HHS CDC April 8, 2024 Yes PubMed Central and CDC Stacks
HHS FDA August 15, 2025 Yes
HHS NIH July 2025 Yes PubMed Central
ODNI n/a 2017 Yes Defense Technical Information Center PubDefense
Institute of Museum and Library Services (IMLS) n/a October 1, 2025 Yes To the "IMLS designated repository" [TBD]
National Endowment for the Humanities n/a October 1, 2025 Yes See guidance
NASA n/a 2016 Yes PubSpace
NASA NASA Science Mission Directorate 2023 Yes PubSpace
NIST n/a 2015 Yes PubMed Central
NOAA n/a 2016 Yes PubMed Central
NSF n/a January 22, 2026 (PAPPG Supplement 2) Yes NSF Public Access Repository
Smithsonian n/a January 1, 2025 Yes Smithsonian Research Online
USDA n/a Updated 2022 Yes PubAg
USDA NIFA 2022 Yes PubAg
USAID n/a 2016 Yes Development Experience Clearinghouse
USGS n/a 2016 Yes Publications Warehouse
VA n/a 2015 Yes PubMed Central
Commerce Census Bureau December 31, 2025 Yes Not announced yet

Additional updates to federal policies are expected in 2027, including requirements for using persistent identifiers such as ORCID.

Other funding agencies

The public access requirements of selected foundations and other funders are summarized below.

Agency Effective date Embargo allowed Sharing venue or other requirements
American Heart Association n.d. 12 months PubMed Central
Children's Tumor Foundation 2015 n/a Drug Discovery Initiative Registered Reports
Ford Foundation 2015 n/a Creative Commons License required
Bill & Melinda Gates Foundation (BMGF) 2015, updated 2025 No Must post a preprint to a recognized preprint server under a Creative Commons Attribution license.
Gordon & Betty Moore Foundation 2017 n/a Creative Commons License required
Hewlett Foundation 2026 n/a Creative Commons License required
Howard Hughes Medical Institute 2007 n/a Must post a preprint to a recognized preprint server under a Creative Commons Attribution license.
Laura and John Arnold Foundation 2017 n/a Preregistration with the Center for Open Science
MacArthur Foundation 2008 n/a Creative Commons License required
The Michael J. Fox Foundation for Parkinson's Research 2020 n/a Articles must be posted in an open access preprint repository and published open access
Simmons Foundation 2017 n/a Encourages preprints at arXiv or, bioRxiv, or publishing under open access licenses
Wellcome Trust 2017 No embargo allowed Creative Commons License required PubMed Central or EuropePMC

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Public access to data

The 2013 Public Access to Federally Funded Research memo from the White House Office of Science and Technology Policy (OSTP) directed most grant-funding agencies to develop policy requirements public access to resulting articles and data. For more detailed information, including timelines for sharing, select an agency.

The Libraries can help you write and implement your data management plan to best meet funder requirements. You can also use our Data Repository for the University of Minnesota (DRUM) to meet federal funder requirements for data sharing.

Federal funders' responses to the OSTP memo:

Agency Directorate guidance Effective date DMP required Sharing venue
Department of Defense (DOD) n/a End of 2016 Yes “Established, publicly accessible institutional repositories”
Department of Energy (DoE) n/a June 2023 Yes "including the data as supplementary information to the published article, or through other means. " Additional guidance
Department of Education (DoED) IES Sept. 30, 2024 Yes “IES does not endorse the use of a particular repository or standards for documentation"
Department of Transportation (DOT) n/a Dec. 31, 2015 Yes An appropriate data repository, and inventoried in the DoT Public Data Listing
Health and Human Services (HHS) Agency for Healthcare Research and Quality (AHRQ) Dec. 2024 Yes Encourages the use of public repositories or government owned repositories.
Health and Human Services (HHS) Assistant Secretary for Preparedness and Response (ASPR) Oct. 2015 Yes Publicly accessible databases
Health and Human Services (HHS) Centers for Disease Control and Prevention (CDC) Oct. 1, 2024 Yes Encourages the use of public repositories or government owned repositories.
Health and Human Services (HHS) Food and Drug Administration(FDA) Aug. 15, 2025 Yes Publicly accessible, discipline specific repositories
Health and Human Services (HHS) National Institutes of Health (NIH) Revised plan implemented January 25, 2023 Yes Existing, publicly accessible repositories
National Aeronautics and Space Administration NASA Science Mission Directorate Feb. 2023 Yes Existing data repositories
NIST n/a Oct. 2015 Yes Publicly accessible databases
NOAA n/a 2015 Yes Existing NOAA data centers, other data repositories, interagency Research Data Commons
National Science Foundation (NSF) NSF Guide December 8, 2025 (PAPPG Supplement 2) Yes “an appropriate repository”
Smithsonian n/a Jan. 1, 2025 Yes Deposit to a permanent database/repository; an open Smithsonian database/repository; a U.S. government funder–designated database/repository; a publisher open database or repository; or Smithsonian Research Online
United States Department of Agriculture (USDA) n/a January 2016 Yes USDA registry of datasets, other repository options
United States Geological Society (USGS) USGS Guide January 2016 Yes USGS Data Portal
Veterans Affairs (VA) n/a December 31, 2015 Yes Partner with HHS, NIH, FDA, and DoD on “effective mechanisms"

* Data must be available for at least 10 years

Department of Defense

DOD's response to the 2022 OSTP Public Access Memo

DOD's Response to the 2013 OSTP Public Access Memo

The 2016 policy is still in effect.

DOD Principles and Operational Parameters of the DoD Scientific and Technical Information Program
"It is DoD policy under DoD Directive 3200.12 to establish and maintain a coordinated and comprehensive program to document the results and outcome of DoD-sponsored and/or performed research and engineering (R&E) and studies efforts and provide access to those efforts in an effective manner consistent with the DoD mission."

Department of Transportation

DOT's Response to the 2013 OSTP Public Access Memo

"In the DMP, researchers will propose their strategy(ies) to deposit Digital Data Sets resulting from DOT-funded Scientific Research in a repository that enables and allows for Public Access and sharing.... All Digital Data Sets subject to this plan will be inventoried in the DOT Public Data Listing, whether performed by intramural or extramural researchers."

Centers for Disease Control and Prevention

CDC's Response to the 2022 OSTP Public Access Memo

CDC Policy on Sharing Data

"Public health data collected or generated with federal funds must be made readily available for the public to access (e.g. in a non-proprietary format and with a data dictionary) and archived for a prespecified amount of time, unless there are strong reasons not to do so. These tasks are the responsibility of the awardees, not CDC."

Department of Education

Department of Education's 2022 OSTP Public Access Memo

Institute of Education Sciences (IES) implementation guide

Frequently asked questions about providing public access to data

National Institutes of Health

NIH's Response to the 2013 OSTP Public Access Memo

NIH Data Sharing Policy (updated for 2023)

For grants over $500,000, a data sharing plan must be included in the grant application and incorporated as a term and condition of the award. Final Research Data "should be made as widely and freely available as possible while safeguarding the privacy of participants, and protecting confidential and proprietary data".

National Institute of Standards and Technology

NIST Response to the 2013 OSTP Public Access Memo

NIST Guidelines, Information Quality Standards, and Administration Mechanism

Per NIST, grantees are not subject to the data sharing guidelines listed in the "NIST Guidelines..." document unless NIST directly distributes the data.

United States Department of Agriculture

USDA's Response to the 2022 OSTP Public Access Memo

USDA's Response to the 2013 OSTP Public Access Memo

The 2016 Policy is still in effect.

USDA National Institute of Food and Agriculture (NIFA)
The NIFA requires a DMP will all research. They state: "Increased access to scientific research results (e.g., scholarly publications, digital data sets) from NIFA funded projects is critical to achieving NIFA’s vision to catalyze transformative discoveries, education, and engagement to address agricultural challenges. Therefore, an appropriate data management plan (DMP) should be a core component of research planning for proposals submitted to NIFA."

US Department of Veterans Affairs

VA Policy and Implementation Plan (July 2015) in response to the 2013 OSTP Public Access Memo

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