Meeting New Federal Agency Public Access Requirements For Research Publications and Data
In response to a 2022 memo from the White House Office of Science and Technology Policy (OSTP) entitled “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research”, U.S. federal agencies are now beginning to implement revised guidance related to how you share your research publications and data and how you represent your scholarly profile.
Here's what you need to know.
Public Access Policy Implementation Timelines
Please note: we will be updating this page with links to agency-specific guidance throughout the fall. Please check back soon.
- National Institute of Health (NIH) - Revised public access policy in effect for manuscripts accepted for publication on or after July 1, 2025. The 2023 NIH Data Management and Sharing Policy remains in effect for research data generated with NIH funding. Learn more about how to comply with new NIH requirements
- National Science Foundation (NSF) - Supplement 1 (NSF 26-200) in effect for all financial assistance awarded on or after December 8, 2025. Supplement 2 (NSF 26-202) in effect for awards on or after January 22, 2026. Learn more about how to comply with new NSF requirements.
- United States Department of Agriculture (USDA) - Revised public access policy (DR 1020-0006) in effect for all support active in FY2023, or contract signed on or after October 1, 2022. Learn more here.
- United States Department of Energy (US DOE) - DOE Public Access Plan effective December 31, 2025
- United States Department of Defense (US DoD) - DoD Implementation Plan for Free, Immediate, and Equitable Access to Federally Funded Research in effect from December 31, 2025
- National Endowment for the Humanities (NEH) - NEH Public Access Policy applicable to all awards made on or after October 1, 2025.
Agency guidance documentation
SPARC, a non-profit advocacy organization focused on securing open and equitable access to scholarly research, is closely tracking new agency guidance as it becomes available. Please see SPARC's website for links out to agency-specific documentation.
For more information on navigating agency guidelines for public access to research data, please see our Data Management Guide.
For questions about any of the information contained here, please feel free to contact any of the Library staff listed below.
General Information about Federal Policy Changes Related to OSTP Memo
- What will be required?
In a nutshell, the memo issues guidance in several main areas that will likely impact any researcher who receives federal funding:
- Immediate public access to publications and data: Embargoes will no longer be allowed for research outputs including peer-reviewed publications such as articles, books, book chapters, conference proceedings, as well as datasets and code, that are supported with funding from federal grants. See below for more details.
- Use persistent identifiers: Persistent identifiers (e.g., DOIs for publications, ORCID IDs for researchers) will be required in grant applications and related outputs such as publications.
- Establish policies for how data must be managed and shared: Federal agencies need to describe researcher responsibilities for managing and sharing federally funded scientific data.
- When will these new policies be implemented?
- All federal funding agencies are instructed to develop (or update) and implement plans to support this guidance by December 31, 2025. Some policies may not take effect until the beginning of 2026; however, many federal funding agencies are already discussing earlier timelines by which they plan to update and make available their implementation plans.
The 2024 NIH Public Access Policy went into effect on July 1, 2025.
- What can I do right now to prepare for the upcoming changes?
- Use digital persistent identifiers (known as PIDs or DPIs) for all of your publications, data, and code, and for your researcher identity.
- Sign up for an ORCID ID (Open Researcher and Contributor ID) and connect it to your Unity ID. Start here: https://ci.lib.ncsu.edu/
- Make sure your publications and research data have been assigned a PID (such as a DOI or Handle) and link them from your ORCID record.
- Familiarize yourself with the data repositories in your field. The Libraries Data Repositories page provides useful information. If you aren’t aware of any data repositories in your field, check out the Dryad Data repository. Start here: https://www.lib.ncsu.edu/do/data-management/sharing-data/data-repositories
- Familiarize yourself with strategies that support sharing of scholarly articles and other types of publications. Start here: https://www.lib.ncsu.edu/do/open-research/scholarly-sharing/where-to-share
- Familiarize yourself with the elements of data management and sharing plans, which outline at a high level how you will collect, manage, store, and provide access to your data. Some federal agencies already require DMPs or data management plans (aka data management and sharing plans) including NSF, USDA, DOE, and NIH. Send us a copy of your DMP to get feedback to improve it. Start here: https://www.lib.ncsu.edu/do/data-management/drafting-your-dmp
- Use digital persistent identifiers (known as PIDs or DPIs) for all of your publications, data, and code, and for your researcher identity.
- What is a persistent identifier (PID), and how do I get one?
- Persistent identifiers or PIDs are unique identifiers to digital objects, people, organizations, etc. that are meant to persist over time. The advantage of PIDs is that they provide access to the digital objects regardless of the location of the information. DOIs (digital object identifiers) and ORCIDs (Open Researcher and Contributor ID) are both examples of PIDs.
- For articles, DOIs are usually assigned to articles by a publisher or article repository.
- For datasets, DOIs are usually assigned by the data repository that hosts the dataset. Our membership to the Dryad Data Repository includes DOIs to datasets.
- For people, ORCIDs are free and easy to set up. Start here:https://ci.lib.ncsu.edu/
- NC State has the Research Facilitation Service (RFS), which partners with university and departmental service providers to address research computing and data questions. It’s a good place to start if you aren’t sure where to look for help.
- What additional information is available from the White House Office of Science and Technology Policy?
The White House Office of Science and Technology Policy made an FAQ available: https://bidenwhitehouse.archives.gov/ostp/news-updates/2022/12/20/frequently-asked-questions-2022-public-access-policy-guidance/
Public access requirements for publications
- What publications are going to be required to be made publicly accessible?
The 2022 OSTP memo broadens the definition of publications and includes not only research articles and accepted manuscripts, but also peer-reviewed book chapters, editorials, and conference proceedings. From the University of Michigan Library OSTP guide:
- Peer-reviewed publications include "peer-reviewed research articles or final manuscripts published in scholarly journals, and may include peer-reviewed book chapters, editorials, and peer-reviewed conference proceedings published in other scholarly outlets that result from federally funded research.”
- Scientific data include: "the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings. Such scientific data do not include laboratory notebooks, preliminary analyses, case report forms, drafts of scientific papers, plans for future research, peer-reviews, communications with colleagues, or physical objects and materials, such as laboratory specimens, artifacts, or field notes." In addition, scientific data do not include data subject to legal, privacy, ethical or other similar restrictions or limitations.
- Will a 12-month embargo still be allowed after publication and before an article supported by federal funds has to be made publicly available?
No, the 12-month embargo will no longer be allowed.
- Do researchers need to pay article processing charges (APCs) in order to comply with the new policies?
- No. There is no requirement from federal funding agencies that researchers need to pay article processing charges (APCs) to journals to comply with the public access policy.
- Compliance can be achieved by submitting the author’s final version to the appropriate repository. Sometimes referred to as the Author Accepted Manuscript (AAM), this is the author’s manuscript which includes all modifications resulting from the peer review process, including all associated tables, graphics, and supplemental material. The AAM is different from the Version of Record, the publisher’s authoritative copy of the paper that includes all modifications from the publishing peer-review process, copyediting, stylistic edits, and formatting changes
- You will be required to make publications freely available and publicly accessible in agency-designated repositories. In some cases, those agency-designated repositories have yet to be identified. In other cases, federal funders are already using repositories, e.g., the NIH uses PubMed Central as its primary public access repository for publications that are supported by NIH grants.
- SPARC maintains a resource for tracking, comparing, and understanding U.S. federal funder publication sharing policies: https://researchsharing.sparcopen.org/publications/
- If your article was not published open access, deposit the final peer-reviewed manuscript/author accepted manuscript. If you’ve published open access, you still need to deposit your article in the designated repository, but you may deposit the Version of Record.
- If you do decide to pay an APC to make your publication open access, the NC State University Libraries participates in a number of open access agreements that allow campus authors to publish their articles open access without having to pay an article processing charge (APC). Check our Open Access Support webpage for eligibility details.
- No. There is no requirement from federal funding agencies that researchers need to pay article processing charges (APCs) to journals to comply with the public access policy.
- What is the difference between "public access" and "open access"?
- The Office of Science & Technology Policy defines public access as the “free availability of federally funded scholarly materials to the public". Public access is often dictated as policy set forth by federal funding agencies such as NIH or NSF. Public access does not necessarily incur a publishing fee nor does it include a specific license dictating re-use.
- Open access is a broad set of principles and practices for sharing research outputs (including publications and data), where they are freely available online and free of most copyright and licensing restrictions. Many (but not all) open access journals require a fee known as an article processing charge (APC).
- In some cases, publishing in an open access journal may not meet public access policy guidelines. For example, NIH-funded research articles published in some open access journals may still need to be deposited into the NIH repository PubMed Central in order to be compliant.
- Who is going to submit my article (or other publication type) to the agency-designated repository?
In some cases, the publisher of the journal in which your article was published will submit it on your behalf. Publishers might do this for free, or they might charge you for this service. In other cases, you will have to submit the appropriate version of your article to the agency-designated repository yourself or set up a designee to do this for you.
- Does NC State offer any support for helping to understand how I can comply with the public access requirements for publications?
- The NC State University Libraries offers the Open Knowledge Center, providing support for public access to publications and expert help for securing rights to make publications publicly accessible.
- NC State also has several OA agreements in place to cover the costs of APCs required for OA publishing.
Public access requirements for research data
- Do I really have to make my research data publicly accessible?
- Yes. However, the specifics will be determined by the implementation plans from the federal funding agencies. In general, underlying data needed to validate the conclusions of articles need to be shared and made immediately available upon publication of related publications.
- For supporting data, agencies have already begun to indicate that a variety of repositories will be acceptable for deposit, and many research data repositories are working to ensure that they are ready to meet the guidelines issued by the OSTP for data repositories.
- Who will submit my research data to the appropriate data repositories?
In most cases, you or a designated member of your research team will submit the relevant data to a data repository. Check with your funder to see whether they prefer you use a specific data repository. NC State is an institutional member of the Dryad data repository. The Libraries also provides information about additional repository options depending on disciplines/subjects. Dryad can link datasets with articles and will provide you with a digital object identifier (DOI) for your data.
- Does NC State offer any support for helping to understand how I can comply with the public access requirements for data?
- NC State has the Research Facilitation Service (RFS), which partners with university and departmental service providers to address research computing and data questions. The team can help with these kinds of questions or link you to the appropriate unit for help when necessary.
- NC State has the Research Data Management Guide providing support for public access to data and a team of experts to support specific questions for sharing data publicly
- NC State has a membership to the Dryad data repository, and our guide recommends additional repository options depending on disciplines/subjects. Dryad can link datasets with articles and provide you with a digital object identifier (DOI) for your data.
- Can I include costs that I expect to incur to comply with data management and sharing in the budget of my grant?
Yes. You can include reasonable publication costs and costs associated with submission, curation, management of data, and special handling instructions as allowable expenses in all research budgets.
- The National Institute of Mental Health Data Archive (NDA) has developed a cost estimation tool that can be used as a model to help you budget for data curation costs.
- Similarly, OpenAIRE has developed a tool to estimate the costs of research data management.
- FASEB has generated some guidance on budgeting for data management.
- I keep hearing about FAIR data - what exactly does that mean?
FAIR Data Principles stand for Findable, Accessible, Interoperable, and Reusable. Please reach out to us through the Research Facilitation Services (RFS) intake form if you need help to learn about possible established data repositories used in your field (data repositories organized by discipline are available at re3data.org and fairsharing.org), and let us know if you would like help using the Dryad Data repository.
Agency guidance documentation
SPARC, a non-profit advocacy organization focused on securing open and equitable access to scholarly research, is closely tracking new agency guidance as it becomes available. Please see SPARC's website for links out to agency-specific documentation.
For more information on navigating agency guidelines for public access to research data, please see our Data Management Guide.
For questions about any of the information contained here, please feel free to contact any of the Library staff listed below.