National Institutes of Health Public Access Policy

The 2024 Public Access Policy put forward by the National Institutes of Health has several implications for how you share your research and represent your scholarly profile. This policy became effective on July 1, 2025.

Awards closed before July 1, 2025 are subject to the 2008 Public Access Policy, which allows for an embargo of up to 12 months.

How do I comply?

Publications

• Peer-reviewed journal articles with acceptance dates on or after July 1, 2025 are subject to the policy.
• On acceptance of your article for publication, submit a copy of the Author Accepted Manuscript (AAM) to PubMed Central
  • PMC submission instructions
  • Please note: deposit through publisher workflows is not sufficient for compliance. You must submit your article to PMC directly.

Things to note:

• A 12-month embargo period is no longer allowed; articles must be submitted immediately upon acceptance.
• Some journals do not allow zero-embargo deposit of the AAM for articles that are not published open access.
• Articles published open access (OA) do not have embargo restrictions. The AAM for OA articles must still be submitted upon acceptance (Note that the NIH does not require publishing open access to comply with the updated public access policy).

Choosing a publication venue:

• Check publisher/journal embargo policies before submitting your manuscript. Many journal policies can be found on the Jisc Open Policy Finder.
• The Penn State University Libraries maintains a list of zero-embargo publishers.
• 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.

Allowable publication costs:

• Publishing open access is not required to comply with the updated policy, but funding for reasonable publication costs is allowed as part of the project budget which can include APCs for publishing open access.
  • The NIH has announced it will begin imposing a cap on allowable publication costs beginning in FY2026.
• NIH guidance currently states that "Journal or publisher fees charged for the purpose of submitting the Author Accepted Manuscript to PubMed Central are not allowable costs."
  • February 2026 update: ACS has indicated that NIH has agreed to consider their article development charges (ADCs) to be allowable. Your program officer is generally a good resource if you have questions.

The Authors Alliance has a helpful Q&A page on the policy update, especially as it relates to manuscripts submitted before July 1, 2025 and publishers with zero-embargo policies. 

Research data

The most important thing to know is that not much has changed since 2023 when the updated NIH Data Management and Sharing Policy came into effect. PIs are still expected to

• submit a Data Management and Sharing Plan (DMSP) with their grant proposals indicating how scientific data and metadata will be stored, described, preserved, and – where possible – shared
• maximize the sharing of scientific data generated during the course of the research project

Allowable costs:

Expenditures such as publication costs and costs associated with submission, curation, management of data, and special handling instructions, are considered allowable expenses in all research budgets. PIs are encouraged to incorporate data management and sharing (DMS) costs in the appropriate cost category, e.g., personnel, equipment, supplies, and other expenses, following the instructions for the R&R Budget Form or PHS 398 Modular Budget Form. Applicants will be asked to specify estimated DMS cost details within the “Budget Justification” attachment of the R&R Budget Form or “Additional Narrative Justification” attachment of the PHS 398 Modular Budget Form.

There are a few tools available to help forecast DMS costs for NIH 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.

Resources

Metadata and Persistent Identifiers (PIDs or DPIs)

In December 2024, the NIH issued its draft Plan to Increase Findability and Transparency of Research Results Through the Use of Metadata and Persistent Identifiers to address section IV of the OSTP memo.

• As of May 2025, NIH requires all senior and key personnel named in NIH grants to link their eRA profiles with a free, uniquely assigned ORCID iD. Senior and key personnel will use their ORCID in SciENcv to submit Common Forms and NIH Biographical Sketch Supplement.
• For new manuscripts generated with NIH support, all authors who are named senior and key personnel will use an ORCID iD when submitting new research manuscripts to the NIH Manuscript Submission system (and the journal submission system, where allowed).
• NIH intramural PIs will use ORCID iDs to submit new research manuscripts.
• Where ORCIDs are not accepted, NIH authors are expected to submit name and affiliation metadata consistently.
• When depositing data with a data repository, PIs are expected to meet the repository's best practices with regard to providing metadata about the dataset.
  • As part of the dataset's metadata, PIs will be expected to include:
    • ORCID iDs or other PIDs and names for contributing senior and key personnel
    • Affiliations (or other PIDs for affiliations, such as a Research Organization Registry, or ROR, identifier)
    • Funding sources
• NIH intramural PIs will be expected to provide PIDs for publications and shared data when citing these products in NIH funding applications or proposals, and when providing research performance progress reports or annual reporting, as able.

Resources