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Federal Government Public Access Policies

Federal Agency Public Access Requirements

Funder Requirements

Materials from the 9/16/25 Federal Policy Changes Impacting Research Sharing Info Session

This session covered federal funding agency policy changes that have gone into effect or will be implemented in 2025 that may impact your research. We covered the expanded sharing requirements for publications, data, and software resulting from federally funded research, describe where researchers can find more information, and highlight the resources that are available at UT Austin to assist with compliance. We also discussed the commonalities and differences among individual research funding agency plans.

 

New Funder Requirements

Here is information about revised public access policies for some of the larger federal funding agencies. Agencies not listed below may still have existing policies for grant-holders. Click on the name of an agency below to see expanded information about that agency's policy.

Please note that policy websites, implementation dates, and other aspects of open access requirements are subject to change, so we are doing the best we can to keep information up to date on this guide. For general questions about changes in funder policies, contact your subject liaison librarian for assistance. For questions about a particular funding opportunity, please read over your notice of funding opportunity and contact your program officer for additional clarification about expectations in order to ensure that you are receive the latest information specific to your research situation.

DoD - Dept. of Defense
Effective 12/31/25

Articles:

  • Currently, final, peer-reviewed manuscripts documenting the results of DoD-funded research must be uploaded, at the time of acceptance for publication, to a submission portal hosted and maintained by the Defense Technical Information Center (DTIC). Final, peer-reviewed manuscripts uploaded to the DTIC submission portal are released to the public after a 12-month embargo, and final versions of open access journal articles are released immediately upon publication. DoD intends to revise its policy such that ublications documenting the results of DoD-funded research will be made available without embargo or delay; made available in machine-readable format; and broadly accessible through assistive devices.

Data:

  • Extramural researchers will store data sets underlying or resulting from DoD-funded research in digital repositories. DoD will issue guidance for selection of repositories based on the National Science and Technology Council Subcommittee on Open Science document entitled "Desirable Characteristics of Data Repositories for Federally Funded Research."
DOE - Dept. of Energy
In Effect

Articles:

  • DOE-funded researchers must submit the full-text accepted manuscript of a journal article and associated metadata to DOE’s Office of Scientific and Technical Information (OSTI) through E-Link  no later than the publication date of the article. If the article itself is published as “open access” (OA), the author may submit the OA article and metadata to DOE. DOE will provide immediate, free public access to submitted publications through its designated repository DOE PAGES®.

Data:

  • "The DMSP should specify the use of digital repositories that align, to the extent practicable,with the National Science and Technology Council document entitled "Desirable Characteristics of Data Repositories for Federally Funded Research," by the Subcommittee on Open Science of the National Science and Technology Council, May 2022. In general, DOE does not endorse or require sharing in any specific repository and encourages researchers to select the repository that is most appropriate for their data type and discipline, though individual sponsoring research offices may provide specific guidance or designate a specific repository." "Scientific data that are shared publicly, as described in an approved DMSP, must be reported as STI [scientific and technical information] to DOE "
  • These requirements primarily apply to data supporting a peer-reviewed publication, but "the DMSP should also provide a timeline for sharing digital scientific data produced under the DOE funded R&D effort not associated with peer-reviewed scholarly publications."
Ed - Dept. of Education
In Effect

Articles:

  • Authors must submit their final, peer-reviewed scholarly publications to ERIC upon acceptance. The article must be made available publicly on ERIC at the same time as the publication becomes available on the publisher's website. Authors who are depending upon publishers to submit publications on their behalf should ensure that the publisher has a system for implementing the “zero-day embargo” policy.

Data:

  • Data collected must be shared at time of publication or if unpublished 5 years after award ends (whichever comes first) in machine readable formats with accompanying metadata to facilitate discoverability and re-use. Data that is made accessible should be free of identifiers that would allow linkages to individuals participating in the research as well as other elements that could lead to deductive disclosure of the individual study participants. Data should be shared in public repositories that align with the characteristics described in the National Science and Technology Council document, "Desirable Characteristics of Data Repositories for Federally Funded Research."
EPA - Environmental Protection Agency
In Effect

Articles:

  • If a journal does not submit the full text of an OA journal publication or an AAM associated with the journal publication to PubMed Central on behalf of the author(s), the grant recipient is responsible for submitting the AAM to PMC unless the publication is jointly authored with an EPA researcher, in which case the federal employee is responsible for the upload. The AAM must be submitted to PMC within 30 days of journal publication.

Data:

  • Scientific research data supporting a journal publication must be published in a publicly accessible data repository by the recipient within 30 days of the date of the journal publication or the associated author manuscript becomes accessible to the public, unless 1) the dataset has already been made accessible to the public via public release or another sharing mechanism; or 2) the research data cannot be released due to one or more constraints (e.g., national security, prohibited release of data).
  • Researchers should use a digital, online, public access data repository. The EPA does not require the use of a specific repository, provided that the selected repository ensures that research data are findable, accessible, interoperable, and reusable to the greatest extent possible and meets criteria listed by the National Science and Technology Council Subcommittee on Open Science guidance document, "Desirable Characteristics of Data Repositories for Federally Funded Research" (2022).
  • Data must be accessible in at least one machine-readable format, preferably a widely-used or open-standard format, and should also be accompanied by machine-readable documentation (metadata), preferably based on widely used or international standards, such as described in principle in the Office of Management and Budget Memorandum M-13-13 entitled “Open Data Policy-Managing Information as an Asset”
FDA - Food & Drug Administration
In Effect

Articles:

  • FDA-funded researchers must make "the final manuscript and associated metadata for such scholarly publication available in a full-text archive as soon as practicable after the formal publication date" (from SMG 2126.6)
  • Options for compliance include:
    • relying on the formal publisher—consistent with its written policies and procedures, written assurances, or an agreement with the National Library of Medicine—to upload the final manuscript and associated metadata to PubMed Central or another full-text archive;
    • making the final manuscript and the associated metadata available via a full- text archive hosted, managed, and overseen by the extramural researcher and/or a third party; and
    • relying on FDA staff who have been credited as authors on the scholarly publication to post the final manuscript and associated metadata directly to PMC via the NIH Manuscript Submission System (NIHMS).

Data:

  • The FDA will "require extramural researchers to obtain FDA authorization of a Data Management Plan before they begin the extramural research" (SMG 2126.6)
  • FDA-funded researchers must, "as soon as practicable after the formal publication date—directly or indirectly make available to the public in a data repository the scientific data underlying such scholarly publication (insofar as the data were generated by the research funded by FDA
    and except insofar as the disclosure is prohibited by law or other federally mandated policies). The extramural researcher must also include metadata associated with the scientific data."
  • Options for compliance include:
    • relying on the publisher—consistent with its written policies and procedures or written assurances—to make the scientific data and metadata available in a data repository;
    • making the scientific data and associated metadata available via a data repository hosted, managed, and overseen by the extramural researcher and/or a third party; and
    • working with FDA staff who have been credited as authors on the scholarly publication to post the scientific data and metadata at openFDA.
HHS - Health & Human Services
In Effect
*Note: Agencies under HHS have their own public access policies that are more detailed and to which grant recipients will be subject.

Articles:

  • Results of awarded projects should be published in a peer-reviewed journal.
  • A copy of each publication must be submitted with the annual or final progress report.

Data:

  • Final research data and tools should be shared either when the main findings are accepted for publication or when findings are submitted to the awarding agency.
  • Data sharing exclusions: drafts of scientific papers; plans for future research; peer reviews; communications with colleagues; physical objects (e.g., laboratory samples, audio or video tapes); trade secrets; commercial information; materials necessary to be held confidential by a researcher until publication; intellectual property; personnel, medical files, and similar files; if disclosure would constitute an unwarranted invasion of personal privacy; personally identifiable information of study participants; data from human cells or tissues that reveal the identity of the original donors.
  • Materials can be shared through the researcher's lab or organization or submitted to a repository.
  • Unique biological data, like DNA sequences, should be sent to the appropriate data banks.
IMLS - Institute of Museum & Library Services
In Effect
The updated IMLS public access policy will apply to all new awards made on or after October 1, 2025.

Articles:

  • A machine readable copy of most appropriate version of a published manuscript (the version of record if possible, if not then the author's accepted manuscript) must be deposited in the IMLS designated repository. The most appropriate version may be the version of record, if that is allowed by the publisher, or it might be the author's accepted manuscript. It must be made available no later than the date of article publication and must be shared without embargo. This policy applies to journal articles, but may also include book chapters, conference proceedings, or editorials. Further instructions regarding the IMLS designated repository have not yet been released as of 9/2025 but will be forthcoming.

Data:

  • This policy applies to all data underlying peer-reviewed scholarly publications with exceptions for data that cannot be shared for ethical or legal reasons. Data must be deposited immediately following publication. Researchers have the freedom to choose the repository that they feel is the most appropriate for publishing their research data. Researchers are responsible for ensuring that only research data that meet all disclosure requirements, including all ethical and legal restrictions, are shared publicly.
NASA - National Aeronautics & Space Administration
In Effect

Articles:

  • "Under SPD-41a, all publications resulting from research funded by SMD shall be made publicly available to the extent allowed by applicable law and existing NASA policies. Peer reviewed manuscripts resulting from SMD-funded scientific activities shall be made freely available to the public by default, without any embargo or delay after the publication date."
  • Certain Open Access articles may be automatically deposited with NASA if the publisher is part of CHORUS or the journal is indexed in NASA's Astrophysics Data System (ADS). For all of other articles, researchers should either deposit the final publisher's version (other OA articles) or the Author's Accepted Manuscript (AAM, for non-OA articles) in the PubSpace collection within the NASA Technical Report Server (NTRS). Authors can deposit AAMs as early as formal acceptance of the manuscript, and all AAMs must be submitted by the formal publication of the article.

Data:

  • "Scientific data underlying peer-reviewed scholarly publications resulting from Federally funded research shall be made freely available and publicly accessible by default at the time of publication, and no embargo by a publisher or others shall be imposed, nor will such be recognized by NASA."
  • "All proposals or project plans submitted to NASA for scientific research funding shall include a DMP that describes whether and how data generated through the course of the proposed research will be shared and preserved (including timeframe) or explains why data sharing and/or preservation are not possible or scientifically appropriate. At a minimum, DMPs shall describe how data sharing and preservation will enable validation of published results, or how such results could be validated if data are not shared or preserved."
  • Researchers may be required to use certain data repositories as prescribed either by the solicitation or by a specific division. If no repository is specified, researchers should next assess whether a NASA Science Data Archive can support their data. If a NASA Archive is not appropriate, third-party repositories may be used, provided that they comport with the standards established in the linked guidance (SPD-41A).

Software: 

  • "All proposals or project plans submitted to NASA for scientific research funding will be required to include a Software Management Plan (SMP) that describes whether and how software generated through the course of the proposed research will be shared and preserved (including timeframe) or explains why software sharing and/or preservation are not possible or scientifically appropriate."
  • "Scientific software underlying peer-reviewed scholarly publications resulting from Federally funded research must be made freely available and publicly accessible by default at the time of publication."
  • If software is shared on a version controlled platform (e.g. GitHub, GitLab), it is also important to archive the software at a designated repository like Zenodo that can issue DOIs.
NEH - National Endowment for the Humanities
In Effect
The updated NEH public access policy will apply to all new awards made on or after October 1, 2025.

Articles:

  • "Recipients must submit a copy of the author's accepted manuscript (AAM) for any peer-reviewed scholarly article resulting in whole or in part from award activities. Recipients must submit an AAM to NEH no later than the article publication date, defined here as the date the final publisher's version is available online."
  • "NEH will also accept the version of record or publisher's version of the article when the applicable publisher agreement explicitly allows this"
  • "NEH will deposit each article in a free and publicly available designated repository"

Data:

  • "Recipients must publicly share applied or scientific research datasets produced as a result of funding from a small number of NEH programs, as described in the respective Notices of Funding Opportunity. Recipients will not submit data directly to NEH; rather, they will adhere to a Data Management and Sharing Pan (DMPS) detailing expected points of access and preservation."
NIH - National Institutes of Health
In Effect
Note: the NIH policy for articles (and similar outputs) applies to all grant-holders, whereas the NIH policy for data only applies to those considered to generate data (e.g., does not apply to Training and Fellowship grants).

Articles:

  • "Submission of the electronic version of the [peer-reviewed] Author Accepted Manuscript to PubMed Central upon its acceptance for publication, for public availability without embargo upon the Official Date of Publication." Or
  • "Submission of the Final Published Article to PubMed Central from journals or publishers with formal agreements with NLM [National Library of Medicine], upon the Official Date of Publication, for public availability without embargo."

Data:

  • "Submission of a Data Management and Sharing Plan outlining how scientific data and any accompanying metadata will be managed and shared, taking into account any potential restrictions or limitations."
  • "NIH expects that in drafting Plans, researchers will maximize the appropriate sharing of scientific data, acknowledging certain factors (i.e., legal, ethical, or technical) that may affect the extent to which scientific data are preserved and shared. Any potential limitations on subsequent data use should be communicated to individuals or entities (e.g., data repository managers) that will preserve and share the scientific data."
  • "Compliance with the awardee’s plan as approved by the NIH ICO [Institute, Center, Office]."
  • "Shared scientific data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of performance period, whichever comes first."
  • NIH may encourage or require use of a specific data repository based on a specific solicitation or ICO policy; NIH manages many data repositories itself.
NOAA - National Oceanic & Atmospheric Administration
Effective date TBA

Articles:

  • NOAA Library (encouraged, other repositories may be acceptable)

Data:

NSF - National Science Foundation
Effective date TBA
*Note: The below policy is based on the draft PAPPG that was released in December 2024 - it is anticipated that significantly more detail will be provided around the public access policies in the final version.

Articles:

  • "Final versions of manuscripts accepted for publication after peer-review in either scholarly journals or juried conference proceedings must be deposited in NSF’s Public Access Repository (PAR)."

Data:

  • "Scientific datasets underlying peer-reviewed scholarly publications resulting from federally funded research should be made freely available and publicly accessible by default at the time of publication in a repository which assigns a persistent identifier (e.g., DOI) to such deposited datasets, and the persistent identifier must be recorded in NSF’s Public Access Repository as part of the annual and final annual project reporting process."
USDA - United States Department of Agriculture
Effective date TBA

Articles:

  • Final peer-reviewed, accepted manuscripts will be required to be made publicly accessible through the USDA public access system (PubAg). USDA will provide public access through PubAg on the date on which the publisher makes the article available online. Final versions of record may be submitted if the author has secured rights to submit them (e.g., by securing open access licensing).
  • Scholarly publications must reference the USDA funding source(s).
  • All authors of scholarly publications must have individual persistent identifiers, such as ORCIDs, that are linked to their scholarly publications.

Data:

  • USDA will require digital research data be published in a machine-readable format by a data repository that is recognized by reputable registries and provides:
    • Public access for search, retrieval, and analysis.
    • A digital persistent identifier, such as a DOI.
    • Long-term preservation of the data asset.
  • USDA will make digital research data that are associated with scholarly publications publicly accessible immediately, simultaneous with the article publication. USDA also requires data that are not associated with scholarly publications to be made available by the end of the award.
  • All authors of digital research data must have individual persistent identifiers, such as ORCIDs, that are linked to their data publications.
USGS - United States Geological Survey
Partially In Effect
The USGS Public Access Plan already has most of its requirements now in place, but the full effective date will be 12/31/2025.

Articles:

As outlined in its original and current plans, the USGS requires journal article manuscripts of record (also referred to as final accepted manuscripts), which are considered external or outside publications (SM 1100.4), and USGS series publication information products (SM 1100.3) be handled as follows:
  • All accepted manuscripts must be deposited in the internal USGS Information Product Data System (IPDS) repository, which serves as an archive.
  • Journal articles are made publicly available free-of-charge by the publisher or the accepted manuscript archived in IPDS is made publicly available through the USGS Publications Warehouse at the time of publication.
  • Bureau-approved USGS series publications are released through the USGS Publications Warehouse immediately upon publication and are provided in a machine-readable format.
  • Persistent identifiers for publications, authors, and awards are included in the publication metadata as applicable.
  • Repository: USGS Publications Warehouse

Data:

Research data collected with USGS funds meet the following requirements:
  • All scientifically-relevant data, (that is, data associated with a scholarly publication and the supporting data collected by the project), will be made available free-of-charge for public access, unless the Bureau determines that a demonstrated circumstance restricts the data from being made publicly available; for example, in cases where access must be restricted because of security, privacy, confidentiality, or other constraints (SM 502.8).
  • Data should be machine-readable, and digitally accessible to the public by time of publication of results dependent upon that data.
  • Scientific data management requirements must be followed, including the development of data management plans (DMPs), which must be part of the approved USGS project plans. The DMP details information such as acquisition method, quality assurance, security, disposition, and if applicable, circumstance restricting public access (SM 502.6).
  • Metadata (using USGS endorsed metadata standards) must accompany the scientific data and this metadata record must be submitted to the USGS Science Data Catalog (SM 502.7).
  • Guidance is available on the USGS Data Management website.

External Resources

In light of proposed changes to the structure and organization of certain federal agencies and small extramural research budgets of others, only a select set of agencies are listed above. If you are planning to pursue funding from an agency not on this list, please visit their web page, policy documents, and funding opportunities for information about research sharing expectations.

For a comprehensive list of links to policy documents related to publication and data sharing requirements for all federal research funding agencies, including those with smaller extramural research funding budgets, visit the Scholarly Publishing and Academic Resources Coalition (SPARC) resource at https://sparcopen.org/our-work/2022-updated-ostp-policy-guidance/ to review those documents and policy implementation dates.”

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