Planning considerations for new NIH Public Access Policy

From: Office of the Vice Chancellor for Research
Sent: Wednesday, April 1, 2026, 9 a.m.
To: NIH principal investigators

Dear Colleagues,

Effective July 1, 2025, the National Institutes of Health implemented a new a Public Access Policy requiring immediate public access, upon publication, to the author’s accepted manuscript or the final published version of any article reporting on NIH‑funded research. The previous policy permitted embargoes of up to 12 months.

All articles accepted on or after July 1, 2025 are subject to this updated requirement. Failure to comply may jeopardize current and future NIH funding. Because this represents a significant change — and because publishers are responding in different ways — it is important for PIs to understand the requirements and plan accordingly.

Planning for compliance
We strongly encourage NIH-funded investigators to plan now for how they will meet these requirements for current and future submissions. Common approaches include:

• Publishing in journals that permit no-cost, zero‑embargo public access.
• Publishing in journals covered by KU institutional agreements that eliminate or reduce article processing charges (APCs).
• Identifying funding sources to cover APCs during and beyond the grant period. 
  • APCs are currently allowable under NIH guidance, though NIH is considering potential caps or future restrictions.

Related NIH data policy
Alongside the new Public Access Policy for publications, NIH’s Policy for Data Management & Sharing — in effect since January 2023 — sets expectations for how research data generated with NIH funds are managed and shared. Although these are distinct requirements, investigators are expected to plan for and comply with both, and each may affect publication choices, repository selection and allowable project costs.

Under the Data Management & Sharing policy, which is intended to promote responsible data sharing and accelerate biomedical research, researchers and institutions are expected to:

• Plan and budget for data management and sharing.
• Submit a Data Management & Sharing Plan with each NIH application.
• Comply with the approved plan throughout the project life cycle.

Comprehensive NIH guidance is available at sharing.nih.gov.

KU resources and contacts
To support PIs navigating these requirements, KU offers the following resources:

• Funder Public Access Guide: General and NIH-specific guidance on public access requirements
• Video: Faculty How To at KU: Changes to Public Access Research & Navigating Requirements
• NIH Data Management & Sharing Policy Guide: Practical guidance for planning and compliance
• Scholarly Communication & Copyright Services
• Research Data Management Resources

For additional assistance:

• Scholarly publishing and copyright:
  Josh Bolick, Head of the Shulenburger Office of Scholarly Communication & Copyright, jbolick@ku.edu
• Research data management:
  Jamene Brooks-Kieffer, Data Services Librarian, jamenebk@ku.edu
• NIH proposal questions:
  Pre-Award Services, Office of Research, kucrpremgmt@lists.ku.edu
• NIH reporting questions: 
  Nancy Biles, Office of Research, kuresrpprteam@ku.edu

We recognize these evolving requirements add complexity to the publication and data-sharing process. KU Libraries and the Office of Research are committed to helping you plan for compliance and identify practical, cost-effective approaches. Please reach out early with questions or concerns.

Respectfully,
Alicia & Scott

Alicia Reed
Assistant Vice Chancellor for Research
Office of Research

Scott Hanrath
Associate Dean for Research Engagement
KU Libraries