Unlocking Scholarly Publishing: New federal public access requirements and what CU Boulder researchers need to know
Federal agencies have updated their public access policies to require that research outputs be made publicly available at the time of publication, eliminating previous embargo periods. These changes also expand expectations for sharing research data.
For CU Boulder researchers working with funding from all federal agencies, such as the National Science Foundation (NSF) and National Institutes of Health (NIH), these updates affect how research is shared and how publication and data management are planned.
What’s Changed
Public access policies are not new. Many agencies have had public access requirements in place for a decade or more. Recent updates introduce two key changes:
- Zero embargo: Articles must be publicly available immediately upon publication
- Expanded data sharing: Research data associated with federal funding must also be made publicly accessible (with some exceptions noted by individual agencies)
Requirements vary by agency, but these changes apply broadly across federally funded research.
What Research Outputs Are Covered
Public access requirements vary by agency, but for CU Boulder researchers, NSF and NIH policies are most relevant:
- NSF: Peer-reviewed journal articles, conference papers and proceedings, and supporting research data
- NIH: Journal articles and all scientific data produced from funded research
In both cases, manuscripts and associated data must be made publicly accessible, with details defined by each agency. A Data Management and Sharing Plan (DMSP) should describe how the proposal will conform with data sharing policies and justify exceptions. For the NIH, a new streamlined DMSP format was recently released.
What You Need to Do
To meet public access requirements, researchers should take these steps:
- Deposit your manuscript
You are required to deposit your Author Accepted Manuscript (AAM) in an agency-designated repository at or before publication. Agencies vary in which repository to use and the timing of deposit, but here is the NIH and NSF guidance- NSF: Submit to the NSF Public Access Repository (PAR)
- NIH: Submit to PubMed Central upon acceptance
- Plan for data sharing
Ensure your Data Management and Sharing Plan (DMSP) reflects current requirements. In most cases, data supporting your research must be made publicly available. - Consider publication-related costs
Federal agencies require deposit in a repository but do not require publication in an open access journal. However, some publishers require payment either to make an article openly available or to allow authors to deposit their manuscripts in public repositories. You may want to consider including anticipated publication costs in your grant proposal, where allowable.
Understanding Publisher Requirements
Although federal policies focus on repository deposit, publisher policies can affect how you meet these requirements. Some publishers require payment for open access publication or for allowing authors to share their manuscripts in public repositories.
At the same time, federal policy is continuing to evolve. In 2025, the NIH announced an intention and issued a Request for Information on limits on allowable publication costs, though further guidance is still forthcoming. The interplay between federal agencies and publishers in relation to these policies is ongoing.
Resources and Support
CU Boulder provides several resources to help faculty navigate public access requirements:
- Proposal Essentials by Sponsor, from the Office of Contracts and Grants, includes information about the DMSP, budgeting costs at proposal, and requirements during the award
- Publication Sharing Requirements by Federal Agency
- Guide for Authors Complying with U.S. Federal Agency Public Access and Publisher Policies
Because requirements vary by agency, faculty with federal funding should consult agency-specific guidance when planning publications and managing research outputs.
This article was authored in collaboration with Andrew Johnson, head of Data and Scholarly Communication Services unit.