The National Institutes of Health (NIH) announced on April 30, 2025 an accelerated implementation date for the updated Public Access Policy (released December 17, 2024). It will now go into effect July 1, 2025. Like the current policy, it applies to peer-reviewed journal articles from all research funded in whole or in part by NIH. 

The updated NIH Public Access Policy advances the NIH’s long standing prioritization of providing public access to NIH funded research. NIH’s 2023 Data Management and Sharing Policy remains in effect and will not change based on this new implementation date.

What you need to know

The Public Access Policy applies to all grants, including those awarded prior to the implementation date.

Starting July 1, 2025, investigators are required to submit the Author Accepted Manuscript (AAM) or Final Published Article for any peer-reviewed journal article based on research funded, in whole or in part, by NIH grants into PubMed Central (PMC) immediately upon the Official Date of Publication. 

When submitting to NIH, authors must also agree to a license similar to the Government Use License (2 CFR 200.315), explicitly granting NIH the right to make the AAM publicly available in PMC, with no embargo, on the Official Date of Publication.

The policy defines: 

• Author Accepted Manuscript (AAM) as the “author’s final version that has been accepted for journal publication and includes all revisions resulting from the peer review process, including all associated tables, graphics, and supplemental material.”
• Final Published Article as the “journal’s authoritative copy, including journal or publisher copyediting and stylistic edits, and formatting changes, even prior to the compilation of a volume or issue or the assignment of associated metadata.”
• Official Date of Publication as the “date on which the Final Published Article is first made available in final, edited form, whether in print or electronic (i.e., online) format.”

Compliance requirements and impact of noncompliance

To comply with the policy, the Author Accepted Manuscript to PubMed Central must be submitted to PubMed Central upon acceptance for publication and NIH granted the right to make it publicly available on the Official Date of Publication. 

For journals or publishers with formal agreements with the National Library of Medicine, compliance can be met by submission to PubMed Central on the Official Date of Publication, for immediate public access.

Compliance with the Public Access Policy is mandatory. NIH may consider noncompliance with the policy in future funding decisions for the recipient institution. Non-competing continuation grant awards are subject to a delay in award processing for noncompliance with the NIH Public Access Policy.   

Government use license

By accepting NIH funding, recipients agree to grant a license to the Author Accepted Manuscript to NIH. When submitting an AAM, authors will agree to a license similar to the Government Use License (2 CFR 200.315), which provides NIH with a royalty-free, nonexclusive, and irrevocable right to the Author Accepted Manuscripts. This explicitly grants NIH the right to make the article publicly available in PubMed Central on the Official Date of Publication. 

NIH encourages authors to include a statement that indicates the Author Accepted Manuscript is subject to the NIH Public Access Policy provided in the Supplemental Guidance to the 2024 NIH Public Access Policy: Government Use License and Rights NOT-OD-25-049

“This manuscript is the result of funding in whole or in part by the National Institutes of Health (NIH). It is subject to the NIH Public Access Policy. Through acceptance of this federal funding, NIH has been given a right to make this manuscript publicly available in PubMed Central upon the Official Date of Publication, as defined by NIH.”

Costs

The NIH Public Access Policy does not require authors to pay a fee, such as an article processing charge for open access. The updated policy continues to allow reasonable publication costs as part of the project budget. Fees charged by a journal or publisher for submission of the AAM to PubMed Central are not allowable costs.

Support

Journals and publishers that currently have formal agreements with the National Library of Medicine to submit to PubMed Central on behalf of authors are operating under the 12-month embargo allowed by the 2008 policy. If the journal or publisher does not change their practices, authors have additional options for complying with the policy. 

NIH provides instructions on how to submit a manuscript to PubMed Central (“Method C” is for authors submitting directly to PMC). The NIH Manuscript Submission has a video overview, illustrated submission tutorials and an FAQ.

Regardless of who starts and manages the submission process, authors and awardees are responsible for ensuring that the final, peer-reviewed manuscript is deposited into the NIHMS upon acceptance for publication.

For more, visit the Libraries’ Public Access Policy LibGuide.