Proper Research Data Management (RDM) is a mandatory Open Science practice in Horizon Europe projects that generate or reuse digital research data. Beneficiaries must manage these data responsibly, in line with the FAIR principles (Findable, Accessible, Interoperable, Reusable).

At a minimum, beneficiaries must:

• Establish by month 6 a Data Management Plan (DMP), and keep it updated throughout the project, covering the data generated and/or reused in the project.
• Deposit the data in a ‘trusted’ and ‘metadata-ready’ repository as soon as possible or within the deadlines set out in the DMP. When required by the call conditions, use a repository federated in the European Open Science Cloud (EOSC).
• Ensure Open Access to the deposited data via the repository as soon as possible or within the timeline set in the DMP, under a CC0 or CC BY licence (or equivalent), following the principle “as open as possible, as closed as necessary”. This means that the data access can be restricted to safeguard legitimate interests and constraints. If open access is not provided to some or all data, the reasons must be explained and justified in the DMP.
• Provide open metadata for deposited datasets (CC0 or equivalent,) and provide information via the repository about any related research outputs and any other tools or instruments needed to reuse or validate the data.
• Provide information (via the same repository) about any research output or any other tools and instruments needed to re-use or validate the data.

Keep in mind that ‘research data’ is a very broad concept and certainly not limited to numerical and tabular data.

• Horizon Europe emphasises managing digital research data, and where relevant other research outputs, in line with the FAIR principles, which means making them Findable, Accessible, Interoperable and Reusable. Through appropriate metadata, identifiers, standards and clear access/reuse conditions, they can be reused by both humans and machines.
• Depositing data in a FAIR-enabling, trusted and metadata-ready repository is a key step towards FAIRness, as it supports persistent identifiers, rich metadata, standard access mechanisms and preservation. FAIR does not necessarily mean open: access may be restricted where justified, provided that metadata remain openly accessible and conditions are clearly described within the DMP.
• There is no one-size-fits-all approach to FAIR. What is appropriate and feasible largely depends on the research domain, data types involved, as well as on the specificities of the project (e.g. sensitivities, constraints, project context), and should be documented and reviewed in the DMP.

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Developing a Data Management Plan (DMP) is a core step in complying with Research Data Management (RDM) requirements in Horizon Europe.

A DMP describes how digital research data (and, where relevant, other research outputs) will be managed both during and after a research project. It identifies key actions and strategies to ensure that research data are of a high-quality, properly documented, secure, preserved, sustainable, and where possible, accessible and reusable. It also outlines how the FAIR principles align with any applicable legal, ethical, or commercial constraints.

DMP timeline

• Proposal stage: a formal DMP is not required but a short (typically one-page) DMP-like document is required as part of the proposal. Note that in cases of a public emergency, and where required by the Work Programme, a full DMP may be required at proposal submission or by grant signature.
• Project implementation: a full initial version of the DMP must be submitted as a project deliverable, normally by month 6.
• During the project: the DMP is a living document and must be regularly updated to reflect changes in data generation, reuse, access conditions, repositories, or decisions taken. For projects lasting longer than 12 months, at least one updated version must be submitted as a deliverable.
• End of the project: a final DMP must be delivered, describing how the data have been managed, preserved, and shared.

Whenever possible, beneficiaries are encouraged to make DMPs publicly available as non-restricted deliverables, under open access and a CC BY licence, to support reuse. This may be done by uploading the DMP on a trusted repository (e.g. Zenodo), which will make it available on the CORDIS website.

What to include in a DMP?

Horizon Europe provides a recommended DMP template, which beneficiaries are encouraged, but not required, to use.

To support both proposal preparation and DMP development, beneficiaries may use ARGOS, OpenAIRE’s free and open-source online tool for creating and publishing DMPs. ARGOS offers templates aligned with Horizon Europe requirements, together with contextual guidance for each section.

Trusted repositories

Trusted repositories are infrastructures that provide reliable and long-term access to digital resources such as data, publications, etc. Usually, these repositories go through assessment or certification processes to guarantee that certain quality criteria are met.

In Horizon Europe, the following are considered trusted repositories:

• Certified repositories, for example those with CoreTrustSeal, Nestor Seal DIN31644, or ISO16363 certifications.  
• Domain-specific repositories that are internationally recognised, commonly used and endorsed by the research communities relevant to your project.
• General-purpose repositories or institutional repositories that, without official certification, present the essential characteristics of trusted repositories (e.g. security provisions, services for the creation of machine actionable metadata, long-term preservation of data, etc.).

You can find more information on how to find a trustworthy repository for your data on our dedicated page.

When should data be deposited?

In Horizon Europe, data should be deposited as soon as possible after its generation and, at the latest, by the end of the project.

There are, however, some additional requirements:

• Data underpinning a scientific publication should be deposited at the latest at the time of publication, and in line with standard community practices.  
• In cases of public emergency, if requested by the granting authority, immediate open access should be provided. If exceptions to open access to data apply, data should be made available at least to the legal entities that need the data to address the public emergency.
• In exceptional cases, data can be deposited after the project has finished.

'As open as possible, as closed as necessary'

In Horizon Europe, research data should be made open access by default and licensed under the latest version of CC BY (attribution required) or CC0 (public domain), or equivalent.

However, it is recognized that data should be ‘as open as possible, as closed as necessary’, and exceptions can be made when providing open access to data:

• Is against the beneficiary’s legitimate interests, including regarding commercial exploitation;
• Is contrary to any other constraints, such as data protection rules, privacy, confidentiality, trade secrets, Union competitive interests, security rules, intellectual property rights or;  
• Would be against other obligations under the Grant Agreement. 

In such cases, data can be kept restricted, closed or under embargo, but beneficiaries must explain in the DMP the legitimate exception(s) under which they choose to restrict access to (some of the) research data. 

Find more information on How do I know if my research data is protected? 

Metadata compliance

Horizon Europe requires that, when you deposit data in a trusted repository, this should be described with rich metadata in line with the FAIR principles. In practice, this means that you should choose a repository that has a number of mandatory and recommended metadata fields. 

Metadata should:

• At least include the following fields: author(s), dataset description or abstract, date of dataset deposit or publication date, dataset deposit venue, dataset license (CC0 or CC BY by default) and dataset embargo period (if any).
• Also include information about Horizon Europe or Euratom funding: grant project name, acronym and number. Ideally, the repository will have dedicated fields for this information. If not, you can include them in other appropriate fields, such as the abstract.
• Be open access under a CC0 licence or equivalent. This is also recommended in cases where data must be closed or restricted but there are no compelling reasons for metadata not to be findable and accessible.

Most (trusted) repositories will require that you fill in a metadata form about the data or files that you will publish, which should cover these requirements.

For additional information, you can check the page on metadata.

IMPORTANT!

The European Research Council (ERC) requested in 2023 an analysis of the ‘metadata readiness’ of repositories (Lazzeri 2024). Only five repositories (<intR>²Dok, DANS, HAL, and Zenodo), met the “Essential” readiness level requirements. Many other repositories were at a “Close-to-Essential” level, and were making modifications to add the missing metadata fields. 

In practical terms, you need to check directly with your repository whether they have all the mandatory metadata fields required by the European Commission. If not, one work around is to deposit your data in Zenodo (for HE compliance) and a subject-specific or your institutional repository (to improve visibility and discoverability, and a better community engagement and networking).

Horizon Europe requires that, at the time of depositing research data in a trusted repository, you must also provide access (via the repository) to information about any research output or any other tools or instruments needed to re-use or validate the research data.

• “Research outputs, tools and instruments” may include data, software, algorithms, protocols, models, workflows, electronic notebooks and others.
• What type of information should be provided? A detailed description of the research output/tool/instrument, how to access it, any dependencies on commercial products (e.g. software), potential version/type, potential parameters, etc.
• Besides information about these outputs, beneficiaries are encouraged to provide open (digital) access to the research outputs, tools and instruments themselves unless legitimate interests or constraints apply.

Typically, the repository will allow you to provide links to relevant information (e.g. links to related publications, to a code repository, to related datasets, etc.).

Research Data Management activities need to be costed into research, in terms of the time and resources needed. By planning early, costs can be significantly reduced. Under Horizon Europe, eligible costs are governed by the Grant Agreement rules (Article 6.2 and general eligibility principles); they must be actual, incurred by the beneficiary, necessary for the action, recorded in accounts, and incurred during the action (with limited exceptions e.g. final reporting). They must be foreseen in the project budget/Description of Action and incurred during the duration of the project.

To estimate costs for RDM, you can check the online RDM-costing tool and the infographic on ‘What will it cost t o manage and share my data?’.

Webinar

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• Recording (03/04/2026 session)

Interactive guide

https://openplato.eu/mod/scorm/view.php?id=1250

The following additional support materials can help you with the RDM requirements in Horizon Europe projects:

• Open Science in Horizon Europe proposal [guide]
• Horizon Europe OA to publications [guide]
• What will it cost to manage and share my data? [infographic]
• How to make your data FAIR [guide]
• Data formats for preservation [guide]
• How to deal with non-digital data [guide]
• How to deal with sensitive data [guide]
• Raw data, backup and versioning [guide]
• How to find a trustworthy repository for your data [guide]

OpenAIRE also offers tools for research data management: ARGOS is an OpenAIRE service that simplifies the management, validation, monitoring and maintenance of DMPs. [tool]

Links and further information

The following sources were used and contain more extensive information on how to address open science in Horizon Europe proposals:

• European Commission, Horizon Europe Programme Guide (contains a dedicated section on open science on page 38)   
• European Commission, Horizon Europe Programme Standard Application Form (HE RIA, IA)  
• European Commission, EU Grants. AGA- Annotated Model Grant Agreement

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Links and further information

The following sources were used and contain more extensive information about Research Data Management, and how to address Open Science in Horizon Europe proposals:

• European Commission, Horizon Europe reference documents
• European Commission, Horizon Europe Programme Guide (contains a dedicated section on Open Science in Article 17)   
• European Commission, Horizon Europe Programme Standard Application Form (HE RIA, IA)  
• European Commission, EU Grants. AGA - Annotated Model Grant Agreement
• European Commission, Data Management Plan Template
• European Research Council, Managing your project - Open Science
• European Commission, EC Participant Portal - ‘Continuous reporting’ guide
• MSCA, Information package for MSCA
• MSCA, Financial Guide (6.4) for MSCA