Demonstrating Compliance Retrospectively

If your article has already been published and you are in non-compliance with the NIH Public Access Policy, you will need to immediately follow the steps outlined below to bring your article(s) into compliance. 

Contact the Journal

The first step you take should be to contact the journal (usually you can contact the editor with whom you have communicated previously) and request permission (it is best if the permission is in writing) to deposit the manuscript into NIHMS-PubMed Central PMC.  Even if the publisher offers to upload the article for you, in the interest of timeliness, it is suggested that you instead upload the manuscript yourself.

Determine the Embargo

While you communicate with the publisher, determine the embargo period, if any, that still applies to the published article. This is important to determine because when you upload your Author Accepted Manuscript (AAM) to NIHMS, you are required to provide an embargo period; this will determine when your article will be publicly available via PubMed Central. For articles deposited in PubMed Central, this embargo period may last no longer than one year from the official date of publication. If your article was published more than a year previous, no embargo period will apply to the publication. 

For papers accepted for publication on/after July 1, 2025, there is no embargo period; AAMs are to be made publicly available on the official date of publication (with “zero embargo”). 

Double-check Copyright

Double-check that the copyright agreement that you signed with the publisher allows for NIH Public Access Compliance. If not, you will want to address this with the publisher.

Determine Responsibility

Are you the only author on this publication? If not, then multiple investigators will be listed as non-compliant, and it will speed the process of compliance if a single person is determined responsible for bringing the article into compliance. NIHMS will not allow duplication of manuscripts in the system, so there are no compliance issues surrounding multiple uploads; however, there is no reason to duplicate efforts.

Deposit the Manuscript Via Method C

Submitting a final peer-reviewed manuscript to PubMed Central (PMC) via the NIHMS involves three tasks, as explained below.  Task 1 may be done by an author or by someone in the author’s organization (e.g., an assistant or a librarian).  Tasks 2 and 3 must by done by the author.

A Note on Timing: NIH awardees are responsible for ensuring that manuscripts are submitted to the NIHMS upon acceptance for publication and that all NIHMS tasks are complete within three months of publication.

For more infomation on using the NIH Manuscript Submission (NIHMS) system, see the 'NIHMS System' page in this guide.

Task 1: Deposit Manuscript Files and Link to NIH Funding 

Upload a copy of the accepted final peer-reviewed manuscript and associated files (e.g., Microsoft Word document and figures) via the NIHMS.  At the same time, identify the NIH funding associated with the manuscript.  It usually takes less than 10 minutes to complete this task.

Task 2: Authorize NIH to Process the Manuscript

The author designates the number of months after publication when the manuscript may be made publicly available in PMC (also known as the embargo period).  The author then confirms, via the NIHMS, a statement that the deposit of the manuscript is consistent with any publication and copyright agreements, and that NIH may begin processing the manuscript for use in PMC.

Task 3: Approve the PMC-formatted Manuscript for Public Display

The NIHMS will convert the deposited files into a standard PMC format, and email the author to approve the PMC-formatted manuscript for public display. The author then reviews and approves the PMC-formatted manuscript via the NIHMS. Corrections to the manuscript, if necessary, may be requested at this time.  

Following completion of Task 3:

• The NIHMS will email the author and all PIs the citation with the PMCID once it is assigned;
• PMC will automatically make the paper publicly available after the designated delay period has expired.

For a video of this process, see NIH Manuscript Submission (NIHMS): Deposit and Initial Approval (YouTube Video - 6:14).