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Beginning on or before 31 December 2025, all recipients of United States federal research funding will be required to make their federally funded scholarly outputs, including scientific data, freely available via public access venues with no delays or embargos. This paper focuses on research data as one of the key scholarly output types impacted by the requirements outlined in the Memorandum on Ensuring Free, Immediate and Equitable Access to Federally Funded Research issued by the US Office of Science and Technology Policy (OSTP), commonly called the “Nelson memo”. This paper sets out working definitions of four key terms: cost, price, reasonable, and allowable. Using these terms, we describe some of the pathways research data take to final publication, and summarize some of the extensive body of research on the costs of research data curation and sharing. In the process, we look at cost modelling experimentation in the fields of research data management and digital preservation to consider what might be relevant from their approaches. 

Beginning on or before 31 December 2025, all recipients of United States federal research funding will be required to make their federally funded scholarly outputs, including scientific data, freely available via public access venues with no delays or embargos. This paper focuses on research data as one of the key scholarly output types impacted by the requirements outlined in the Memorandum on Ensuring Free, Immediate and Equitable Access to Federally Funded Research issued by the US Office of Science and Technology Policy (OSTP), commonly called the “Nelson memo”. This paper sets out working definitions of four key terms: cost, price, reasonable, and allowable. Using these terms, we describe some of the pathways research data take to final publication, and summarize some of the extensive body of research on the costs of research data curation and sharing. In the process, we look at cost modeling experimentation in the fields of research data management and digital preservation to consider what might be relevant from their approaches.