On January 15, 2025, OMB released guidance to agencies on implementation of the Open, Public, Electronic, and Necessary (OPEN) Government Data Act, also known as Title II of the Foundations for Evidence-Based Policymaking Act of 2018. OMB Memorandum M-25-05, “Phase 2 Implementation of the Foundations for Evidence-Based Policymaking Act of 2018: Open Data Access and Management,” outlines a systematic approach to open data that will better facilitate data access, subject to appropriate safeguards for privacy, confidentiality, and security. The guidance addresses requirements in the OPEN Government Data Act related to agency data being open by default, maintenance of agency comprehensive data inventories, dissemination of agency data via the Federal Data Catalog, maintenance of agency open data plans, and agency engagement with the public. It also provides guidance on open data access and management under the OPEN Government Data Act.