The ExPaNDS project is the European Open Science Cloud (EOSC) Photon and Neutron Data Service: a collaboration, funded by the Horizon 2020 programme, between ten national Photon and Neutron Research Infrastructures as well as EGI, an e-infrastructure that provides advanced computing services for research. These research infrastructures are exemplars of “facilities science”, providing specialised instruments and techniques for use by researchers from a wide range of fields. One strand of work in the project is on “Enabling FAIR data for photon and neutron national research infrastructures”, and includes development of a data policy framework to allow the facilities to adopt a coherent approach to FAIRness of the data that they generate. The activity examined here concerns revisions to the ExPaNDS data policy framework presented in the project’s Final data policy framework for Photon and Neutron RIs. The earlier draft policy framework (ExPaNDS deliverable D2.1: Draft extended data policy framework for photon and neutron RIs) had been published in September 2020, and drew on the FAIRsFAIR Policy enhancement recommendations. Before that, there had been joint work with the PaNOSC project, which had produced its own data policy deliverable in May 2020. However it became apparent that ExPaNDS partners were keen to explore the various themes of the data policy framework in more depth, especially with a view to providing greater flexibility in approach, so a programme of consultations with each of the ten ExPaNDS partner facilities was undertaken.