Staff Interpretations and FAQs Related to Interactive Data Disclosure

June 6, 2024

From time to time, the staff of the Division of Economic and Risk Analysis (DERA) will publish interpretations and FAQs to help filers understand how to comply with the Commission's interactive data disclosure rules.

For further information, please also review the Division of Corporation Finance's Compliance and Disclosure Interpretations for Release 33-9002.

The DERA staff have prepared the following responses to questions about EDGAR submissions with eXtensible Business Reporting Language (XBRL) data and expect to update from time to time our responses to additional questions. These responses represent the views of the DERA staff. They are not a rule, regulation, or statement of the Securities and Exchange Commission (Commission). The Commission has neither approved nor disapproved its content. These responses, like all staff statements, have no legal force or effect: they do not alter or amend applicable law, and they create no new or additional obligations for any person.

FAQ's

A. Validation

Question A.1 (Reserved)

Question A.2

Q: How does the Electronic Data Gathering Analysis and Retrieval (EDGAR) validator validate HTML embedded into Block Text?

A: In all SEC submissions and attachments, EDGAR rejects HTML that does not conform to the EDGAR-specific restriction of HTML 3.2 or 4.0 Document Type Definition (DTD), in particular rejecting anything that could pose a security threat to a recipient. On that general principle, the EDGAR Validator analyzes Interactive Data content that, when processed, may be interpreted as HTML, and will reject it if it contains content that the existing DTD would reject. EDGAR XBRL Guide section 9.1 addresses this. Note that Block Text content must also be well formed eXtensible Markup Language (XML) as described there. This is a stronger requirement than validating against the EDGAR HTML 3.2 or 4.0 DTD.

Question A.3

Q: How can I tell whether a warning or an error from my test filing validation is related to eXtensible Business Reporting Language (XBRL) and what would have happened if the filing had been live?

A: In general, an EDGAR filing can be accepted even if some of its attached exhibits have errors. Exhibits that have errors are removed from the filing (“stripped”) before it is accepted into EDGAR. However, primary documents, such as the “10-K” attachment to submission type “10-K,” with errors (such as invalid HTML) will always result in filing suspension.

If a submission has an Inline XBRL primary document with an XBRL error, EDGAR will suspend the entire submission. See section 5.2.5 of the EDGAR Filer Manual (Volume II) for more information.

Some exhibits are XBRL files. Therefore, an error message that reads “WRN: XBRL Error” means that those files will be stripped from a live filing, but the rest of the filing will generally be accepted into EDGAR. If this happens, the filer must submit an Amendment with the corrected XBRL.

A message that reads “WRN: XBRL Warning” means that there is a less severe error in the XBRL data, but the XBRL file will not be stripped. We encourage filers to fix the warnings in their subsequent filings.

A message that starts with “ERR:” or “WRN:” but does not mention XBRL is not an XBRL problem, and is due to some other aspect of the submission.

B. Presentation and Rendering — All Submissions

Question B.1

Q: Can I still view submissions made under the Voluntary Filing Program?

A: No. The older Voluntary Filing Program Data Viewers are separate from the Interactive Data Viewer and are no longer supported.

Question B.2 (Reserved)

Question B.3

Q: How do I ensure that a statement renders with periods as rows rather than as columns, with a specific axis as columns, ignoring some axis, or other arrangements?

A: Section 7 of the EDGAR XBRL Guide contains rules oriented toward rendering, including restrictions on statement rendering. Some special treatments are allowed for the Cash Flow Statement (section 7.12) and the Statement of Changes in Shareholder Equity (section 7.13).

Question B.4

Q: Do operating company financial statements and fund prospectus risk/return summary submissions need to be in Inline XBRL?

A: Yes. All relevant phase-in periods ended in September 2021. See Release No. 33-10514 and 17 CFR 232.405(f) for additional details.

Question B.5 (Reserved)

Question B.6

Q: How do I arrange for facts with different types to appear on the same row?

A: Please refer to EDGAR XBRL Guide section 7.6, "Merged Columns."

Question B.7

Q: I got some of the label linkbases for my submission from a site that used xml:lang="en" instead of xml:lang="en-US", will they render correctly?

A: Please refer to EDGAR XBRL Guide section 9.2, "Labels."

Question B.8

Q: Why is some of my escaped HTML rendering as raw HTML?

A: Make sure that the embedded HTML appears inside of elements whose type is dtr-types:textBlockItemType. It is not enough for the element name to end with "TextBlock." Different versions of the US GAAP Financial Reporting taxonomy (GAAP taxonomy) may have more or less consistent element naming conventions, but it is the element type that is important, not the element name.

Question B.9 (Reserved)

Question B.10

Q: What does it mean for the presentation to "match" the original HTML/ASCII document?

A: For a taxonomy that requires the use of specific presentation links (for example, the Self-Regulatory Organization (SRO) taxonomy) see the associated Taxonomy Guide for description of any filer-controlled presentation decisions. In custom taxonomies, as defined in the EDGAR XBRL Guide chapter 5, the presentation relationships within a custom role should be the same as the ordering in the Related Official Document as defined in the EDGAR XBRL Guide section 6.1. EDGAR XBRL Guide chapter 6 describes several different tagging decisions that affect whether the presentation will match, and chapter 7, particularly sections 7.11, 7.12, and 7.13, describe features of the renderer that will affect appearance of financial statement data.

Question B.11

Q: How do I make a text block appear by itself in a presentation link role as EDGAR XBRL Guide section 6.7.1 seems to require? Do I have to provide a heading?

A: The way to satisfy these rules is to use an abstract to be the parent of the text block, in each of the separate roles. For example,

  • 06100 — Disclosure — Business Segments (Level 1) Segment Disclosure [Abstract] + Segment Disclosure [Text Block]
  • 06101 — Disclosure — Oil Reserves (Level 1) Oil Reserves Disclosure [Abstract] + Oil Reserves Disclosure [Text Block]

And so on.

Question B.12

Q: Should filers use a certain naming convention for presentation group titles?

A: Sections 7.12, 7.13 and 10.2 of the EDGAR XBRL Guide define these conventions.

Question B.13

Q: Should filers use a certain ordering convention for presentation groups?

A: Section 7.2 of the EDGAR XBRL Guide addresses presentation groups, including rules around ordering.

Question B.14(Reserved)

Question B.15

Q: When tagging a line item with multiple text descriptions in the original HTML presented in a roll forward for 3 years, the line item element requires three different negating labels which limit the available label roles, does EDGAR XBRL Guide section 5.10.1 last paragraph still apply?

A: Yes, to accommodate this scenario, merge the text from the three periods in a way that is readable and does not lose any information.

C. Presentation and Rendering — Risk/Return Summaries

Question C.1

Q: Is there any guidance published by the SEC on XBRL for Risk/Return Summary disclosures?

A: Yes. The Risk/Return Summary disclosure guidance is included in the Open-End Fund (OEF) taxonomy guide. Please visit https://www.sec.gov/data-research/standard-taxonomies/investment-companies for the latest OEF taxonomy guide.

D. Standard Taxonomies

Question D.1

Q: Which files from a standard taxonomy can an Interactive Data submission refer to?

A: The schema files of a taxonomy that define elements, types or roles, and that may have embedded linkbases with calculation, definition, label, and presentation relationships are listed on the SEC website https://www.sec.gov/data-research/standard-taxonomies as soon as the taxonomy is available for use in EDGAR.

See EDGAR XBRL Guide chapter 6 for an overview of the relationship between filer type, submission type, attachment type, and taxonomy entry points.

Question D.2 (Reserved)

Question D.3 (Reserved)

Question D.4

Q: Do all the rules in EDGAR XBRL Guide apply to the standard taxonomies?

A: No. The rules in EDGAR XBRL Guide apply to company extensions and instances. Although the standard taxonomies are consistent with many of the EDGAR XBRL Guide rules, here are some exceptions:

  • File names, namespaces, schemaLocation and xlink:href attributes of a standard taxonomy are not restricted by any of the EDGAR XBRL Guide rules.
  • Element declarations: A standard taxonomy might include elements that do not follow the LC3 naming convention, non-numeric types with period type “instant”, or other variations.
  • Role declarations: A linkbase xlink:role might be defined as being used on only one type of linkbase instead of all three, or its “description” field may vary from what custom taxonomies may use.
  • Linkbases: Although always valid with respect to XBRL International recommendations, there may be any number of EDGAR XBRL Guide violations.

Please refer to EDGAR XBRL Guide section 10.1, “Custom Namespace and Role URLs,” section 10.2, “Roles” and section 8.7, “Element Attribute Values” for more information.

Question D.5

Q: Does EDGAR forbid the use of “prohibited” arcs because such an arc would then cause some arc to be “ineffectual?”

A: This restriction applies only to arcs in the company extension taxonomy. See validation checks in EDGAR XBRL Guide section 10.4. If the company extension taxonomy has a “prohibiting” arc that prohibits an arc in a standard taxonomy, then it's the standard taxonomy that has the “ineffectual” arc, not the company extension. In practice, arcs in a standard taxonomy usually have priority=10 meaning that in EDGAR they cannot be overridden at all.

Question D.6

Q: EDGAR XBRL Guide section 3.1 discusses expected facts in the required context. One of these elements in the required context is “Document Fiscal Period Focus.” What values should filers use for this element?

A: Please refer to EDGAR XBRL Guide section 3.1.8, “Document Fiscal Year and Period Focus.”

Question D.6.1

Q: I am preparing a FORM 10-KT for a period other than 12 months (e.g., 1/1/2012 thru 8/31/2012), should I use “FY” for the DocumentFiscalPeriodFocus?

A: Yes.

Question D.7

Q: I am preparing a company's FORM S-4 that also includes XBRL for the acquiring company. Should I include the EntityCentralIndexKey element with our CIK number for the acquiring company?

A: You must provide one EntityCentralIndexKey element in the required context and it should be for the parent (consolidated) company. Note that required contexts are distinguished by having no xbrli:segment elements (i.e., no dimension members).

Question D.8

Q: Once a new taxonomy (e.g., US GAAP taxonomy) is approved and available for use, when should a filer make the transition to the new version?

A: Updates to the U.S. GAAP Taxonomy are subject to accounting standard changes and taxonomy improvements. In general, we support only two versions of the U.S. GAAP Taxonomy at one time. Indication that the updated taxonomy is available for use will be made via the standard taxonomies page at https://www.sec.gov/info/edgar/edgartaxonomies.shtml. The SEC staff strongly encourages filers to use the most recent version of any taxonomy release for their Interactive Data submissions to take advantage of the most up to date tags related to new accounting standards and other improvements.

Whether a submission uses the current year version or prior year version of the U.S. GAAP Taxonomy, the version of other taxonomies used in the submission must be compatible. In general, that would mean the same version year as the U.S. GAAP Taxonomy. The only exception to this compatibility rule is the time period between EDGAR’s acceptance of the new U.S. GAAP Taxonomy and other SEC taxonomies for that year, and the new International Financial Reporting Standards (IFRS) Taxonomy for that year, due to the IFRS Taxonomy being accepted in EDGAR at a different date.

Question D.9

Q: Where is the information on compliance dates for XBRL tagging?

A: Compliance requirements for any given filer may depend on considerations of filer type, size, fiscal year end, prior registration under the ’33, ’34, or ‘40 acts, and many other details, and this information is found in the relevant rule release text. To avoid redundancy, discrepancies and frequent updates, details about compliance dates are not repeated in EFM chapter 6, the EDGAR XBRL Guide, nor in taxonomy guides.

Question D.10 (Reserved)

Question D.11 (Reserved)

Question D.12 (Reserved)

Question D.13 (Reserved)

Question D.14

Q: Sometimes the sample instance zip files only contain the schema and HTML, and do not include linkbases. Is this the only acceptable way to file? Can filers continue to file with linkbases, and if so, for how long?

A: As long as the linkbases follow sections 5 (Custom Taxonomies) and 10 (Validation Details on Custom Taxonomies) of the EDGAR XBRL Guide, filing with linkbases is allowed.

Question D.15 (Reserved)

Question D.16 (Reserved)

Question D.17 (Reserved)

Question D.18 (Reserved)

Question D.19 (Reserved)

Question D.20 (Reserved)

Question D.21 (Reserved)

Question D.22

Q: If a closed-end fund has risk factors that are not considered principal risk factors to the fund, do those non-principal risk factors have to also be tagged?

A: Item 8.3.a of Form N-2 requires funds to discuss the principal risk factors associated with an investment in the fund specifically, as well as factors that are generally associated with investment in a fund with investment objectives, investment policies, capital structure, or trading markets that are similar to the fund’s. General Instructions I.2 and 3 of Form N-2 require information provided in response to Item 8.3.a to be tagged. Therefore, to the extent that any non-principal risk factors are disclosed in response to Item 8.3.a, the fund would need to tag those.

E. Company Extensions and Instances

Question E.1

Q: Characters that are "special" are forbidden by EDGAR Filer Manual (Volume II) 5.2.2.1 and 7.3.4.3 but they appear in the Original HTML/ASCII, so how do I get them into labels?

A: Use the XML numeric character codes from the column titled Character Reference (Dec) of the table in EDGAR Filer Manual (Volume II) section 5.2.2.6.

Question E.2

Q: What does it mean for an element label to be "the same" as the original HTML/ASCII document?

A: EDGAR XBRL Guide (EXG) section 5.10.1 last paragraph states this more precisely. Roughly speaking, all the contents of the Related Official Document (EXG section 6.1) must appear somewhere in the EX-101 attachments, and all contents of the EX-101 attachments must appear somewhere in the Original. The rules adopted in Release 33-9002 do not require identical appearance, and neither does the EXG. See EXG section 6.5 for additional discussion on the relationship of the concept being tagged and its custom label.

Question E.3

Q: Am I required to use existing linkbase roles or make up my own? Can they change with every submission?

A: Filers should develop an ordering and naming scheme that is appropriate to the organization of their Related Official Document while supporting a sensible (though obviously not identical) rendering. That implies filer-specific roles. Changing the roles frequently is akin to frequently changing the elements used in the instance: there is no rule against it, but given such freedom to define the roles at the outset, a reasonable amount of forethought should lead to a stable arrangement.

Question E.4 (Reserved)

Question E.5 (Reserved)

Question E.6

Q: The submission I am tagging requires the public float, so what context should I use?

A: Please refer to EDGAR XBRL Guide section 3.1.15, “Public Float.”

Question E.7

Q: Am I required to put in a value for AmendmentDescription when I set the value to true for the AmendmentFlag?

A: Yes. AmendmentDescription should be a nonempty fact if and only if the AmendmentFlag is set to true. See EDGAR XBRL Guide section 3.1.6.

Question E.8 (Reserved)

Question E.9

Q: Can the content of a text block be in a language other than US English (“en-US”)?

A: Yes; however, EDGAR XBRL Guide section 9.9 requires instances containing a fact in a language other than US English must also contain a fact using the same element and all other attributes with an xml:lang attribute equal to “en-US.” For example, an US English fact can appear in an instance without the French fact, but the French fact cannot appear without the US English fact.

Question E.10

Q: Since the target of the dimension-default and dimension-domain relationships must be a domain or member, why not also the domain-member relationship?

A: That restriction would not work because the domain-member relationship also represents the hierarchy of primary items that are not themselves members.

Question E.11

Q: Does EDGAR allow for multiple dimension-default effective arcs in distinct extended-type links as long as they all have the same source and target?

A: They would be redundant, because the dimension-default arc affects the entire DTS, not just the link they appear in. XBRL Dimensions 1.0 specification would require a validation error to be signaled if the targets were different, no matter in which link role they appeared. Furthermore, if the duplicated arcs had the same link role and priority one of them would be ineffectual and thus forbidden. See EDGAR XBRL Guide section 10.4.

Question E.12 (Reserved)

Question E.13

Q: One of the validation checks in EDGAR XBRL Guide section 10.2 is the DTS does not contain more than one link:roleType having the same roleURI attribute value. It seems redundant with XBRL 2.1's prohibition on duplicate role declarations.

A: XBRL 2.1 forbids duplicate role declarations in a schema file; EDGAR XBRL Guide section 10.2 applies to the entire DTS.

Question E.14

Q: Does EDGAR XBRL Guide section 5.6.2’s discussion around the use of an updated namespace contradict Rule 405(c)(1) of Regulation S-T (17 CFR §232.405(c)(1)), which requires each data element and label contained in the Interactive Data File to reflect the same information in the corresponding data in the Related Official Filing?

A: No. The use of the same element’s local name in a subsequent version of a namespace is not considered “different” for purposes of complying with Rule 405(c)(1) of Regulation S-T.

Question E.15

Q: Should elements for line items appearing with a dash ("-") in the original HTML/ASCII version be tagged with a "0"?

A: Please refer to EDGAR XBRL Guide section 6.8.1.10, “Dashes.”

Question E.16

Q: Should filers use the pre-defined table structures and axes in the U.S. GAAP Taxonomy?

A: We strongly recommend that filers utilize the pre-defined table definition and presentation links and axes as they exist in the U.S. GAAP Taxonomy. Creating new hypercubes (tables) and dimensions (axes) should generally be avoided. Custom tables and axes have a negative impact on analysis of the financial information affecting comparability and should be avoided wherever possible. In addition, filers should also avoid creating new domains or changing default member elements for pre-defined dimensions.

For example, when filers are tagging a Property, Plant and Equipment note at Level 4, they should copy the pre-defined dimensional Property Plant and Equipment [Table], and axes, from the U.S. GAAP Taxonomy linkbase; extending members or line items only when necessary.

Question E.17

Q: What are some of the nuances associated with preparing an interactive data file in situations involving separate entities filing a single set of financial statements, where multiple CIKs are concerned, such as by a filer who is a consolidated parent company with wholly-owned subsidiaries (which have their own CIKs), or by dual listed companies with their own CIKs?

A: Please refer to EDGAR XBRL Guide section 6.2, “Entities in Instances.”

Question E.18

Q: Can I report the CIKs associated with the various subsidiaries as referred to in Question E.17?

A: Please refer to EDGAR XBRL Guide section 6.2.7, “Dual (or multiple) Registrants.”

Question E.19

Q: What context period should be used for an event that occurred during the second quarter for a 12/31 fiscal year end registrant?

A: Please refer to EDGAR XBRL Guide section 6.3.2, “Reporting Periods for Non-numeric Facts.”

Question E.19.1

Q: What context period should be used for a duration element when the actual date is specified (e.g., "on Sep 14, 2021")?

A: A duration period may use any period that EDGAR validation will allow (see validations in section 9.7 of the EDGAR XBRL Guide) and whose end date reflects the specified date.

Question E.20

Q: EDGAR XBRL Guide section 5.6.3 prohibits the use of company-specific or period-specific information in element names. Does this apply to all item types?

A: EDGAR XBRL Guide section 5.6.3 applies to elements with item types other than “domainItemType.” Elements with other item types, including (but not limited to) monetary, percent, integer, shares, per share, string, or text block item types, should not include company-specific or period-specific information in the element name. Domain members may include company-specific or period-specific information in the element name.

For example, filers should not create a monetary element with the name "AcquisitionOfDefCo" or "FourthQuarterAdjustment." However, they may create a domain member with the name "AbcSegmentMember."

Question E.21

Q: What are the rules around using unit types in an Interactive Data filing?

A: See section 9.8 of the EDGAR XBRL Guide for the unit type registry restrictions.

Question E.22

Q: Can an interactive data submission contain more than one EX-101.* attachment of any given type?

A: Please refer to EDGAR XBRL Guide section 8.1, “File names and Character Encodings.”

Question E.23 (Reserved)

Question E.24

Q: Are calculations allowable for elements with amounts outside of a “required context”?

A: Please refer to EDGAR XBRL Guide section 5.9, “Custom Calculation Relationships for Standard Concepts.”

Question E.25

Q: My Form10-K includes line items in the original HTML/ASCII that come under the EDGAR XBRL Guide section 5.9. However, those same line items are presented in both a primary statement and a footnote. Furthermore, the footnote contains additional line items which are not found in the primary statement. Will a single set of calculation linkbase relationships which include all required line items in the footnote satisfy the EDGAR calculations requirements for both sets of items?

A: Please refer to EDGAR XBRL Guide section 5.9, “Custom Calculation Relationships for Standard Concepts.”

Question E.26

Q: If a company changes its name or ticker symbol, should the XBRL file names and recommended namespace prefix be changed to conform to the new name?

A: Please refer to EDGAR XBRL Guide section 8.1, “File names and Character Encodings.”

Question E.27

Q: What are the conditions for determining when a calculation relationship is required?

A: Please refer to EDGAR XBRL Guide section 5.9.1, “When Calculation Relationships are Required.”

Question E.28

Q: Form 11-K is used for annual reports pursuant to Section 15(d) of the Securities Exchange Act of 1934 with respect to employee stock purchase, savings and similar plans (collectively, “Plans”). All financial statements and schedules required to be included on this report must be provided as an Interactive Data File in accordance with Rule 405 of Regulation S-T, beginning with filings made on or after July 11, 2025.

When filing a Form 11-K, a Plan must use the CIK of the issuer of the securities held pursuant to the Plan (the issuer is identified under Part B on the cover page of Form 11-K). Because a Plan does not have its own CIK or Commission file number, how should the Plan distinguish between the values tagged for the issuer and the values to be tagged for the Plan?

A: Please refer to EDGAR XBRL Guide section 3.2.7, “Employee Benefit Plans” and section 6.2.8, “Employee Benefit Plan-specific Members.”

F. Detail Tagging

Question F.1

Q: Should the formatting of footnote tables that result from tagging at Level 4 match exactly the format presented in the original HTML/ASCII version?

A: Please refer to EDGAR XBRL Guide section 6.8.4, “Level 4 (Detail) Tagging.”

Question F.2

Q: Does the EDGAR XBRL Guide section 5.6.3 limiting the use of company-specific elements apply to tagging at Levels 2, 3, and 4?

A: Yes, but see the clarification in Question E.20.

Question F.3

Q: Outside of the primary financial statements, is superscripted text at the bottom of a footnote table allowed to be included in an XBRL footnote link element?

A: Please refer to EDGAR XBRL Guide section 6.8.3, “Level 3 (Table) Tagging.”

Question F.4

Q: When tagging a narrative disclosure using "no" or "none" such as "There were no impairment losses for the years ended December 31, 2012, 2011, and 2010, respectively," should a value of zero be tagged for each of the disclosed periods?

A: In general, if you can replace the word "no" or "none" with a zero and it does not change the meaning of the sentence, then you are disclosing an amount. From Compliance and Disclosure Interpretations - Regulation S-T Question 130.04 - “Each amount, whether expressed numerically or textually, must be tagged separately under Rule 405(d)(4)(i). This guidance also applies to tagging each amount within the financial statement schedules under Rule 405(e)(2)(i) of Regulation S-T. Each tagged amount must be mapped to the applicable monetary, decimal, percent, integer or shares data type element.”

Question F.5

Q: When tagging a single value that represents two separate facts with the same value, should two individual elements be used to tag the value separately?

A: Please refer to EDGAR XBRL Guide section 6.7.9, “Multi-tagging.”

Question F.6

Q: Release No. IC-33836 states that “[a] seasoned fund filing a short-form registration statement on Form N-2 also will be required to tag information appearing in Exchange Act reports— such as those on Form N-CSR, 10-K, 10-Q, or 8-K—if that information is required to be tagged in the fund’s prospectus.” If such information is included in the Form 10-K or Form 10-Q outside of the financial statements and notes (for example in item 5), is it still required to be tagged?

A: Yes. General Instruction I.3 of amended Form N-2 does not limit this requirement to only information included in financial statements and notes. Regardless of where information provided in response to the specified disclosure items appears in a A.2 Qualified fund’s Exchange Act reports, whether in Forms 10-K or 10-Q (or any other document filed pursuant to Sections 13(a), 13(c), 14, or 15(d) of the Exchange Act that is incorporated by reference into the Form N-2 registration statement that contains the specified disclosures), it is required to be tagged.

Question F.7

Q: Is tagging the Schedule of Investments for BDCs required or optional? If required, should the schedule be detail tagged for every fact reported?

A: Rule 405(e) of Regulation S-T describes the tagging requirements for financial statement schedules, which includes a fund’s Schedule of Investments, pursuant to certain rules under Articles 6 and 12 of Regulation S-X. Accordingly, a BDC must tag its Schedule of Investments (SOI) consistent with the tagging requirements in Rule 405(e) of Regulation S-T, which include detail (i.e., separate) tagging of each amount (i.e., monetary value, percentage and number) within each schedule.

It is the staff’s view that detail tagging nonnumeric facts disclosed in the table of the SOI would improve the usefulness of the data. Examples of nonnumeric facts include acquisition dates, maturity dates, investment issuer, industry, and base reference rate (e.g., SOFR). For tagged dates, including the month, day, and year would also improve the usefulness of the data.

FASB GAAP Taxonomy Implementation Guide Series – Financial Services – Investment Companies (Including SEC S-X Schedules for Business Development Companies) provides examples of the modeling for reporting by investment companies, including the SOI.

Question F.8

Q: Does each risk factor have to be tagged separately? It appears this way in the examples provided in the 2021Q4 CEF taxonomy package. If so, our assumption is that every risk factor will need to be created as a custom extension domain member. Please confirm if that is correct.

A: Yes. It is the staff’s view is that registered CEFs and BDCs that are subject to the Inline XBRL tagging requirements must separately tag each risk factor, as the 2021Q4 CEF taxonomy package reflects.

Question F.9

Q: Given that A.2 Qualified funds may incorporate by reference documents that contain some, but not all, information that must be tagged in Inline XBRL, it is likely that a “full set” of the specified disclosures will not be tagged within a single filing. For example, a registered CEF that is a seasoned issuer must tag Risk Factors, Investment Objective and Policies and Senior Securities Table information in the Form N-CSR, if that information appears in the report. Even if the fund incorporates by reference its Form N-CSR into a subsequent Form N-2 filing, neither the Form N-2 nor the Form N-CSR would contain a “full set” of tagged data. Is it appropriate to have different context dates in this scenario?

A: Yes, it is appropriate to have different context dates in this scenario. Consistent with EDGAR XBRL Guide section 3.1.12, the context date should reflect the information being disclosed or context date of the report. Data users can merge the data from multiple filings together and use additional algorithms to arrange the data for the appropriate context.

G. Element Selection

Question G.1

Q: What are some considerations for selecting the most appropriate element from the U.S. GAAP Taxonomy among similar elements?

A: Please refer to EDGAR XBRL Guide section 6.8.1.1, “Fact on the Face of Financial Statements.”

Last Reviewed or Updated: Nov. 25, 2025