Apr. 13, 2026
CORPORATE
Hello All
Greetings from London Stock Exchange Group
To the Securities and Exchange Commission
London Stock Exchange Group ("LSEG") appreciates the opportunity to comment on the Commission's request for comment regarding Regulation S-K and the broader review of issuer disclosure requirements, including the continued use of Inline XBRL for structured digital reporting.
LSEG is a global market infrastructure, data, and analytics provider serving investors, asset managers, financial institutions, issuers, and regulators. Our clients rely extensively on high?quality, timely, and comparable structured disclosure data to support investment analysis, risk management, research, and regulatory compliance.
Context of the Regulation S-K Review
We understand the Commission's current initiative as a broad review of Regulation S-K disclosure requirements, rather than a proposal targeted specifically at XBRL or structured data. We also note the distinction between Regulation S-K, which governs many narrative and non?financial disclosures, and Regulation S-K, which applies to audited financial statements and related footnotes.
However, in practice, Inline XBRL now spans both financial statements and an increasing portion of narrative disclosures under Regulation S-K. As a result, any reconsideration of structured data requirements within S-K would have implications well beyond a narrow subset of disclosures, affecting the overall consistency, comparability, and usability of the U.S. issuer dataset.
Benefits of Structured Data and Market Efficiency
The adoption of XBRL and Inline XBRL reporting has materially improved the efficiency, consistency, and scalability of issuer disclosures. Over time, structured data has enabled automation across the financial data lifecycle, reducing manual processing, improving data quality, and supporting more timely dissemination of information to the market.
For data aggregators and vendors such as LSEG, XBRL is fundamental to the operational feasibility of processing and distributing standardized disclosure data at scale. In the United States alone, this involves thousands of issuers and increasingly demanding expectations around timeliness. Structured tagging enables automated ingestion, validation, and normalization of disclosures-capabilities that would be significantly constrained in a predominantly unstructured reporting environment.
Rolling back or exempting issuers from XBRL requirements would therefore represent a meaningful step backward, increasing reliance on manual data extraction, slowing data availability, and reducing the comparability and reliability of disclosures across issuers.
Investor Reliance on XBRL-Enabled Data
While many investors may not interact directly with tagged filings, they rely heavily on the analytics, tools, benchmarks, and comparisons built on top of structured disclosure data. In LSEG's experience, XBRL is foundational to:
Cross-company financial comparability Investment screening and portfolio construction Risk, performance, and exposure analytics Integration of financial and non?financial disclosures across datasets Accordingly, the value of XBRL should be assessed based on its role in the broader market information ecosystem, not solely on direct end-user interaction with XBRL tags. The absence of structured data would ultimately impact the quality, accessibility, and consistency of information available to investors, even if indirectly.
Cost Considerations and Smaller Issuers
We acknowledge concerns regarding the effort and cost associated with XBRL tagging, particularly for smaller issuers. However, experience indicates that these costs tend to decline over time as issuers gain familiarity, service providers mature, and technology continues to improve. Advances in software automation and standardization are already reducing manual burdens while preserving the benefits of structured reporting.
Broad exemptions for certain issuer populations risk creating a two-tier disclosure environment, reducing comparability and transparency precisely where it is most needed. Such outcomes would undermine the integrity of the overall disclosure framework and diminish the usefulness of the data for both investors and regulators.
Rather than exemptions that would reduce data quality and consistency, we encourage the Commission to consider targeted measures-such as clearer guidance, increased standardization, or technology-enabled supports-that address cost concerns without undermining the long-term benefits of structured digital disclosure.
Conclusion
LSEG believes that structured digital disclosure remains a critical component of transparent, efficient, and competitive capital markets. The continued use of Inline XBRL supports investors, enhances comparability, enables timely access to information at scale, and underpins ongoing innovation in data and analytics. We encourage the Commission to consider these broader market impacts as part of its Regulation S-K review.
Warm Regards
London Stock Exchange Group
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