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Inappropriate Use of Custom Tags for Operating Lease Right-of-Use Asset Amortization

Oct. 6, 2021

Staff in the Commission’s Division of Economic and Risk Analysis reminds filers that the Commission’s rules allow filers to create custom tags when the standard taxonomy does not provide an appropriate element to tag that data.

Staff recently assessed companies’ use of custom tags to tag the amortization of operating lease right-of-use assets in their Forms 10-K and 10-Q for fiscal year 2020.[1] The standard element OperatingLeaseRightOfUseAssetAmortizationExpense was added in the 2020 version of the U.S. Generally Accepted Accounting Principles (GAAP) taxonomy for filers to tag this expense. While filers using the 2019 or an earlier version of the U.S. GAAP taxonomy for their fiscal year 2020 filings would have to create custom tags to tag this expense, staff observed that some filers using the 2020 version of the U.S. GAAP taxonomy still tagged the expense using custom tags instead of the standard element.

While custom tags accommodate unique circumstances in a filer’s particular disclosure, the Commission has acknowledged that the use of custom tags could potentially reduce the ability of users to compare similar information across companies.[2] Thus, the Commission’s rules specify that “[a]n electronic filer must create and use a new special element if and only if an appropriate tag does not exist in the standard list of tags for reasons other than or in addition to an inappropriate standard label.”[3]

Filers can find additional information about the element OperatingLeaseRightOfUseAssetAmortizationExpense by consulting the U.S. GAAP taxonomy. For more data quality reminders, see Staff Observations and Guidance.


[1] Fiscal years are self-designated by filers and may not align with the calendar year.

[2] See Release No. 33-9002 (Jan. 30, 2009) at 104-05.

[3] See 17 CFR 232.405(c)(1)(iii)(B).

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