Trend Analysis on Custom Tag Rates in XBRL Exhibits Submitted from 2015 to 2017

The staff in the Commission’s Division of Economic and Risk Analysis (DERA) recently analyzed eXtensible Business Reporting Language (XBRL) exhibits submitted by issuers complying with the 2009 Interactive Data rules to file financial statement information in an XBRL format.[1] Our analysis covered XBRL exhibits submitted in Forms 10-K and 10-K/A from January 2015 to December 2017.[2] The purpose of the analysis was to monitor filers’ use of custom tags[3] in their XBRL submissions during the last three years.

The Commission’s rules allow filers to create custom tags when the standard taxonomy does not provide a tag for the necessary financial element. While this customization accommodates unique circumstances in a filer’s particular disclosure, the Commission acknowledged that the use of unnecessary customized tags could potentially reduce the comparability of inter-company data.[4] Thus, the Commission’s rules specify the limited circumstances under which a filer may create custom tags. [5]

I. TREND ANALYSIS

The trend analysis shows that the average custom tag rates for all filers combined, have been declining from 19% to 18% in the last three years. The average custom tag rates for the specific filers in the last three years are as follows: The tag rates for large accelerated filers have been declining from 19% to 18%. The tag rates for accelerated filers have remained at 18%. The tag rates for non-accelerated filers have been declining from 22% to 21%. The tag rates for smaller reporting compani

[1] Release No. 33-9002 (Jan. 30, 2009), 74 FR 6776 (Feb. 10, 2009).

[2] Our analysis includes custom tags of line item tags and excludes tags that are abstract, text-related, member, domain, and document and entity.

[3] 17 CFR 232.405(c)(iii).

[4] See n. 1. at 104-05.

[5] See 17 CFR 232.405(c)(iii)(B) (“An 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.”).

* DERA staff identified “large accelerated filers,” “accelerated filers,” “non-accelerated filers,” and “smaller reporting companies” based on their self-identifications on their Forms 10-K and 10-K/A. Verification of the accuracy of the self-identification is beyond the scope of this analysis.

The trend analysis for Forms 10-K and 10-K/A shows that the average custom tag rates continue to decline in the last three years for all filers, except for accelerated filers whose custom tag rates remained the same in all three years. In addition, the trend analysis reveals that the non-accelerated filers had the highest average custom tag rates while the smaller reporting companies had the lowest average custom tag rates.

II. CONCLUSION

DERA staff intends to continue to review filers’ use of XBRL in their submissions to the Commission XBRL submissions. Depending on the results of those efforts, DERA staff may share additional trends, issue guidance, or pursue other actions.

For the staff observations DERA staff published on custom tag rates in 2014, see http://www.sec.gov/dera/reportspubs/assessment-custom-tag-rates-xbrl.html. For the staff’s previous trend analysis on custom tags from 2017, see https://www.sec.gov/structureddata/trends.

DERA staff welcomes your questions and comments. Please feel free to call us at (202) 551-5494 or email us at StructuredData@sec.gov.

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