The staff in the Commission’s Division of Economic and Risk Analysis (DERA) analyzed eXtensible Business Reporting Language (XBRL) financial data[1] submitted by issuers complying with the 2009 Interactive Data rules to file financial statement information in an XBRL format.[2] Our analysis covered XBRL financial data submitted with Forms 20-F, 20-F/A, 40-F and 40-F/A from January 2017 to December 2019[3] by filers preparing their reports using International Financial Reporting Standards as issued by the International Accounting Standards Board.[4] The purpose of the analysis was to analyze trends in filers’ use of custom tags[5] in their XBRL financial data for the aforementioned forms during the last three years in two categories: 1) Financial statements (F/S) only and 2) F/S and notes.
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 has acknowledged that the use of unnecessary customized tags could potentially reduce the comparability of inter-company data.[6]Thus, the Commission’s rules specify the limited circumstances under which a filer may create custom tags.[7]
DERA staff intends to continue reviewing filers’ use of XBRL custom tags in their submissions to the Commission. Depending on the results of those efforts, DERA staff may share additional trends, issue guidance, or pursue other actions.
For the staff’s previous trend analyses on custom tags, see the Trends section on this page: https://www.sec.gov/structureddata/osdstaffobsandguide. DERA staff welcomes your questions and comments. Please feel free to call us at (202) 551-5494 or email us at StructuredData@sec.gov.
[1] Financial data submitted in the Inline XBRL format were included in the analysis. 16 of 1,386 forms included in the analysis represent Inline XBRL filings as of July 5, 2020. In general, IFRS filers will not be required to submit financial statements in the Inline XBRL format until the financial statements first cover a fiscal period ending on or after June 15, 2021. See 17 CFR 232.405(f)(1)(i)(C).
[2] See Release No. 33-9002 (Jan. 30, 2009), 74 FR 6776 (Feb. 10, 2009).
[3] Our analysis excludes custom tags that are abstract (e.g. member, domain, and hypercube) or related to document and entity. For definitions of abstract, member, domain, and hypercube, see XBRL glossary at https://www.sec.gov/page/osd_xbrlglossary. Document and entity tags are largely related to identification and classification of filers and include, among other things, form type, company name, filer size, and public float.
[4] On March 1, 2017, the Commission provided notice that the IFRS Taxonomy was available on the Commission’s website. https://www.sec.gov/rules/other/2017/33-10320.pdf
[5] See 17 CFR 232.405(c)(1)(iii).
[6] See supra n. 2. at 6798.
[7] See 17 CFR 232.405(c)(1)(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.”).
Modified: July 21, 2020