The staff in the Commission’s Division of Economic and Risk Analysis (DERA) recently analyzed custom tags used in eXtensible Business Reporting Language (XBRL) exhibits submitted by issuers to comply with the rules requiring financial statement information to be reported in XBRL. Our analysis covered XBRL exhibits submitted in Forms 20-F, 20-F/A, 40-F and 40-F/A for fiscal years 2018 through 2020 by filers preparing their reports using International Financial Reporting Standards as issued by the International Accounting Standards Board. The purpose of the analysis was to analyze trends in filers’ use of custom tags 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 an appropriate element to tag the disclosure. While this customization accommodates unique circumstances in a filer’s particular disclosure, the Commission has acknowledged that the use of custom tags could potentially reduce the comparability of inter-company data. Thus, the Commission’s rules specify the limited circumstances under which a filer may create custom tags.
Custom tag rates saw a modest increase in 2020 both for financial statements only and when combining financial statements and footnotes. This increase continues the trend from 2018 to 2019.
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 observations DERA staff published in 2014 on custom tag rates, see http://www.sec.gov/dera/reportspubs/assessment-custom-tag-rates-xbrl.html. 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 email us at StructuredData@sec.gov or leave us a voicemail at (202) 551-5494.
 Includes Inline XBRL exhibits. 97 out of 526 filers that submitted fiscal year 2020 filings used Inline XBRL.
 Release No. 33-9002 (Jan. 30, 2009), 74 FR 6776 (Feb. 10, 2009) and Release No. 33-10514 (Jun. 28, 2018).
 Fiscal years are based on filers’ self-designations. Our analysis includes custom tags of line item tags and excludes tags that are abstract, text-related, domain member, domain, and document and entity. For definitions of abstract, domain member, and domain, see the XBRL glossary at https://www.sec.gov/page/osd_xbrlglossary. Document and entity tags are largely related to identification of filings and filers including, for example, form type, company name, filer size, and public float.
 17 CFR 232.405(c)(1)(iii).
 See n. 2. at 104-05.
 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: April 6, 2023