XBRL US submitted a comment letter to the Securities and Exchange Commission Office of Structured Disclosure in response to their request for input on the draft Executive Compensation Disclosure (ECD) Taxonomy. The taxonomy is to be used by filers as well as tool and service providers who work with them, to comply with the new SEC rule on Pay versus Performance. The letter was prepared by members of XBRL US and raised key points regarding:
- Request for additional guidance and resources, e.g., validation rules, minimum data set, additional standardized elements to accomodate multiple compensation-related scenarios, documentation labels, and additional sample instance documents.
- Technical issues including a request to adhere to the XBRL US Style Guide, and corrections in the Taxonomy Guide.
- Request for clarification on guidance provided, graphical content and other topics
The letter also raised concerns about the timing of the availability of the final taxonomy, given compliance dates which begin in January 2023.
Read the letter: XBRL US Comment on Draft 2022 ECD Taxonomy 11 28 2022