XBRL US submitted a comment letter in response to the Securities and Exchange Commission Regulation Crypto Assets File Number S7-2026-27. The proposal calls for data reported to be submitted in a custom XML schema and in HTML. Key recommendations made in the letter include:
- Collect data reported in all proposed forms in conformance with the XBRL semantic data model (taxonomy/ontology) to reduce costs across the supply chain and to generate data that is machine-readable, and of the highest quality because data can be automatically validated.
- Require identifiers for the entity and the digital asset: the Legal Entity Identifier (LEI) for each issuer, and the ISO 24165 Digital Token Identifier (DTI) for the subject crypto asset.
- Ensure data on digital assets is ready for AI.
- Give issuers reporting flexibility within a standardized structured reporting program.
- Align reporting requirements with the FDTA and other stablecoin regulatory programs.
- Enable the Form 1-CRYPTO Part I template to generate data in XBRL format.
- Make certain values mandatory for all issuers so that investors have material information they need and data can be compared across issuers and stablecoins.
- Require all data to be reported to the SEC’s Electronic Data Gathering and Retrieval (EDGAR) System rather than solely to a corporate website posting to ensure ease of data access.
- Require each report to include (i) a Merkle root of its own disclosures and (ii) the Merkle root of the issuer's prior report, creating a tamper-evident chain of filings which follows the Haber–Stornetta method of time-stamping digital documents, which links each record to the one before it and groups many records under a single hash-tree root.
Read the letter: XBRL US - SEC - Regulation Crypto Assets File Number S7–2026–27
