XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rule, Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies. The rule proposes streamlining filer status for public companies by establishing two primary categories: large accelerated filers and non-accelerated filers. The proposed amendments would raise the threshold and seasoning requirements for large accelerated filers, and extend to all non-accelerated filers the existing accommodations and scaled disclosures applicable to smaller reporting companies and emerging growth companies. The Commission also proposes to extend periodic reporting deadlines for the smallest non-accelerated filers, as measured by total assets.
Our comment letter cautioned that the proposed rule would move more than half of the companies currently considered Large Accelerated Filers (LAF) into the pool of Non-Accelerated Filers (NAF) which carries a substantial reduction in disclosure requirements. Over 1,000 companies would have significant changes to their disclosure requirements including extended filing deadlines, scaled disclosures, and exemptions. Data that has previously been prepared in XBRL format such as pay versus performance disclosures and some block text tagging such as risk factors, would no longer be required to be reported and therefore no longer be available to investors. These changes will impact on data and analytic offerings and the investors and analysts that rely on them. It could also have an adverse impact on the companies themselves as fewer disclosures would reduce their profile among the investment community.
Furthermore our letter suggested that this proposal should be reviewed in light of other proposed rule changes such as Semiannual Reporting and Registered Offering Reform, which are likely to have overlapping consequences that should be considered in their totality.
Read the XBRL US Letter SEC File Number S7-2026-18 7_20_2026
