XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) regarding its proposed rule Updated EDGAR Filing Requirements, which aims to improve investor access to information in registration statements, periodic reports and other filings made with the Commission. The proposal includes a requirement for Inline XBRL for the filing of financial statements and notes to the financial statements required in Form 11-K, the Annual Report of Employee Stock Purchase, Savings, and Similar Plans.
The letter from XBRL US supports the use of Inline XBRL for Form 11-K which contains financial and narrative data; and in addition made these recommendations related to other filings referenced in the SEC proposal:
- Require the Form 6-K cover page to be tagged (to mirror requirements on Form 8-K cover page tagging)
- Require the tagging of financial content contained in both Forms 6-K and 8-K to render the data more useful for data consumers
- Establish a mechanism so that companies can assign unique identifiers to the various plans reported on Form 11-K so that companies can reference plans in their base financial reports and improve the ability to link plans with financial statement data
- Require structured data reporting for Exhibit 21, Subsidiary Listing, to improve the ability of data users to better understand business and investment risk of a reporting entity
In addition, the XBRL US letter encouraged the Commission to conduct a beta program with test environment and technical materials prior to implementation of the final rule so that vendors and issuers can have sufficient time and instruction to ensure successful compliance.
Read the letter: XBRL US Comment – SEC File Number S7-16-21
