Posted on Tuesday, October 22, 2019

XBRL US submitted a comment letter responding to the SEC proposal, Modernization of Regulation S-K Items 101, 103, and 105. The Commission proposes various changes in disclosure requirements related to Item 101 for business description, Item 103 for legal proceedings and Item 105 for risk factors. The proposed amendments are intended to improve the readability of
disclosure documents, as well as discourage repetition and disclosure of information that is not material.

The proposed amendments did not include a requirement that the text data reported be provided in machine-readable format. Given the importance of this information, the ability to establish clear definitions for each item, and the Commission’s goal of improving the readability of the data, requiring this data in tagged (XBRL) format, would be a logical step that would aid the Commission in its goal of improving the usability of disclosures.

The XBRL US letter strongly recommends adopting financial data standards for information in Items 101, 103, and 105.

Read the letter: XBRL US Response to Regulation S-K Modernization File S7-11-19

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