U.S. Securities and 

Exchange Commission

SEMI-ANNUAL REPORT 

TO CONGRESS

Regarding Public and Internal Use of 

Machine-Readable Data for 

Corporate Disclosures

June 2023
DISCLAIMER: This is a report prepared by staff of the U.S. Securities and Exchange Commission. The Commission has 

expressed no view regarding any analysis, findings, or conclusions contained herein.
Contents

INTRODUCTION......................................................................................................................................................................1

IDENTIFICATION OF CORPORATE DISCLOSURES EXPRESSED AS 

MACHINE-READABLE DATA.............................................................................................................................................1

ANALYSIS OF THE COSTS AND BENEFITS OF THE USE OF MACHINE-READABLE DATA ...........2

Existing Structured Data Requirements................................................................................................. 2

Benefits ..............................................................................................................................................................3

Costs.....................................................................................................................................................................3

SUMMARY OF ENFORCEMENT ACTIONS RESULTING FROM THE USE OR 

ANALYSIS OF THE MACHINE-READABLE DATA THAT THE COMMISSION COLLECTS...................5

ANALYSIS OF HOW THE COMMISSION’S STAFF USES THE MACHINE-READABLE 

DATA THAT THE COMMISSION COLLECTS............................................................................................................ 6

PUBLIC USE OF THE MACHINE-READABLE DATA THAT THE COMMISSION COLLECTS.............. 9

CONCLUSION......................................................................................................................................................................... 9

APPENDIX...............................................................................................................................................................................10

ENDNOTES ............................................................................................................................................................................20

JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 1

Introduction

The Financial Data Transparency Act of 2022 (FDTA), which was signed into law on 

December 23, 2022, as Title LVIII of the James M. Inhofe National Defense Authorization 

Act for Fiscal Year 2023,1 requires the Commission to report semi-annually on the public 

and internal use of machine-readable data for corporate disclosures.2 This report is the first 

such report. The FDTA requires the Commission to submit this report to the Committee 

on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial 

Services of the House of Representatives every 180 days until December 23, 2029, when 

the provision requiring the report sunsets.3

FDTA Section 5825(b) requires that this report include an identification of which 

corporate disclosures required under specified provisions of the securities laws are 

expressed as machine-readable data and which are not; an analysis of the costs and 

benefits of the use of machine-readable data in corporate disclosure to investors, markets, 

the Commission, and issuers; a summary of enforcement actions that result from the use 

or analysis of machine-readable data collected under the specified statutory provisions; and 

an analysis of how the Commission uses the machine-readable data it collects.4

Identification of Corporate Disclosures 

Expressed as Machine-Readable Data

FDTA Section 5825(b)(2)(A) requires an identification of which corporate disclosures 

required under Section 7 of the Securities Act of 1933 (the Securities Act),5 Section 13 of 

the Securities Exchange Act of 1934 (the Exchange Act),6 and Section 14 of the Exchange 

Act7 are expressed as machine-readable data and which are not. Currently, 38 of 52 (or 

about three-quarters) of the forms, schedules, and statements that contain the disclosures 

require some machine-readable data, while 14 (or about one-quarter)8 do not require any 

machine-readable data. Please refer to the Appendix. 
2 | U.S. SECURITIES AND EXCHANGE COMMISSION

Analysis of the Costs and Benefits of the 

Use of Machine-Readable Data

EXISTING STRUCTURED DATA9 REQUIREMENTS

In 2009, the Commission adopted rules requiring operating companies to provide the 

information from the financial statements in their registration statements and periodic 

and current reports in machine-readable format using eXtensible Business Reporting 

Language (XBRL),10 which is a structured-data language used for standardized reporting 

of business information, including information relating to the financial performance of 

companies.11 That same year, the Commission similarly required open-end management 

investment companies (mutual funds) to provide risk/return summary information in their 

prospectuses in XBRL format.12

Since that time, the Commission has refined its rules by requiring open and freely 

available, machine-readable standardized formats promulgated by standards organizations 

or voluntary consensus standards bodies. For instance, in 2018, the Commission adopted 

amendments requiring the use, on a phased-in basis, of Inline XBRL for operating 

company financial statement information and fund risk/return summary information.13

Whereas previously filers generated an HTML document of their financial statement 

information or risk/return summary information and then tagged a copy of the data to 

create a separate XBRL exhibit, Inline XBRL allows filers to prepare a single document 

that is both human-readable and machine-readable.14

The Commission has adopted rules requiring machine-readable formats for additional 

collections of information. In 2019, the Commission introduced structured data tagging 

requirements for certain reporting form cover page data.15 In 2021, the Commission 

amended most of its fee-bearing forms and schedules to require tagging of information 

related to filing fee calculation.16 Also in 2021, the Commission added tagging 

requirements in Forms 10-K, 20-F, and 40-F pertaining to the auditor and jurisdiction 

on the audit report signed by the registered public accounting firm.17 A number of other 

Commission releases have adopted or proposed structured data tagging requirements for 

additional collections of information.18

In addition to requiring XBRL and Inline XBRL for certain filings, the Commission 

requires some reports and disclosures to be filed in an eXtensibleMarkupLanguage 

(XML)-based data language specific to particular forms (custom XML, and form-specific 

XML).19 That is, certain filings are submitted using custom XML languages that are 
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 3

each specific to the particular form being submitted.20 For such filings, filers are typically 

provided the option either to submit the filing directly in the relevant custom XML data 

language, or to manually input the information into a fillable web-based form developed 

by the Commission that converts the completed form into a custom XML document.21

BENEFITS 

Studies show that machine-readable disclosures benefit investors, markets, and issuers. 

Making corporate disclosures machine-readable has decreased information asymmetry by 

reducing information processing costs, making stock prices more informative (i.e., more 

reflective of firm-specific information), and reducing market inefficiencies and risks.22

Machine-readability has enhanced market competition by, for example, reducing insider 

advantages relative to non-insiders and local investor advantages relative to non-locals.23

The reduction in information processing costs has heightened monitoring of issuers by 

investors and other external parties (e.g., financial analysts, press) which often helps to 

inform investors and markets.24 Greater monitoring has driven firms to provide more 

quantitative disclosure and report earnings in a more consistent manner.25

Issuers have, in some instances, benefitted from decreased audit fees and increased 

timeliness of audit and financial reports as a result of machine-readable disclosures.26

Issuers have experienced additional benefits associated with machine-readable disclosures, 

including: higher liquidity; lower cost of capital; higher return on investment; and improved 

performance benchmarking and acquisition analysis.27 Finally, machine-readable disclosures 

have facilitated the Commission’s investor protection efforts, enabling staff to analyze 

large quantities of information in support of risk assessment, rulemaking, and enforcement 

activities, including as part of its internally developed structured data applications.28

COSTS

The cost of machine-readable disclosure largely affects issuers and the Commission, as 

these parties must, respectively, comply with or mandate and implement machine-readable 

disclosure requirements. Investors are not bound to use machine-readable versions of 

corporate disclosures, because the disclosures are human-readable as well.29 Furthermore, 

while commercial XBRL research software is available for a cost, investors and other data 

users (e.g., financial analysts, asset managers, and academic researchers) can access and 

download machine-readable corporate disclosures at no cost.30

Issuers incur compliance costs to apply machine-readable tags to their disclosures or 

pay a third-party tagging service provider to do so. Compliance costs for new tagging 

requirements tend to be higher, but generally decline as issuers and service providers adapt 
4 | U.S. SECURITIES AND EXCHANGE COMMISSION

to the requirements.31 These compliance costs are likely reduced for those issuers with 

experience applying tags to their disclosures, whether through other machine-readability 

requirements or through the use of machine-readable data in their internal enterprise 

resource planning systems.32 With respect to the magnitude of these compliance costs, 

an American Institute of Certified Public Accountants survey of 1,032 smaller reporting 

companies in 2018 found a median cost of $2,500 per year for fully outsourced XBRL 

creation and filing.33 A separate survey of 139 Nasdaq-listed issuers and other responding 

companies in 2018 found higher XBRL compliance costs, including a median XBRL 

compliance cost of $7,500 per Form 10-Q.34 The discrepancy may be due to Nasdaq-listed 

companies generally having longer and more complex financial statements than smaller 

reporting companies, resulting in more time and effort needed to tag financial statements.35

Lastly, the Paperwork Reduction Act section of a 2018 Commission adopting release 

that addressed the costs of Inline XBRL tagging stated that the long-term effect of Inline 

XBRL would be to reduce the internal burden for financial statement tagging to 54 hours 

per response and increase the out-of-pocket cost to $6,175 per response.36 In 2020, the 

Commission estimated an internal burden of 10.5 hours per response and an out-of-pocket 

cost of $900 per response for closed-end fund prospectus tagging, after completion of an 

implementation period.37

The Commission incurs costs to develop taxonomies and schemas for new structured 

disclosures and to set up the infrastructure for structured data intake, validation, 

publication, and use. This includes the cost of updating the Commission’s Electronic 

Data Gathering, Analysis, and Retrieval (EDGAR) filing system, the integration of 

new structured data into databases and internal applications, and the publication of 

structured datasets. Such costs can vary based on the volume, complexity, and novelty 

of new structured disclosure requirements. The Commission also incurs costs to update 

taxonomies and schemas and the related EDGAR intake and validation functions on a 

periodic basis.
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 5

Summary of Enforcement Actions Resulting 

from the Use or Analysis of the MachineReadable Data That the Commission Collects

The availability of machine-readable data that has been submitted to the Commission 

has enabled staff in the Division of Enforcement (Enforcement) to perform more efficient 

analyses of individual issuers’ accounting practices and disclosures and more sophisticated 

analyses of accounting practices and disclosures across wide-ranging cross-sections of 

issuers. The latter analyses, together with traditional investigative tools, have resulted 

in the filing of actions against issuers and related individuals alleging various types 

of misconduct that violated the federal securities laws. Without the use or analysis of 

machine-readable data, the alleged violations would have been significantly more difficult 

to detect and pursue in a cost-effective or timely manner. 

Enforcement utilized risk-based data analytics to uncover potential accounting and 

disclosure irregularities caused by, among other things, earnings management practices. 

Machine-readable data enabled Enforcement staff to review the financial data of thousands 

of public issuers in order to detect indicia of earnings management or other types of 

financial misconduct. The initiative resulted in charges against six public companies and 

several related individuals for violations of the federal securities laws for engaging in 

certain practices that gave the appearance of meeting or exceeding consensus earnings-pershare (EPS) estimates.38
6 | U.S. SECURITIES AND EXCHANGE COMMISSION

Analysis of How the Commission’s Staff 

Uses the Machine-Readable Data That the 

Commission Collects

The Commission’s staff uses several applications to analyze machine-readable data. The 

following applications are internally developed and available to Commission staff: 

• Filer Profile provides instant access to certain key data points, such as financial data, 

audit-related information, and other data for operating companies. It highlights 

potentially high-risk data points or topic areas and facilitates further analysis via links 

to data sources. Additionally, Filer Profile allows users to identify quickly specific 

areas and topics of interest. 

• Financial Statement Query Viewer (FSQV) offers users a convenient means of 

comparing machine-readable financial statements and notes data for operating 

companies across multiple filings and periods. In FSQV, users can query tagged 

narrative or numeric disclosures. FSQV has various features, such as the ability to 

track a filer’s changes in footnotes across reporting periods and share queries with 

other users.

• iView leverages the open-source, freely and publicly available Inline XBRL Viewer. 

iView includes various filters and query capabilities, such as the identification of 

disclosures with custom tags (i.e., filers creating tags instead of using standard tags) 

and the sorting of machine-readable data by scale (e.g., amounts in thousands, 

millions, or billions). iView also offers time-series charting and benchmark analyses 

for numeric values and tracking changes in narrative disclosures. 

Division of Corporation Finance (Corporation Finance) staff uses machine-readable data 

in a variety of ways:

• Corporation Finance staff uses machine-readable data to help identify issuers that 

are subject to the disclosure and submission requirements of, and potentially subject 

to a trading prohibition under, the Holding Foreign Companies Accountable Act 

(Commission-Identified Issuers).39 Specifically, the staff uses data in Forms 10-K, 20-F 

and 40-F identifying the auditor (or auditors) who provided opinions related to the 

financial statements presented in the registrant’s annual report, the location where 
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 7

the auditor’s report has been issued, and the Public Company Accounting Oversight 

Board (PCAOB) ID Number(s) of the audit firm(s) or branch(es) providing the 

opinion(s).

• Corporation Finance staff uses several items of machine-readable data that appear 

on the cover pages of registrants’ annual reports (Forms 10-K, 20-F, and 40-F) to 

identify, count, sort, compare, and analyze registrants and their disclosures (e.g., to 

identify more readily and accurately issuers that are listed on a specific exchange or 

that have identified themselves as well-known seasoned issuers). 

• Corporation Finance and Division of Economic and Risk Analysis (DERA) staff 

review machine-readable financial statement information contained in filings under 

Commission rules. In connection with these reviews, the staff has issued comment 

letters to some individual issuers regarding the Inline XBRL tagging requirements. 

The staff has also used its findings to publish observations on data quality and 

analyses of custom tags. 

• Corporation Finance staff uses machine-readable data to make preliminary 

assessments of compliance with the Commission’s recently adopted pay-versusperformance disclosure requirements. 

The Division of Investment Management (Investment Management) staff uses machinereadable fund disclosures to detect more readily errors and inconsistencies within filings 

and to identify funds with particular characteristics or disclosures, as well as funds with 

certain holdings, exposures or risk parameters.40 The ability to scan across the industry 

for funds with certain disclosures and characteristics enhances Investment Management’s 

disclosure review program,41 informs staff recommendations for Commission rulemakings 

and other policy initiatives, and supports the staff’s coordination with other federal 

agencies. The staff has also used machine-readable information regarding fund holdings, 

among other data, to evaluate fund compliance with the federal securities laws and to 

identify trends and risks faced by the fund industry. This information can be shared with 

the Divisions of Examinations and/or Enforcement when it suggests non-compliance with 

law or other heightened risks. 

Structured data analysis may also better enable Investment Management staff to identify 

fund data errors. When Investment Management staff identified common errors as a result 

of our use of structured data, the staff published information highlighting common tagging 
8 | U.S. SECURITIES AND EXCHANGE COMMISSION

issues to facilitate more accurate fund disclosure.42 The compliance date has recently 

passed for a number of new data tagging requirements, including certain disclosures 

associated with closed-end funds, business development companies, and variable insurance 

contracts. This new data tagging will enable Investment Management staff to identify more 

effectively funds that may not be in compliance with these new disclosure requirements.43

As these new disclosures become more widely tagged, the staff can use the newly available 

machine-readable data to evaluate and uncover disclosure and compliance issues and to 

help inform future staff policy recommendations.

The Office of the Chief Accountant (OCA) staff uses the Commission’s analytical 

applications, including FSQV, iView, and others, to perform searches based on key words 

and XBRL tagging. OCA staff uses the output of these searches to conduct research for 

accounting consultations, information gathering relevant to accounting standard-setting 

projects, and the preparation of responses to specific data requests regarding registrants’ 

accounting application. OCA staff additionally uses the outputs in researching the 

identification of independent auditors concentrated in specific industries, identifying issuers 

subject to the Holding Foreign Companies Accountable Act, and supporting Enforcement 

on auditor-related matters. 

The tagging requirements of filing fee-related information, adopted in 2021,44 will 

enable EDGAR to determine automatically in many cases whether a registrant’s filing fee 

calculations have been performed correctly. Filings that use the SEC’s optional fee-tagging 

tool and test filings that do not pass specific validation tests will be flagged before the 

related live filing is filed. This will allow filers to correct any filing fee calculation errors 

without needing to wait for Commission staff to verify the calculations manually, and 

without having to subsequently revise an already-filed document and adjust any fees owed 

due to an erroneous calculation. 
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 9

Public Use of the Machine-Readable Data That 

the Commission Collects

Users of machine-readable corporate disclosures include institutional investors,45 asset 

managers,46 issuers,47 financial analysts and research firms,48 individual investors,49 data 

aggregators,50 the financial press,51 and academics.52 For example, academic studies 

indicate that the implementation of XBRL data requirements appear to be correlated 

with increased forecast accuracy by financial analysts.53 Also, financial academics have 

used XBRL data to study financial reporting complexity.54 Further, staff members of the 

Financial Accounting Standards Board (FASB) have used XBRL data to complete more 

than 200 research projects over the past several years.55

Financial analysts and press also use data from Commission filings that are in a custom 

XML, such as data from Form 13F (quarterly equity holdings reports filed by large 

institutional investment managers).56 For example, since August 2022 (when the Form 13F 

datasets first became available), there have been 35,000 Form 13F dataset downloads.57

Conclusion

The FDTA’s directives coincide with internal Commission and staff efforts58 to improve the 

management and use of data across the agency, consistent with other statutory directives59

as well as overall strategic goals to work more efficiently.
10 | U.S. SECURITIES AND EXCHANGE COMMISSION

Appendix

FDTA Section 5825(b)(2)(A) requires an identification of which corporate disclosures 

required under Securities Act Section 7 and Exchange Act Sections 13 and 14 are expressed 

as machine-readable data and which are not. The Commission collects these disclosures 

via the submission of forms and schedules through the EDGAR System. This Appendix 

identifies the disclosures expressed in a machine-readable format on an individual form, 

schedule, and statement basis. All other required disclosures in these filings are submitted 

in a non-machine readable format. The Appendix also identifies the forms, schedules, or 

statements that do not collect any machine-readable information. It does not include other 

collections of information with machine-readable data that are not required under these 

statutory provisions.

The Commission’s requirement to file information tagged in XBRL (Inline XBRL, except 

where noted) is implemented primarily through Rule 405 of Regulation S-T. Rule 405 

addresses the obligation to tag financial statements60 and disclosure regarding pay-versusperformance, action to recover erroneously awarded compensation, insider trading 

arrangements and policies, and policies and practices related to the grant of certain 

equity awards close in time to the release of material non-public information. Rule 406 

of Regulation S-T addresses the obligation to tag the cover page of Forms 10-K, 10-Q, 

8-K, 20-F, and 40-F. Rule 408 of Regulation S-T addresses the obligation to tag the filing 

fee exhibit for registration statements and related fee-bearing prospectus supplements 

(excluding SF-1, SF-3, S-20, Schedule B, F-6, F-7, F-8 and F-80), fee-bearing Schedules 

14A, 14C, 13E-3, 13E-4F, TO, and 14D-1F, and statements under Rule 13e-1 (phase-in 

begins in 2024).

CORPORATE DISCLOSURES IN FORMS UNDER SECURITIES ACT SECTION 7

Securities Act Registration Statements61

Form S-1

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form S-3

• Financial statements must be tagged in Inline XBRL. 

• Filing fee exhibits must be tagged in Inline XBRL. 
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 11

Form S-4

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form S-8

• Filing fee exhibits must be tagged in Inline XBRL.

Form S-11

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-1

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-3

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-4

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-10

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form SF-1/SF-3 (registration forms used by certain types of asset-backed issuers)

• If an asset-backed issuer registrant’s asset pool includes residential mortgages, 

commercial mortgages, automobile loans, automobile leases, debt securities or 

re-securitizations of asset-backed securities, certain asset-level information62 is 

required to be filed under cover of Form ABS-EE in XML format.63 The initial 

asset-level disclosure filing is incorporated by reference into the relevant registration 

statement filing or related prospectus filing.

• Filing fee exhibits are not required to be tagged, but may be tagged, in Inline XBRL.

No machine-readable data is required in Forms F-6, F-7, F-8 and F-80 (registration 

statements available only to a registrant that is incorporated or organized under the laws 

of Canada or any Canadian province or territory and meets certain other conditions).
12 | U.S. SECURITIES AND EXCHANGE COMMISSION

No machine-readable data is required in Form S-20 (used to register standardized options 

under the Securities Act if specified conditions are met) or in Schedule B (a registration 

statement available only to a registrant that is a foreign government).

CORPORATE DISCLOSURES IN FORMS AND SCHEDULES UNDER 

EXCHANGE ACT SECTION 13

Form 10-K

• Financial statements must be tagged in Inline XBRL.

• Cover page information (e.g., company name, form type, filer size, public float, ticker 

symbol) must be tagged in Inline XBRL.

• The identity of the auditor (or auditors) who have provided opinions related to the 

financial statements presented in the registrant’s annual report, the location where the 

auditor’s report has been issued, and the PCAOB ID Number(s) of the audit firm(s) or 

branch(es) providing the opinion(s) must be tagged in Inline XBRL.

• Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover 

erroneously awarded compensation) must be tagged in Inline XBRL.

• Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and 

practices related to the grant of certain equity awards close in time to the release of 

material non-public information) must be tagged in Inline XBRL.

• Disclosure required by Item 408(a), (b)(1) and (d)64 of Regulation S-K (registrant’s 

insider trading arrangements and policies) must be tagged in Inline XBRL.

• Disclosure required by Item 601(b)(26) and Item 703 of Regulation S-K (purchases of 

equity securities by registrant and affiliated purchasers) must be tagged in Inline XBRL.

Form 10-Q

• Financial statements must be tagged in Inline XBRL.

• Disclosure required by Item 408(a) and (d) of Regulation S-K (registrant’s insider 

trading arrangements and policies) must be tagged in Inline XBRL.

• Disclosure required by Item 601(b)(26) and Item 703 of Regulation S-K (purchases of 

equity securities by registrant and affiliated purchasers) must be tagged in Inline XBRL.

Form 11-K

• Financial statements must be tagged in Inline XBRL (beginning in 2025).
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 13

Form 20-F

• Financial statements must be tagged in Inline XBRL.

• Cover page information must be tagged in Inline XBRL (when Form 20-F is filed as 

an annual report).

• Disclosure required by Item 6.F (registrant’s action to recover erroneously awarded 

compensation) must be tagged in Inline XBRL.

• The identity of the auditor (or auditors) who have provided opinions related to the 

financial statements presented in the registrant’s annual report, the location where the 

auditor’s report has been issued, and the PCAOB ID Number(s) of the audit firm(s) or 

branch(es) providing the opinion(s) must be tagged in Inline XBRL.

• Disclosure required by Item 16E (purchases of equity securities by registrant and 

affiliated purchasers) must be tagged in Inline XBRL.

• Disclosure required by Item 16.J (insider trading policies).

Form 40-F

• Financial statements must be tagged in Inline XBRL.

• Cover page information must be tagged in Inline XBRL (when Form 40-F is filed as 

an annual report).

• Disclosure required by General Instruction B, paragraph (19) (registrant’s action to 

recover erroneously awarded compensation) must be tagged in Inline XBRL.

• The identity of the auditor (or auditors) who have provided opinions related to the 

financial statements presented in the registrant’s annual report, the location where the 

auditor’s report has been issued, and the PCAOB ID Number(s) of the audit firm(s) or 

branch(es) providing the opinion(s), must be tagged in Inline XBRL.

Form ABS-EE

• The information in the Form ABS-EE must be tagged in XML.

Form 8-K

• Cover page information must be tagged in Inline XBRL.

• Financial statements must be tagged in Inline XBRL (when the form includes audited 

annual financial statements that are a revised version of financial statements that 

previously were filed with the Commission).
14 | U.S. SECURITIES AND EXCHANGE COMMISSION

Form 6-K

• Financial statements must be tagged in Inline XBRL (when the form includes audited 

annual financial statements that are a revised version of financial statements that 

previously were filed with the Commission, or current interim financial statements 

are included pursuant to the nine-month updating requirement of Item 8.A.5 of 

Form 20-F).

Form F-SR

• Purchases of equity securities by registrant and affiliated purchasers must be tagged in 

Inline XBRL.

Form SD

• Information included in the Resource Extraction Issuer Disclosure Report (Exhibit 

2.01) must be filed in XBRL.

Form 10-D

• ABS issuers generally are required to file standard Exchange Act filings, including 

Forms 10-K and 8-K. Additionally, ABS issuers are required to file ongoing reports 

(typically monthly) on Form 10-D, which include the distribution report sent to 

the holders of the ABS. If the issuer’s asset pool includes residential mortgages, 

commercial mortgages, automobile loans, automobile leases, debt securities or 

re-securitizations of asset-backed securities, Form 10-D must also incorporate by 

reference the current asset-level disclosure filing on Form ABS-EE, which must be filed 

in XML format. 

Schedules 13E-3 and 13E-4F and Statements under Rule 13e-1

• Filing fee exhibits must be tagged in Inline XBRL.

No machine-readable data is required in Schedules 13D and 13G (beneficial ownership 

reports) or Form 18-K (annual report form used by foreign governments or political 

subdivisions of foreign governments with securities listed on a United States exchange).

Exchange Act Section 13(n) requires Security-Based Swap Data Repositories to file 

registration statements (Form SDR). Commission Rules 13n-1(b) and 13n-11(f)(5) require 

entities to file Form SDR and all amendments “electronically in a tagged data format.” 
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 15

The Commission has stated that for a period of four years following Regulation SBSR’s 

Compliance Date 1, “an entity submitting an application to register would not need to 

comply with the requirement in Rule 13n-1(b) and Rule 13n-11(f)(5) to file Form SDR 

and all amendments ‘electronically in a tagged data format’ but instead would be able to 

submit such documents to the Commission electronically as portable document format 

(PDF) files, consistent with the CFTC SDR application procedures under Part 49.3(a)

(1).775.”65

CORPORATE DISCLOSURES IN SCHEDULES UNDER EXCHANGE ACT SECTION 14 

Schedules 14A/14C

• Disclosure required by Item 402(v) of Regulation S-K (pay versus performance) must 

be tagged in Inline XBRL.

• Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover 

erroneously awarded compensation) must be tagged in Inline XBRL.

• Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and 

practices related to the grant of certain equity awards close in time to the release of 

material non-public information) must be tagged in Inline XBRL.

• Disclosure required by Item 408(b)(1) of Regulation S-K (registrant’s insider trading 

arrangements and policies) must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Schedules TO and 14D-1F

• Filing fee exhibits must be tagged in Inline XBRL.

No machine-readable data is required in Schedules 14D-9, 14D-9F, or 14N.

Specific forms govern the disclosures made by mutual funds, exchange-traded funds 

(ETFs), money market funds, variable insurance products, closed-end funds and business 

development companies (BDCs) (together, funds). Funds are subject to a number 

of disclosure requirements, several of which are required to be machine-readable. 

Institutional investment managers are also required to periodically disclose certain 

holdings. The list below provides a complete list of such machine-readable disclosure 

requirements for these entities.
16 | U.S. SECURITIES AND EXCHANGE COMMISSION

The following is a list of Machine-Readable Fund Disclosures under Securities Act 

Section 7 and Exchange Act Sections 13 and 14

FUND DISCLOSURES IN FORMS UNDER SECURITIES ACT SECTION 7 

Securities Act Registration Statements

Form N-1A

• Items 2 through 4 of Form N-1A must be tagged in Inline XBRL. (Mutual funds and 

ETFs are required to tag their investment objectives, fee tables, principal strategies, 

principal risks, and performance information.)

Form N-2

• Cover page of Form N-2 must be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 

10.3, and 10.5 of Form N-2 must be tagged in Inline XBRL. (Closed-end funds and 

BDCs are required to tag their fee table, senior securities table, investment objectives 

and policies, risk factors, share price data, and capital stock, long-term debt and other 

securities. This information may be tagged in the prospectus or in periodic reports.)

• Filing fee exhibits must be tagged in Inline XBRL. (Closed-end funds that are not 

interval funds are required to tag their filing fee exhibits.) 

Form N-3

• Items 2, 4, 5, 11, 18 and 19 of Form N-3 for contracts available to new investors 

must be tagged in Inline XBRL. (Variable insurance contracts are required to tag 

their key information table, fee table, principal risks, information about benefits, and 

investment options.)

Form N-4

• Items 2, 4, 5, 10, and 17 of Form N-4 for contracts available to new investors must 

be tagged in Inline XBRL. (Variable insurance contracts are required to tag their 

key information table, fee table, principal risks, information about benefits, and 

investment options.)
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 17

Form N-6

• Items 2, 4, 5, 10, 11, and 18 of Form N-6 for contracts available to new investors 

must be tagged in Inline XBRL. (Variable insurance contracts are required to tag 

their key information table, fee table, principal risks, information about benefits, and 

investment options.)

Form N-14

• Filing fee exhibits must be tagged in Inline XBRL. (Closed-end funds that are not 

interval funds are required to tag their filing fee exhibits.) 

No machine-readable data is required in Forms N-5 and S-6.

FUND DISCLOSURES IN FORMS UNDER EXCHANGE ACT SECTION 13 

Form N-CSR

• Item 27A of Form N-1A will be required to be tagged in Inline XBRL. (Mutual 

funds and ETFs will be required to tag their shareholder reports, which includes fee, 

performance, holdings, material changes and other specified fund information.) Note: 

The compliance date is July 24, 2024.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 

10.3, and 10.5 of Form N-2 must be tagged in Inline XBRL. (Closed-end funds 

are required to tag their fee table, senior securities table, investment objectives and 

policies, risk factors, share price data, and capital stock, long-term debt and other 

securities. This information may be tagged in the N-CSR filing to the extent this 

information is included.) 

• Item 14 of Form N-CSR will be required to be tagged in Inline XBRL. (Listed closedend funds will be required to disclose certain share repurchase information.) The 

compliance date commences with the Form N-CSR that covers the first six-month 

period that begins on or after January 1, 2024. 

• Item 18 of Form N-CSR will be required to be tagged in Inline XBRL. (Internally 

managed closed-end funds are required to tag disclosure related to the recovery of 

erroneously awarded compensation.) Note: The compliance date is dependent on 

exchanges updating their listing requirements. 
18 | U.S. SECURITIES AND EXCHANGE COMMISSION

Form N-CEN

• Form N-CEN must be filed in XML format. (Form N-CEN provides annual census 

information or nearly all registered investment companies. The filing of N-CEN 

satisfies Exchange Act reporting obligations for unit investment trusts.)

Form 10-K (Only for BDCs)

• Cover page information (e.g., company name, form type, filer size, public float, ticker 

symbol) must be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 

10.3, and 10.5 of Form N-2 must be tagged in Inline XBRL. (BDCs are required 

to tag their fee table, senior securities table, investment objectives and policies, risk 

factors, share price data, and capital stock, long-term debt and other securities. This 

information may be tagged in the 10-K to the extent this information is included in 

the Exchange Act report.)

• Financial statements and schedules listing various BDC investments must be tagged in 

Inline XBRL.

• The identity of the auditor (or auditors) who have provided opinions related to the 

financial statements presented in the registrant’s annual report, the location where the 

auditor’s report has been issued, and the PCAOB ID Number(s) of the audit firm(s) or 

branch(es) providing the opinion(s) must be tagged in Inline XBRL.

• Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover 

erroneously awarded compensation) must be tagged in Inline XBRL.

• Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and 

practices related to the grant of certain equity awards close in time to the release of 

material non-public information) must be tagged in Inline XBRL.

• Disclosure required by Item 408(a), 408(b)(1), and 408(d) of Regulation S-K 

(registrant’s insider trading arrangements and policies) must be tagged in Inline XBRL. 

• Disclosure required by Items 601(b)(26) and 703 of Regulation S-K (registrant’s share 

repurchases) must be tagged in Inline XBRL.

Form 10-Q (Only for BDCs)

• Cover page information must be tagged in Inline XBRL.

• Financial statements must be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 

10.3, and 10.5 of Form N-2 must be tagged in Inline XBRL. (BDCs are required 

to tag their fee table, senior securities table, investment objectives and policies, risk 

factors, share price data, and capital stock, long-term debt and other securities. This 

information may be tagged in the 10-Q to the extent this information is updated in 

the Exchange Act report.)
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 19

• Disclosure required by Item 408(a) and 408(d) of Regulation S-K (registrant’s insider 

trading arrangements and policies) must be tagged in Inline XBRL.

• Disclosure required by Items 601(b)(26) and 703 of Regulation S-K (registrant’s share 

repurchases) must be tagged in Inline XBRL.

Form 8-K (Only for BDCs and is optional for registered closed-end funds)

• Cover page information must be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 

10.3, and 10.5 of Form N-2 must be tagged in Inline XBRL. (BDCs are required 

to tag their fee table, senior securities table, investment objectives and policies, risk 

factors, share price data, and capital stock, long-term debt, and other securities. This 

information may be tagged in the 8-K to the extent this information is updated in the 

Exchange Act report.)

• Financial statements must be tagged in Inline XBRL (when the form includes audited 

annual financial statements that are a revised version of financial statements that 

previously were filed with the Commission).

Form 13F

• Form 13F must be filed in XML format. (Form 13F is a quarterly report of certain 

holdings required of all institutions with equity assets of $100 million or more. This 

includes investment advisers, banks, insurance companies, broker-dealers, pension 

funds, and corporations.)

FUND DISCLOSURES IN SCHEDULES UNDER EXCHANGE ACT SECTION 14 

Schedules 14A/14C

• For BDCs, disclosure required by Item 402(v) of Regulation S-K (pay versus 

performance) must be tagged in Inline XBRL. 

• For BDCs, disclosure required by Item 402(w) of Regulation S-K (registrant’s action 

to recover erroneously awarded compensation) must be tagged in Inline XBRL.

• For BDCs, disclosure required by Item 402(x) of Regulation S-K (registrant’s policies 

and practices related to the grant of certain equity awards close in time to the release 

of material non-public information) must be tagged in Inline XBRL.

• For BDCs, disclosure required by Item 408(b)(1) of Regulation S-K (registrant’s 

insider trading arrangements and policies) must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.
20 | U.S. SECURITIES AND EXCHANGE COMMISSION

Endnotes

1 See James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, P.L. 117-263 (2022).

2 See FDTA Section 5825(b).

3 See FDTA Section 5825(c) (“Beginning on the date that is 7 years after the date of enactment of this Act, this 

section shall have no force or effect.”).

4 See FDTA Section 5825(b). A separate provision of the FDTA indicates that the term “machine-readable,” 

when used with respect to data, means data in a format that can be easily processed by a computer without 

human intervention while ensuring no semantic meaning is lost. See FDTA Section 5811 (providing that the 

term “machine-readable” shall have the meaning given in 44 U.S.C. 3502(18)).

5 15 U.S.C. 77g.

6 15 U.S.C. 78m.

7 15 U.S.C. 78n.

8 Including Form SDR discussed in the Appendix at 14.

9 Structured data is data that is tagged to make it machine-readable.

10 See Interactive Data to Improve Financial Reporting, Release No. 33-9002 (adopting release) [74 FR 6776 

(Feb. 9, 2009)] (“Interactive Data to Improve Financial Reporting”) as corrected by Interactive Data to 

Improve Financial Reporting, Release No. 33-9002A [74 FR 15666 (Apr. 7, 2009)].

11 See Interactive Data to Improve Financial Reporting, supra note 10, at 6778 (describing how financial 

reporting in XBRL involves the use of standard tags that cover “financial concepts that can be read and 

understood by software applications”). See also XBRL: What Is It? Why the FASB? Who Uses It?, FASB.

org (Apr. 1, 2021), available at https://www.fasb.org/Page/ShowPdf?path=FASB_in_Focus--XBRL_(4-21).pdf

(“[XBRL] is the open international standard for digital business reporting. XBRL is used to deliver humanreadable financial statements in a machine-readable, structured data format.”).

12 See Interactive Data for Mutual Fund Risk/Return Summary, Release No. 33-9006 (adopting release) [74 FR 

7747 (Feb. 19, 2009)] as corrected by Interactive Data for Mutual Fund Risk/Return Summary; Correction, 

Release No. 33-9006A [74 FR 21255 (May 7, 2009)].

13 See Inline XBRL Filing of Tagged Data, Release No. 33-10514 (adopting release) [83 FR 40846 (Aug. 16, 

2018)] (“Inline XBRL Filing of Tagged Data Adopting Release”).

14 See Inline XBRL Filing of Tagged Data Adopting Release, supra note 13, at Section III.A.1.a.

15 FAST Act Modernization and Simplification of Regulation S-K, Release No. 33-10618 (adopting release) [84 

FR 12674 (Apr. 2, 2019)] as corrected by FAST Act Modernization and Simplification of Regulation S-K; 

Correction, Release No. 33-10618A [84 FR 39966 (Aug. 13, 2019)].

16 See Filing Fee Disclosure and Payment Methods Modernization, Release No. 33-10997 (adopting release) [86 

FR 70166 (Dec. 9, 2021)] (“Filing Fee Disclosure and Payment Methods Modernization Adopting Release”). 

17 See Holding Foreign Companies Accountable Act Disclosure, Release No. 34-93701 (adopting release) [86 FR 

70027 (Dec. 9, 2021)]. 

18 See, e.g., Share Repurchase Disclosure Modernization, Release 34-97424 (May 3, 2023) (adopting release) 

[88 FR 36002 (Jun. 1, 2023)]; Insider Trading Arrangements and Related Disclosures, Release No. 33-

11138 (adopting release) [87 FR 80362 (Dec. 29, 2022)]; Enhanced Reporting of Proxy Votes by Registered 

Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment 

Managers, Release No. 33-11131 (adopting release) [87 FR 78770 (Dec. 22, 2022)] (“Enhanced Reporting 

Adopting Release”); Short Position and Short Activity Reporting by Institutional Investment Managers, 

Release No. 34-94313 (proposing release) [87 FR 14950 (Mar. 16, 2022)]; see also Standard Taxonomies, 

SEC.gov, available at https://www.sec.gov/info/edgar/edgartaxonomies (last modified Apr. 6, 2023) (providing 

information on the current taxonomies supported by the Commission’s Interactive Data program). 

19 See, e.g., Enhanced Reporting Adopting Release, supra note 18 (Section II.G. discussing decision to adopt 

custom XML as Form N-PX reporting data language); Electronic Submission of Orders Under the Advisers 

Act and the Investment Company Act, Confidential Treatment Requests for Filings on Form 13F, and Form 

ADV-NR; Amendments to Form 13F, Release Nos. 34-95148 [87 FR 38943, 38954 (Jun. 30, 2022)] (Section 

IV.B. stating that fund managers submit Form 13F on EDGAR in a custom XML structured data language 

created specifically for Form 13F).

20 See Current EDGAR Technical Specifications, SEC.gov (Apr. 14, 2023), available at https://www.sec.gov/

edgar/filer-information/current-edgar-technical-specifications (last modified Apr. 14, 2023).
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 21

21 See SEC, EDGAR Filer Manual, Volume II, ch. 8-9 (Version 65, Mar. 2023), available at https://www.sec.

gov/edgar/filermanual.

22 See, e.g., Xin Luo et al., Initial Evidence on the Market Impact of the iXBRL Adoption, 37 Acct. Horizons

143 (2021); Yuyun Huang et al., Information Processing Costs and Stock Price Informativeness: Evidence 

from the XBRL Mandate, 46 Austl. J. Mgmt. 110 (2021); Ju-Chun Yen & Tawei Wang, The Association 

Between XBRL Adoption and Market Reactions to Earnings Surprises, 29 J. Info. Sys. 51 (2015); Yi Dong 

et al., Does Information-processing Cost Affect Firm-specific Information Acquisition? Evidence from XBRL 

Adoption, 51 J. Fin. & Quantitative Analysis 435 (2016); Yanan Zhang et al., XBRL Adoption and 

Expected Crash Risk, 38 J. Acct. & Pub. Pol’y 31 (2019); Jap Efendi et al., Do XBRL Filings Enhance 

Informational Efficiency? Early Evidence from Post-earnings Announcement Drift, 67 J. Bus. Rsch. 

1099 (2014). See also J. Efrim Boritz & Won Gyun No, How Significant are the Differences in Financial 

Data Provided by Key Data Sources? A Comparison of XBRL, Compustat, Yahoo! Finance, and Google 

Finance, 34 J. Info. Sys. 47 (2020).

23 See, e.g., Yuyun Huang et al., Insider Profitability and Public Information: Evidence from the XBRL 

Mandate (Sep. 17, 2019), available at SSRN: http://dx.doi.org/10.2139/ssrn.3455105; Bing Li et al., The 

Impact of XBRL Adoption on Local Bias: Evidence from Mandated US Filers, 39 J. Acct. & Pub. Pol’y

106767 (2020). See also Jeong-Bon Kim et al., Information-processing Costs and Breadth of Ownership, 36 

Contemp. Acct. Rsch. 2408 (2019); Nilabhra Bhattacharya et al., Leveling the Playing Field Between Large 

and Small Institutions: Evidence from the SEC’s XBRL Mandate, 93 Acct. Rev. 51 (2018); but see Elizabeth 

Blankespoor et al., Initial Evidence on the Market Impact of the XBRL Mandate, 19 Rev. Acct. Stud. 1468 

(2014).

24 See, e.g., Andrew J. Felo et al., Can XBRL Detailed Tagging of Footnotes Improve Financial Analysts’ 

Information Environment? 28 Int’l. J. Acct. Info. Sys. 45 (2018) (“XBRL Detailed Tagging of Footnotes”); 

Marcus Kirk et al., From Print to Practice: XBRL Extension Use and Analyst Forecast Properties (Aug. 18, 

2016), available at SSRN: http://dx.doi.org/10.2139/ssrn.2826159; Chunhui Liu et al., XBRL’s Impact on 

Analyst Forecast Behavior: An Empirical Study, 33 J. Acct. & Pub. Pol’y 69 (2014); but see Sherwood Lane 

Lambert et al., Analysts’ Forecasts Timeliness and Accuracy Post-XBRL, 27 Int’l J. Acct. & Info. Mgmt. 

151 (2019). See also Alastair Lawrence et al., Investor Demand for Sell-side Research, 92 Acct. Rev. 123 

(2017). 

25 See, e.g., Elizabeth Blankespoor, The Impact of Information Processing Costs on Firm Disclosure Choice: 

Evidence from the XBRL Mandate, 57 J. Acct. Rsch. 919 (2019); Jeong-Bon Ki et al., Does XBRL 

Adoption Constrain Earnings Management? Early Evidence from Mandated U.S. Filers, 36 Contemp. 

Acct. Rsch. 2610 (2019). See also Steve Yang et al., The Impact of XBRL on Financial Statement 

Structural Comparability, in Network, Smart and Open: Three Keywords for Information Systems 

Innovation 193 (Rita Lamboglia et al., ed. 2018); but see Sandip Dhole et al., Effects of the SEC’s XBRL 

Mandate on Financial Reporting Comparability, 19 Int’l J. Acct. Info. Sys. 29 (2015).

26 See, e.g., Yuan George Shan & Indrit Troshani, Does XBRL Benefit Financial Statement Auditing? 54 J. 

Comput. Info. Sys. 11 (2014) (finding XBRL adoption to be negatively associated with audit fees due to 

its facilitation of the auditing process through enhancement of financial statement transparency); Hui Du 

& Kean Wu, XBRL Mandate and Timeliness of Financial Reporting: Do XBRL Filings Take Longer? 15 J. 

Emerg. Tech. Acct. 57 (2018) (finding decreased reporting lags for XBRL filings compared to non-XBRL 

filings from accelerated and large accelerated filers, but not for non-accelerated filers, and postulating that 

accelerated and large accelerated filers have updated their computer system to use a systemic accounting 

ecosystem); Keval Amin et al., The Effect of the SEC’s XBRL Mandate on Audit Report Lags, 32 Acct. 

Horizons 1 (2018) (finding decrease in audit report lags and audit fees following the mandatory adoption of 

XBRL, likely driven at least in part by auditor efficiency gains).
22 | U.S. SECURITIES AND EXCHANGE COMMISSION

27 See Wafa Sassi et al., The Impact of Mandatory Adoption of XBRL on Firm’s Stock Liquidity: A CrossCountry Study, 19 J. Fin. Reporting & Acct. 299 (2021); Chae-Won Ra & Ho-Young Lee, XBRL 

Adoption, Information Asymmetry, Cost of Capital, and Reporting Lags, 10 iBusiness, 93 (2018); SyouChing Lai et al., 23 XBRL Adoption and Cost of Debt, Int’l. J. Acct. & Info. Mgmt. 199 (2015); Tienshih 

Hsieh & Jean C. Bedard, Impact of XBRL on Voluntary Adopters’ Financial Reporting Quality and Cost 

of Equity Capital, 15 J. Emerging Technologies in Acct. 45 (2018); Xin Cheng et al., How Does 

Information Processing Efficiency Relate to Investment Efficiency? Evidence from XBRL Adoption, 35 J. 

Info. Sys. 1 (2021); Olivia Berkman, XBRL: What are the Benefits, FEI Daily (Aug. 29, 2019), available at

https://www.financialexecutives.org/FEI-Daily/August-2019/XBRL-What-are-the-Benefits.aspx (“Berkman, 

XBRL Benefits”).

28 Specific examples of Commission staff usage of machine-readable disclosures are provided in subsequent 

sections.

29 Inline XBRL documents are both human-readable and machine-readable. Custom XML documents are 

rendered into human-readable versions on the Commission’s public-facing website, https://www.sec.gov/edgar/

searchedgar/companysearch.

30 See DERA Data Library, https://www.sec.gov/dera/data; Structured Disclosure RSS Feeds, https://www.sec.

gov/structureddata/rss-feeds-submitted-filings; Application Programming Interfaces, https://www.sec.gov/

edgar/sec-api-documentation.

31 See AICPA, XBRL Costs for Small Companies Have Declined 45% Since 2014 (2018), available at https://

us.aicpa.org/content/dam/aicpa/interestareas/frc/accountingfinancialreporting/xbrl/downloadabledocuments/

xbrl-costs-for-small-companies.pdf (“AICPA, XBRL Costs for Small Companies Have Declined”) (noting a 

45% decline in XBRL costs for small companies from 2014 to 2017).

32 See F. Guo, X. Luo, P. R. Wheeler, L. Yang, X. Zhao & Y. Zhang, Enterprise Resource Planning Systems and 

XBRL Reporting Quality, 35 J. Info. Sys. 77-106 (2021).

33 See AICPA, XBRL Costs for Small Companies Have Declined, supra note 31. While the survey did not specify 

the particular filings covered, XBRL filing requirements for reporting companies at the time of the sample 

included the XBRL (non-Inline) tagging of quarterly and annual financial statements filed in periodic reports 

(e.g., Forms 10-Q, 10-K, and 20-F) and registration statements (e.g., Forms S-1, S-3, and F-1) filed after the 

initial public offering.

34 See letter from Nasdaq, Inc. (Mar. 21, 2019), Request for Comment on Earnings Releases and Quarterly 

Reports, Release No. 33-10588 [83 FR 65601 (Dec. 21, 2018)]. Both surveys were conducted before the 

Commission’s transition from XBRL to Inline XBRL and before the implementation of cover page and other 

tagging requirements for periodic reports.

35 See, e.g., Electronic Submission of Certain Material Under the Securities Exchange Act of 1934; Amendments 

Regarding the FOCUS Report, Release No. 33-11176 (Mar. 22, 2023) (proposing release) [88 FR 23920, 

23993–23994 (Apr. 18, 2020)] (observing a higher number of tagged information in filings from a population 

of Nasdaq-listed companies than in filings from a population of small companies).

36 See Inline XBRL Filing of Tagged Data, Adopting Release, supra note 13. All operating companies that report 

under the Exchange Act must tag their financials using Inline XBRL subject to limited exceptions (e.g., assetbacked securities issuers).

37 Securities Offering Reform for Closed-End Investment Companies, Release No. 33-10771 (Apr. 8, 2020) 

(adopting release) [85 FR 33290, 33337 (Jun. 1, 2020)]; Securities Offering Reform for Closed-End 

Investment Companies, Release No. 33-10619 (Mar. 20, 2019) (proposing release) [84 FR 14448, 14503 

(Apr. 10, 2019)].
JUNE 2023 SEMI-ANNUAL REPORT TO CONGRESS | 23

38 The six EPS cases covered a wide variety of practices that impacted EPS. See In re Interface, Inc., Release Nos. 

33-10854, 34-90018 (Sep. 28, 2020) (settled action) (making unsupported manual accounting adjustments 

that boosted the company’s income); In re Fulton Fin. Corp., Release No. 34-90017 (Sep. 28, 2020) (settled 

action) (reporting valuation allowances in a manner that was at odds with the valuation methodologies 

described in the same filings); In re Healthcare Services Grp., Inc., Release Nos. 33-10967, 34-92735 

(Aug. 21, 2021) (settled action) (failing to timely accrue and disclose material loss contingencies related 

to private litigation); In re Rollins Inc., Release Nos. 33-11052, 34-94742 (Apr. 18, 2022) (settled action) 

(making unsupported reductions in accounting reserves); Securities and Exchange Commission v. Hutchison, 

No. 1:22-cv-02296 (D.D.C. filed Aug. 3, 2022) (litigated action) (alleging that the defendant engaged in the 

practice of shipping future orders ahead of schedule to “pull forward” revenue and failed to disclose this 

practice to investors) and In re Surgalign Holdings, Inc., Release Nos. 33-11088, 34-95415 (Aug. 3, 2022) 

(settled action); and In re Gentex Corp., Release No. 34-96819 (Feb. 7, 2023) (settled action) (reducing an 

accrual for a performance-based bonus program).

39 Information and lists of Commission-Identified Issuers under the Holding Foreign Companies Accountable 

Act are available on the Commission’s website at https://www.sec.gov/hfcaa.

40 See Division of Investment Management, Accounting and Disclosure Information 2019-09, Performance and 

Fee Issues (“Investment Management, Accounting and Disclosure Information 2019-09”), available at https://

www.sec.gov/investment/accounting-and-disclosure-information/performance/adi-2019-09-performance-andfee-issues. 

41 The disclosure review program refers to the staff’s review of fund registration statements, proxy materials, 

shareholder reports and other disclosures.

42 See Investment Management, Accounting and Disclosure Information 2019-09, supra note 40.

43 See Securities Offering Reform for Closed-End Investment Companies, Release No. IC-33836 (adopting 

release) [85 FR 33290 (Jun. 1, 2020)]; Updated Disclosure Requirements and Summary Prospectus for 

Variable Annuity and Variable Life Insurance Contracts, Release No. IC-33814 (adopting release) [85 FR 

25964 (May 1, 2020)].

44 See Filing Fee Disclosure and Payment Methods Modernization Adopting Release, supra note 16.

45 See, e.g., Who’s Using XBRL Data and Why: Case Studies, Morgan Stanley Research (Nov. 2017), available 

at https://www.calcbench.com/home/pdf?name=MS%20XBRL%20Case%20Study%2011-1-2017.pdf.

46 See, e.g., 2019 Pension Review First Take: Flat to Down, Goldman Sachs Asset Management (2020) (an 

example of asset manager use of XBRL data), available at https://www.gsam.com/content/dam/gsam/pdfs/

common/en/public/articles/2020/2019_Pension_First_Take.pdf?sa=n&rd=n (citing an XBRL research software 

provider as a data source).

47 See Berkman, XBRL Benefits, supra note 27.

48 See, e.g., How Third Party Data Providers Use Structured Data and Why; XBRL US, Financial Fundamentals 

Analysis – What Analysts Can Do with Structured Data, XBRL.us (March 2016), available at https://xbrl.us/

events/analyst-webinar-160323/ (“How Third Party Data Providers Use Structured Data and Why”).

49 See, e.g., Paulien Zhu, The Effect of XBRL on Insider Trading Profitability, Erasmus Univeriteit 

Rotterdam (2018) (noting a decrease in the information gap between insiders and individual investors 

associated with XBRL requirements).

50 See How Third Party Data Providers Use Structured Data and Why, supra note 48.

51 See, e.g., J. Eaglesham, How Companies Treat Stock Options When Tallying Cash Flow Perplexes Investors, 

Wall St. J. (Oct. 7, 2022), available at https://www.wsj.com/articles/how-companies-treat-stock-optionswhen-tallying-cash-flow-perplexes-investors-11665098910 (citing an XBRL research software provider as a 

data source).

52 See, e.g., R. Hoitash & U. Hoitash, Measuring Accounting Reporting Complexity with XBRL, 93 Accounting 

Review 259-287 (2018) (“Hoitash & Hoitash, Measuring Accounting Reporting Complexity”).

53 See XBRL Detailed Tagging of Footnotes (and related citations), supra note 24.

54 See Hoitash & Hoitash, Measuring Accounting Reporting Complexity, supra note 52.

55 XBRL: What Is It? Why the FASB? Who Uses It?, FASB.org, available at https://www.fasb.org/page/

PageContent?pageId=/staticpages/what-is-xbrl.html&isstaticpage=true.
24 | U.S. SECURITIES AND EXCHANGE COMMISSION

56 See, e.g., Sonali Basak, The Really, Really Rich Are Playing It Safe, Bloomberg.com (Feb. 17, 2023), 

available at https://www.bloomberg.com/news/newsletters/2023-02-17/how-billionaires-invested-in-thefourth-quarter-of-2022 (example of news media article analyzing 13F data); Travis A. Dyer, The Demand 

for Public Information by Local and Non-local Investors: Evidence from Investor-Level Data, 72 J. Acct. & 

Econ. 1 (Aug. 2021); Ron Kaniel & Pingle Wang, Unmasking Mutual Fund Use During COVID-19 Crisis, 

49 Covid Econ. 172 (Sept. 18, 2020) (example of academic research using custom XML dataset from the 

Commission’s Form N-PORT). 

57 Based on Google Analytics results for Form 13F data set downloads between August 1, 2022 and March 2, 

2023, accessed on March 3, 2023.

58 See, e.g., Press Release, Sec. & Exch. Comm’n, SEC Publishes FY22-26 Strategic Plan (Nov. 23, 2022). See 

also SEC Office of the Chief Data Officer, Data Strategy For Fiscal Years 2022-2026 (Jan. 26, 2023).

59 See, e.g., Foundations for Evidence-Based Policymaking Act of 2018, Pub. L. 115-435 (Jan. 14, 2019). Title II 

of the Foundations for Evidence-Based Policymaking Act of 2018, also known as the Open, Public, Electronic, 

and Necessary (OPEN) Government Data Act, sets forth a framework for managing government information 

as a strategic asset at each stage of the information’s life cycle to promote accessibility and usability.

60 As used in this report, the reference to financial statements means the face of the financial statements and 

accompanying footnotes. The face of the financial statements refers to the statement of financial position 

(balance sheet), income statement, statement of comprehensive income, statement of cash flows, and statement 

of owners’ equity, as required by Commission regulations. References to the financial statements as required 

for interactive data reporting include any required schedules to the financial statements, unless otherwise 

stated.

61 Financial statements in Securities Act registration statements are required to be tagged when physically 

included (i.e., not incorporated by reference) unless the registration statement is for an initial public offering 

(IPO), in which case, the financial statements are not required to be tagged. See Rule 601(b)(101)(i)(A) and 

paragraph (101)(a)(i) of Part II - Information Not Required to be Delivered to Offerees or Purchasers of Form 

F-10.

62 See Asset-Backed Securities Disclosure and Registration, Release No. 33-9638 (adopting release) [79 FR 

57183 (Sep. 24, 2014)] at Section III. The asset-level item requirements are located in 17 CFR 229.1125. The 

required asset-level information includes: data points about the payment stream related to a particular asset, 

such as the contractual terms, scheduled payment amounts, basis for interest rate calculations and whether 

and how payment terms change over time; data points that allow for an analysis of the collateral related to 

the asset, such as the geographic location of the property, property valuation data and loan-to-value (“LTV”) 

ratio; data points about the performance of each asset over time, for example, data about whether an obligor 

is making payments as scheduled; and data points about the loss mitigation efforts by the servicer to collect 

amounts past due and the losses that may be passed on to the investors.

63 The Commission maintains an XML technical specification that includes rules for validation and permitted 

response codes for each XML tag. See EDGAR ABS XML Technical Specification (Version 3.0) (Dec. 19, 

2022), available at https://www.sec.gov/info/edgar/specifications/absxml.

64 Phase-in of the tagging requirements of Items 408(d), 601(b)(26) and 703 of Regulation S-K, Item 16E of 

Form 20-F, and Form F-SR begins in 2024. 

65 See Cross-Border Application of Certain Security-Based Swap Requirements, Release No. 34-87780 (adopting 

release) [85 FR 6270 (Feb. 4, 2020)].

U.S. Securities and 

Exchange Commission

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