U.S. Securities and 

Exchange Commission

SEMI-ANNUAL REPORT 

TO CONGRESS

Regarding Public and Internal Use of 

Machine-Readable Data for 

Corporate Disclosures

December 2023
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

Existing Machine-Readable Data Requirements ................................................................................. 2

ANALYSIS OF THE COSTS AND BENEFITS OF THE USE OF MACHINE-READABLE DATA ...........3

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

Costs.....................................................................................................................................................................4

SUMMARY OF ENFORCEMENT ACTIONS RESULTING FROM THE USE OR 

ANALYSIS OF THE MACHINE-READABLE DATA THAT THE COMMISSION COLLECTS.................. 6

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

DATA THAT THE COMMISSION COLLECTS.............................................................................................................7

Current Applications Used to Analyze Machine-Readable Data .................................................. 7

Current Division Uses of Machine-Readable Data..............................................................................8

PUBLIC USE OF THE MACHINE-READABLE DATA THAT THE COMMISSION COLLECTS..............11

CONCLUSION.........................................................................................................................................................................11

APPENDIX...............................................................................................................................................................................12

ENDNOTES ............................................................................................................................................................................24

DECEMBER 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 

second 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: (1) an identification of which 

corporate disclosures required under specified provisions of the securities laws are 

expressed as machine-readable data and which are not; (2) an analysis of the costs and 

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

the Commission, and issuers; (3) a summary of enforcement actions that result from the 

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

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

This report contains the following new information since the last report: additional 

Commission rulemaking releases adopting or proposing structured data tagging 

requirements; updated statistics in the analysis of the costs and benefits of the use of 

machine-readable data; and additional Enforcement actions resulting from the use or 

analysis of machine-readable data that the Commission collects.

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. Please refer to the Appendix.
2 | U.S. SECURITIES AND EXCHANGE COMMISSION

EXISTING MACHINE-READABLE DATA 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 using eXtensible Business Reporting Language (XBRL),8 which 

is a machine-readable, structured data language used for standardized reporting of 

business information, including information relating to the financial performance of 

companies.9 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.10

Since that time, the Commission has refined many of 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.11 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.12

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

additional collections of information. In 2019, the Commission introduced structured 

data tagging requirements for certain reporting form cover-page data.13 In 2021, the 

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

information related to filing fee calculation.14 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.15 A number of other 

Commission releases have adopted or proposed structured data tagging requirements for 

additional collections of information.16

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

requires some reports and disclosures to be filed in machine-readable eXtensible Markup 

Language (XML).17 In other words, certain filings are submitted using data languages that 

are specific to the particular form being submitted.18 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.19
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 3

Currently, there are 54 forms, schedules, and statements containing disclosures required 

under Securities Act Section 7, Exchange Act Section 13, or Exchange Act Section 14. 

About three-quarters (42 of 54) of those forms, schedules, and statements require some 

machine-readable data, while about one-quarter (12)20 do not require any machinereadable data. Since the last report, the Commission adopted amendments introducing 

structured data tagging requirements for Forms N-8B-2 and S-6 and for Schedules 13D 

and 13G (augmenting by four the number of forms, schedules, and statements requiring 

some machine-readable data).21

Analysis of the Costs and Benefits of the Use 

of Machine-Readable Data

FDTA Section 5825(b)(2)(B) requires an analysis of the costs and benefits of using machinereadable data in corporate disclosure to investors, markets, the Commission, and issuers.22

BENEFITS 

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

respect to investors and, more broadly, to markets, making corporate disclosures machinereadable has decreased information asymmetry between firms and investors by reducing 

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

of firm-specific information), and reducing market inefficiencies and risks.23 Machinereadability has enhanced market competition by, for example, reducing insider advantages 

relative to non-insiders and local investor advantages relative to non-locals.24 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.25 Greater monitoring has driven firms to provide more quantitative disclosure and 

report earnings in a more consistent manner.26 Such benefits may increase over time as tools 

for investor use of machine-readable data become more widely available.

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.27

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.28 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, 
4 | U.S. SECURITIES AND EXCHANGE COMMISSION

and enforcement activities, including as part of its internally developed structured data 

applications.29 Freely usable technical validation rules also allow issuers to check for 

certain errors before the machine-readable data is submitted, which can further streamline 

the compliance process by reducing Commission staff time that would otherwise be 

spent pinpointing and communicating the existence of technical errors to issuers, and by 

reducing issuer time that would otherwise be spent resolving such errors and resubmitting 

the machine-readable data file.30

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.31 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.32

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 gain 

experience and develop new tools to adapt to the requirements.33 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 machinereadable data in their internal enterprise resource planning systems.34 Compliance 

costs also vary based on the type of issuer, because some types of issuers are subject to 

more extensive tagging requirements than other types of issuers. For example, business 

development companies (BDCs) and registered closed-end funds both are subject to Form 

N-2 prospectus and cover page tagging, but BDCs, because they are registered under the 

Exchange Act, are also subject to financial statement tagging and thus incur additional 

tagging compliance costs as compared to registered closed-end funds. Registered closed-end 

funds are subject to Form N-2 prospectus and cover page tagging, but are not subject to 

financial statement tagging, and thus incur lower tagging compliance costs than BDCs do.

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.35 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.36
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 5

The discrepancy may be due to Nasdaq-listed companies generally having longer, more 

detailed and complex financial statements than smaller reporting companies, resulting 

in more time and effort needed to tag discrete disclosures (such as numbers, blocks of 

narrative text, checkboxes, etc.) and ultimately increased compliance costs.37

Both surveys were conducted before the compliance dates for the Commission’s transition 

from XBRL to Inline XBRL and before the implementation of cover page and other tagging 

requirements for periodic reports. For the purposes of the Paperwork Reduction Act, 

Commission staff estimated in the Inline XBRL Filing of Tagged Data Adopting Release, 

that the effect of using Inline XBRL rather than XBRL to tag financial statements would 

be to reduce the existing aggregate average internal burden of 56 hours per response 

for reporting companies by 2 hours during each of the first three years of the Inline 

XBRL requirements, and increase the aggregate average out-of-pocket cost to $6,175 

per response.38 In 2022, Commission staff updated this burden estimate to 53 hours per 

response, while noting that the actual burdens will likely vary among individual companies 

based on the size of their organization.39

In 2023, the Commission stated in a proposed rule release that, based on the staff’s 

understanding of third-party structured data compliance pricing, smaller filers typically 

pay between $1,500 and $5,000 per year for third-party structured data compliance 

services and/or software, while larger filers typically pay between $5,000 and $30,000 

per year for such services and/or software.40 The Commission also cited a number of 

factors that affect the cost of compliance, including the particular filing or submission on 

which structured data is required, the number of data points to be structured, the size 

of the entity providing the data, the industry to which the entity belongs, the number 

of individual users of the structured data compliance software, the extent to which the 

structuring is fully outsourced, and others.41

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. For example, rules which add a limited number of 

newly tagged disclosures to already tagged disclosure forms will generally entail less 

implementation time and cost than rules which add a significant number of newly tagged 

disclosures to disclosure forms that were previously untagged. The Commission also incurs 
6 | U.S. SECURITIES AND EXCHANGE COMMISSION

costs to update taxonomies and schemas and the related EDGAR intake and validation 

functions on a periodic basis.

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’ disclosures and accounting practices and more 

sophisticated analyses of disclosures and accounting practices across wide-ranging 

cross-sections of issuers. Both types of 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-related 

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 during the last four years for violations of the federal securities 

laws for engaging in certain practices that gave the appearance of meeting or exceeding 

consensus earnings-per-share (EPS) estimates.42

Enforcement used and analyzed machine-readable data during the underlying investigation 

of one other action brought in 2023, a settled action against a Colombian conglomerate, 

Grupo Aval Acciones y Valores S.A., and its bank subsidiary, Corporación Financiera 

Colombiana S.A. (Corficolombiana), for violations of the federal securities laws and the 

Foreign Corrupt Practices Act, finding that Corficolombiana bribed government officials in 

Colombia to win an extension to a contract.43 
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 7

Analysis of How the Commission’s Staff 

Uses the Machine-Readable Data That the 

Commission Collects

CURRENT APPLICATIONS USED TO ANALYZE MACHINE-READABLE DATA

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 statement data (including notes and 

schedules), cover-page data, and certain executive compensation data for operating 

companies and BDCs, as well as cover-page data and certain prospectus data for 

registered closed-end funds and BDCs. FSQV facilitates comparative data analyses 

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. 
8 | U.S. SECURITIES AND EXCHANGE COMMISSION

CURRENT DIVISION USES OF MACHINE-READABLE DATA

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).44 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 issuer’s annual report, the location where 

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 staff 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. On September 7, 2023, Corporation Finance 

published a sample letter to companies regarding their XBRL disclosures.45 The 

letter includes sample comments that, depending on the particular facts and 

circumstances, and type of filing under review, Corporation Finance staff may issue 

to certain companies.

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

assessments of compliance with the Commission’s recently adopted pay-versusperformance disclosure requirements. 
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 9

Division of Investment Management (Investment Management) staff also uses machinereadable data in a variety of ways: 

• Investment Management staff uses machine-readable data for fund disclosures to 

readily detect 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.46 The ability to scan across the industry for funds 

with certain disclosures and characteristics enhances Investment Management’s 

disclosure review program,47 informs staff recommendations for Commission 

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

other federal agencies. 

• 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 its use of structured data, the staff published information 

highlighting common tagging issues to facilitate more accurate fund disclosure.48

• Investment Management 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. 

Other Divisions and Offices use machine-readable data in similar ways: 

• 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 requests from other regulators, 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. 
10 | U.S. SECURITIES AND EXCHANGE COMMISSION

• The tagging requirements of filing fee-related information, adopted in 2021,49 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. 
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 11

Public Use of the Machine-Readable Data 

That the Commission Collects

FDTA Section 5825(b)(2)(1) requires a report regarding the “public . . . use of machinereadable data for corporate disclosures.”50 Users of machine-readable corporate disclosures 

include institutional investors,51 asset managers,52 issuers,53 financial analysts and research 

firms,54 individual investors,55 data aggregators,56 the financial press,57 other regulators,58

and academics.59 For example, academic studies indicate that the implementation of XBRL 

data requirements appears to be correlated with increased forecast accuracy by financial 

analysts.60 Also, financial academics have used XBRL data to study topics such as financial 

reporting complexity and dual-class voting structures.61 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.62 Public users retrieve XBRL data by 

downloading them from individual Commission filings and from aggregated datasets that 

Commission staff compiles from individual Commission filings and makes available on the 

Commission’s website.63

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).64 For example, since August 2022 (when the Form 

13F datasets first became available), there have been over 158,000 Form 13F dataset 

downloads.65

Conclusion

The FDTA’s directives coincide with internal Commission and staff efforts66 to improve the 

management and use of data across the agency, consistent with other statutory directives67

as well as overall strategic goals to work more efficiently.
12 | 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 statements68 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 405 also 

addresses the obligation to tag certain fund prospectus, semi-annual report, and annual 

report disclosures in Forms N-1A, N-2, N-3, N-4, N-6, N-8B-2, S-6, and N-CSR. 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). The information in this Appendix is as of November 17, 2023.
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 13

CORPORATE DISCLOSURES IN FORMS AND SCHEDULES UNDER SECURITIES ACT 

SECTION 7

Securities Act Registration Statements69

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. 

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.
14 | U.S. SECURITIES AND EXCHANGE COMMISSION

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 information70 is 

required to be filed under cover of Form ABS-EE in XML format.71 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).

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, SCHEDULES, AND STATEMENTS UNDER 

EXCHANGE ACT SECTION 13

Form 10-K

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

symbol) must be tagged in Inline XBRL.

• Financial statements 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 106 of Regulation S-K (registrant’s cybersecurity risk 

management, strategy, and governance).
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 15

• 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)72 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

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

symbol) must be tagged in Inline XBRL.

• 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).

Form 20-F

• 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.

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

affiliated purchasers) must be tagged in Inline XBRL.

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

• Disclosure required by Item 16K (registrant’s cybersecurity risk management, strategy, 

and governance).

• Financial statements must be tagged in Inline XBRL.
16 | U.S. SECURITIES AND EXCHANGE COMMISSION

• 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 40-F

• 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.

• Financial statements 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 Form ABS-EE must be filed in XML format.

Form 8-K

• Cover page information must be tagged in Inline XBRL.

• Disclosure required by Item 1.05 (disclosure of material cybersecurity incidents).

• 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 6-K

• Disclosure required by General Instruction B (disclosure of material cybersecurity 

incidents).

• 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).
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 17

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 13D and 13G

• The information in Schedules 13D and 13G 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 Form 18-K (annual report form used by foreign 

governments or political subdivisions of foreign governments with securities listed on a 

United States exchange). 
18 | U.S. SECURITIES AND EXCHANGE COMMISSION

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.” 

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.”73

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.

Fund Structured Data Requirements

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

(ETFs), money market funds, variable insurance products, closed-end funds and 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.
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 19

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 including how terms used in fund 

names are defined, 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 including how terms used in fund names are defined, 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.)
20 | U.S. SECURITIES AND EXCHANGE COMMISSION

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.) 

Forms N-8B-2 and S-6

• Information provided in response to Instruction 2 to Item 11 of Form N-8B-2 

must be tagged in Inline XBRL. Form S-6 incorporates the disclosure and tagging 

requirements of Form N-8B-2. (Unit investment trusts registering on Forms N-8B-2 

and S-6 are required to tag how terms used in fund names are defined.) 

No machine-readable data is required in Form N-5.

FUND DISCLOSURES IN FORMS UNDER EXCHANGE ACT SECTION 13 

Form N-CSR

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

ETFs are 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 

closed-end funds are 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.
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 21

• Item 18 of Form N-CSR is 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. 

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 106 of Regulation S-K (registrant’s cybersecurity risk 

management, strategy, and governance) 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.
22 | U.S. SECURITIES AND EXCHANGE COMMISSION

Form 10-Q (Only for BDCs)

• 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 10-Q to the extent this information is updated in 

the Exchange Act report.)

• Financial statements must be tagged in Inline XBRL.

• 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.)

• Disclosure required by Item 1.05 of Form 8-K (disclosure of material cybersecurity 

incidents) 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).

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.)
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 23

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.
24 | 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)(2). 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 See Interactive Data to Improve Financial Reporting, Release No. 33-9002 (Jan. 30, 2009) (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)].

9 See Interactive Data to Improve Financial Reporting, supra note 8, 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.”).

10 See Interactive Data for Mutual Fund Risk/Return Summary, Release No. 33-9006 (Feb. 11, 2009) (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)].

11 See Inline XBRL Filing of Tagged Data, Release No. 33-10514 (Jun. 28, 2018) (adopting release) [83 FR 

40846 (Aug. 16, 2018)] (“Inline XBRL Filing of Tagged Data Adopting Release”).

12 See Inline XBRL Filing of Tagged Data Adopting Release, supra note 11, at Section III.A.1.a. Structured data 

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

13 FAST Act Modernization and Simplification of Regulation S-K, Release No. 33-10618 (Mar. 20, 2019) 

(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)].

14 See Filing Fee Disclosure and Payment Methods Modernization, Release No. 33-10997 (Oct. 13, 2021) 

(adopting release) [86 FR 70166 (Dec. 9, 2021)] (“Filing Fee Disclosure and Payment Methods Modernization 

Adopting Release”). 

15 See Holding Foreign Companies Accountable Act Disclosure, Release No. 34-93701 (Dec. 2, 2021) (adopting 

release) [86 FR 70027 (Dec. 9, 2021)]. 

16 See, e.g., Modernization of Beneficial Ownership Reporting, Release No. 33-11253 (Oct. 10, 2023) (adopting 

release) [88 FR 76896 (Nov. 7, 2023)] (“Beneficial Ownership Reporting Adopting Release”); Investment 

Company Names, Release No. 33-11238 (Sep. 20, 2023) (adopting release) [88 FR 70436 (Oct. 11, 2023)]; 

Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure, Release No. 33-11216 

(Jul. 26, 2023) (adopting release) [88 FR 51896 (Aug. 4, 2023)]; Money Market Fund Reforms, Release No. 

33-11211 (Jul. 12, 2023) (adopting release) [88 FR 51404 (Aug. 3, 2023) (“Money Market Fund Reform 

Adopting Release”]; Share Repurchase Disclosure Modernization, Release No. 34-97424 (May 3, 2023) 

(adopting release) [88 FR 36002 (Jun. 1, 2023)] (“Repurchase Rule”); Insider Trading Arrangements and 

Related Disclosures, Release No. 33-11138 (Dec. 14, 2022) (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 (Nov. 2, 2022) 

(adopting release) [87 FR 78770 (Dec. 22, 2022)] (“Enhanced Reporting of Proxy Votes Adopting Release”); 

Short Position and Short Activity Reporting by Institutional Investment Managers, Release No. 34-98738 

(Oct. 13, 2023) (adopting release) [88 FR 75100 (Nov. 1, 2023)] (“Short Reporting Adopting Release”); see 

also Standard Taxonomies, Sec. & Exch. Comm’n (last modified Apr. 6, 2023), available at https://www.

sec.gov/info/edgar/edgartaxonomies (providing information on the current taxonomies supported by the 

Commission’s Interactive Data program). 
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 25

17 See, e.g., Short Reporting Adopting Release, supra note 16 (Section II.A.4.b discussing decision to adopt 

custom XML as Form SHO reporting language); Beneficial Ownership Reporting Adopting Release, supra

note 16 (Section II.F discussing decision to adopt custom XML as Schedule 13D and Schedule 13G reporting 

language); Money Market Fund Reform Adopting Release, supra note 16 (Section II.F.1.b discussing decision 

to adopt custom XML as Form N-CR reporting language); Enhanced Reporting of Proxy Votes Adopting 

Release, supra note 16 (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 No. 34-95148 [87 FR 38943 (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).

18 See Current EDGAR Technical Specifications, Sec. & Exch. Comm’n (last modified Sep. 18, 2023), available 

at https://www.sec.gov/edgar/filer-information/current-edgar-technical-specifications.

19 See EDGAR Filer Manual, Volume II, ch. 8-9 (Version 67, Sep. 2023), Sec. & Exch. Comm’n, available at

https://www.sec.gov/edgar/filermanual.

20 Including Form SDR discussed in the Appendix at A-5.

21 Investment Company Names, Release No. 33-11238 (Sep. 20, 2023) (adopting release for amendments to 

Forms N-8B-2 and S-6) [88 FR 70436 (Oct. 27, 2023)]; Modernization of Beneficial Ownership Reporting, 

supra note 16 (adopting release for amendments to Schedules 13D and 13G).

22 See FDTA Section 5825(b).

23 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); Raunaq S. Pungaliya & Yanbo Wang, Machine Invasion: Automation 

in Information Acquisition and the Cross-Section of Stock Returns, 64 J. Fin. Markets. (2023); Marcin 

Jaskowski & Daniel Rettl, Information Acquisition Costs and Credit Spreads, 149 J. Banking Fin. (2023).

24 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).

25 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). 
26 | U.S. SECURITIES AND EXCHANGE COMMISSION

26 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).

27 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).

28 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”).

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

sections. Other Financial Stability Oversight Council member-agency staff use the Commission’s machinereadable data to inform their regulatory efforts. See, e.g., Lei Li and Lucas Epstein, Investor Base and Prime 

Money Market Fund Behavior, FEDS Notes, Washington: Board of Governors of the Federal Reserve System 

(Apr. 19, 2022), available at https://doi.org/10.17016/2380-7172.3116 (using custom XML Form N-MFP 

data to examine the relationship between the investor base and behavior of prime money market funds).

30 For example, the Negative Values validation rule can automatically check for instances where negative values 

are reported for elements that must always be positive or zero. See Approved Validation Rules, XBRL US 

(Nov. 4, 2023), https://xbrl.us/data-quality/rules-guidance/; Negative Values, XBRL US (last modified Oct. 

5, 2023), https://xbrl.us/data-rule/dqc_0015/. See also EDGAR XBRL Validation Errors, Sec. & Exch. 

Comm’n (last modified Sep. 19, 2023), https://www.sec.gov/structureddata/edgarvalidationerrors; EDGAR 

XBRL Validation Warnings, Sec. & Exch. Comm’n (last modified Sep. 19, 2023), https://www.sec.gov/page/

osd_edgarvalidationwarnings.

31 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.

32 See DERA Data Library, Sec. & Exch. Comm’n (last modified Nov. 3, 2023), https://www.sec.gov/dera/data; 

Structured Disclosure RSS Feeds, Sec. & Exch. Comm’n (last modified Mar. 11, 2022), https://www.sec.gov/

structureddata/rss-feeds-submitted-filings; Application Programming Interfaces, Sec. & Exch. Comm’n (last 

modified Nov. 9, 2022), https://www.sec.gov/edgar/sec-api-documentation.

33 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).
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 27

34 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).

35 See AICPA, XBRL Costs for Small Companies Have Declined, supra note 33. 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) that included 

a price or price range and were filed after the first 10-Q, 20-F, or 40-F following the company’s initial public 

offering. 

36 See letter from Nasdaq, Inc. (Mar. 21, 2019), available at https://www.sec.gov/comments/s7-26-18/s72618-

5177722-183507.pdf, Request for Comment on Earnings Releases and Quarterly Reports, Release No. 33-

10588 [83 FR 65601 (Dec. 21, 2018)].

37 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 (Apr. 

18, 2023)] (“Electronic Submission Proposing Release”) (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). 

See also Bok Baik et al., Organizational Complexity, Financial Reporting Complexity, and Voluntary 

Disclosure, presented at the Am. Acct. Ass’n 2020 Virtual Ann. Meeting and Conf. on Teaching & Learning 

(Aug. 13, 2020), https://doi.org/10.26226/morressier.5f0c7d3058e581e69b05d16d (finding “firm complexity 

is positively associated with financial reporting complexity holding all else constant”).

38 A “response” is a filing that requires Inline XBRL tagging; see Inline XBRL Filing of Tagged Data Adopting 

Release, supra note 11, at 40869. These figures represent the costs of tagging financial statements in Inline 

XBRL (not the costs of switching from XBRL to Inline XBRL) for operating companies subject to financial 

statement tagging requirements. 

39 See OMB, Supporting Statement for the Paperwork Reduction Act Information Collection Submission For 

Interactive Data: OMB Control Number 3235–0645, Attachment A (Jun. 6, 2022), available at https://omb.

report/icr/202203-3235-001/doc/122014900.

40 See Electronic Submission Proposing Release, supra note 37, at 23986. Some compliance service providers 

publicly disclose or advertise pricing information on their websites. See, e.g., EDGAR Filing Services, 

Advanced Comp. Innovations, Inc., http://www.edgar-services.com/ (last visited Oct. 12, 2023); CompSci 

Resources, https://www.compsciresources.com/pricing (last visited Oct. 12, 2023). Other compliance service 

providers do not publicly disclose pricing information on their websites, instead requiring individual pricing 

consultations.

41 See Electronic Submission Proposing Release, supra note 37, at 23986.

42 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 

urging subordinates to ship future orders ahead of schedule and report the revenue early, among other things, 

and failed to disclose this practice to investors) and In re Surgalign Holdings, Inc., Release No. 33-11088 

(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, among other things).
28 | U.S. SECURITIES AND EXCHANGE COMMISSION

43 See In re Grupo Aval Acciones y Valores S.A. and Corporación Financiera Colombiana S.A., Release No. 34-

98103 (Aug. 10, 2023) (settled action) (finding that Grupo Aval Acciones y Valores S.A (“Grupo Aval”) and 

Corporación Financiera Colombiana S.A (“Corficolombianiana”) violated the internal accounting controls 

and books and records provisions of the federal securities laws and that Corficolombianiana violated the 

antibribery provisions of the Foreign Corrupt Practices Act and ordering Grupo Aval to pay approximately 

$40 million in disgorgement and prejudgment interest. Corficolombiana also agreed to enter into a deferred 

prosecution agreement with the U.S. Department of Justice and to pay more than $20 million to settle 

criminal charges.)

44 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.

45 See Division of Corporation Finance, Sample Letter to Companies Regarding Their XBRL Disclosures, Sec. 

& Exch. Comm’n (Sep. 7, 2023), https://www.sec.gov/corpfin/sample-letter-companies-regarding-their-xbrldisclosures. 

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

Fee Issues, Sec. & Exch. Comm’n (Oct. 2, 2019) (“Investment Management, Accounting and Disclosure 

Information 2019-09”), https://www.sec.gov/investment/accounting-and-disclosure-information/performance/

adi-2019-09-performance-and-fee-issues. 

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

shareholder reports and other disclosures. 

48 See Investment Management, Accounting and Disclosure Information 2019-09, supra note 47.

49 See Filing Fee Disclosure and Payment Methods Modernization Adopting Release, supra note 14. The 

Commission opted to phase in the structuring requirements over time but otherwise require compliance upon 

effectiveness of the rules. For large accelerated filers, the compliance date for the structuring requirements is 

for filings submitted on or after July 31, 2024. For accelerated filers, certain investment companies that file 

registration statements on Forms N-2 and N-14, and all other filers, the compliance date for the structuring 

requirements is for filings submitted on or after July 31, 2025. See id. at Section II.A.6. 

50 See FDTA Section 5825.

51 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.

52 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).

53 See Berkman, XBRL Benefits, supra note 28.

54 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 (Mar. 2016), available at https://xbrl.us/

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

55 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).

56 See How Third Party Data Providers Use Structured Data and Why, supra note 55.

57 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-options-whentallying-cash-flow-perplexes-investors-11665098910 (citing an XBRL research software provider as a data 

source).
DECEMBER 2023 SEMI-ANNUAL REPORT TO CONGRESS | 29

58 See Investment Management, Accounting and Disclosure Information 2019-09, supra note 47.

59 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”).

60 See XBRL Detailed Tagging of Footnotes (and related citations), supra note 25.

61 See Hoitash & Hoitash, Measuring Accounting Reporting Complexity, supra note 59; Rimona Palas et al., 

Does Wedge Size Matter? Financial Reporting Quality and Effective Regulation of Dual-class Firms. Fin. Res. 

Letters 54 (2023) (using XBRL financial statement data to assess reporting patterns in firms with dual-class 

share structures).

62 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.

63 For example, the Commission’s quarterly XBRL datasets for mutual fund prospectus risk/return summaries 

garnered over 13,000 page views from September 2022 to September 2023, according to a Google Analytics 

query of the Commission’s XBRL dataset webpage, which is available at https://www.sec.gov/dera/data.

64 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-the-fourthquarter-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). 

65 Based on Google Analytics results for Form 13F data set downloads between August 1, 2022 and October 11, 

2023, accessed on October 12, 2023.

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

available at https://www.sec.gov/news/press-release/2022-210. See also SEC Office of the Chief Data Officer, 

Data Strategy For Fiscal Years 2022-2026 (Jan. 26, 2023), available at https://www.sec.gov/files/2022-ocdodata-strategy-fy2022-2026.pdf. 

67 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.

68 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.

69 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.
30 | U.S. SECURITIES AND EXCHANGE COMMISSION

70 See Asset-Backed Securities Disclosure and Registration, Release No. 33-9638 (Sep. 4, 2014) (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.

71 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. 019, 

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

72 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, Form F-SR, and Item 14 of Form N-CSR begins in 2024. The Repurchase Rule, which includes 

these tagging requirements, is stayed pending further Commission action. See In the Matter of Share 

Repurchase Disclosure Modernization, Release No. 34-99011 (Nov. 22, 2023). 

73 See Cross-Border Application of Certain Security-Based Swap Requirements, Release No. 34-87780 (Dec. 18, 

2019) (adopting release) [85 FR 6270 (Feb. 4, 2020)].

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