Guidance regarding implementation of Inline XBRL rules

In 2018, the SEC adopted rules requiring the use of Inline eXtensible Business Reporting Language, often referred to as XBRL, for filings including financial statement information and fund risk/return summary information.  The Inline XBRL requirements recently became effective (in connection with filing a Form 10-Q for a fiscal period ending on or after June 15, 2019) for operating companies that are large accelerated filers that prepare their financial statements in accordance with U.S. GAAP and will be phased in for other operating companies over the next two years.  On August 20, 2019, the SEC released its first Compliance and Disclosure Interpretations (or CDIs) relating to the new Inline XBRL rules, which relate to technical matters that have arisen in initial filings, including:

  • how issuers should identify the Interactive Data Files in a filing containing Inline XBRL;
  • the application of the Inline XBRL requirements to Form 8‑K;
  • the application of the Inline XBRL requirements to issuers that elect to begin providing Inline XBRL prior to the applicable phase-in date; and
  • the application of the Inline XBRL Requirements to foreign private issuers.

The new CDIs are set forth as questions 101.01 through 101.09 here.

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