TheCorporateCounsel.net

In February, John shared a scoop from Orrick’s Bobby Bee that the SEC has to submit a “Semi-Annual Report to Congress on Machine Readable Data for Corporate Disclosures” every 180 days until December 23, 2029. The report must identify which corporate disclosures are expressed as machine-readable data and which are not, so we get regular 6-month updates of an iXBRL form check tool from the SEC.

The latest and greatest (from June 2024) was recently posted on the SEC’s “Reports and Publications” page. See the Appendix of the report. Here’s the summary:

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) do not require any machine-readable data.

Since the last report, the Repurchase Rule was vacated, thereby eliminating Form F-SR, and the Commission adopted a new rule under the Exchange Act requiring reporting on Form SHO, a new disclosure form.

Here’s the Form 10-Q-related excerpt from the Appendix:

– Cover page information (e.g., registrant 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) of Regulation S-K (registrant’s insider trading arrangements and policies) must be tagged in Inline XBRL.

– Meredith Ervine