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The clock is loudly ticking for those issues who are required to disclose resource extraction payments on Form SD by the upcoming September 26, 2024 due date. You can find the latest guidance of the resource extraction disclosure requirements in the July-August 2024 issue of The Corporate Counsel and in our “Resource Extraction” Practice Area. In addition, a number of resource extraction issuers have filed their Form SD early, so there are examples on EDGAR of how issuers have approached the payments disclosure.

One element to not forget when preparing the Form SD filing is that the information presented in Item 2.01 to the Form SD must be tagged using standard XBRL, and not the Inline XBRL that we have all become used to in most other filings. If a resource extraction issuer is submitting an alternative report, that report will also need to be tagged using XBRL. To assist with this task, the SEC published a “Resource Extraction Payments (RXP) Taxonomy Guide” back in June 2023 to facilitate tagging the Item 2.01 exhibit. It includes a number of examples of resource extraction payments disclosure and how it should be tagged.

Given that this is the first go-round for these Form SD reports, filers should build in some extra time to get the XBRL tagging done prior to filing.

– Dave Lynn