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ISACAXBRL Considerations
Sept. 29, 2011
www.pwc.com
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Discussion Items
- Key messages
- Basics of XBRL
- The SEC Mandate
- Common Errors and Issues
- Implementation Considerations
- Who is Using XBRL
- What is Going on Around the World
- What can you do
- Appendixes
◦ Data Aggregators vs. Company Reports
◦ Resources
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Key Messages
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Key Messages
In the short term, key messages include:
• Supply Chain Standardization rather than a compliance requirement
• Review company report via XBRL analytical tools rather than viewer or rendering
• Build-in rather than bolt-on to enhance reporting processes and controls
• Enhances reporting/review processes not just Ks & Qs
• Broadcast directly to stakeholders to enhance effectiveness of communications
• Enables social processes (publishing, analytical, review)
• Currently in use by broad range of analysts (social analytics)
• Redefines ‘convergence’ and provides economic incentives for IFRS adoption in countries around the world (SBR) 4
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Basics on XBRL
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What is XBRLInternational supply chain standardization effort• Designed specifically to address pervasive process problems
• Mandated by economics and regulators (including US SEC)
• Applicable to business information, related business rules, formulas, controls, processes, resources, etc.
• “Bar Code” for Business Information
- Adds structure (meaning) to company disclosures
- Enhances processing and reuse
- Disclosure neutral
- Taxonomies available for: US/IFRS GAAP, other statutory GAAP, MD&A, CSR, GRI, Proxy, Corp Actions, Legers/subledgers, other non-financial
• Process enhancements are available and being realized
• Examples: Traditional Rendered XBRL Raw XBRL
http: //www.xbrl.org and http: //xbrl.us
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1. Rail Road
2. Telegraph
3. Electricity
4. Telephone
5. Shipping
6. Products
7. Networking
8. Internet
9. Information
A. RJ 11
B. 40’ x 8.5’ x 8’
C. UPC
D. HTML / SOAP / Web Services
E. 4’ 8.5”
F. RJ 45
G. Rosettanet, MDDL, XBRL
H. Morse Code
I. 120V, 60Hz
From proprietary to infrastructure Match the proprietary ‘technology’ to the standard that transformed it to ‘infrastructure’.
What were once proprietary technologies were transformed into ‘infrastructure via standards. XBRL is the standard for Business Information.
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What is XBRL?Supply Chain Standard
• UPC/Bar Code for Business Information
• Specifically designed to:
• Enhance Information Transparency and Reuse
• Improve Data Quality through source validation and analysis
• Enable collaborative development and use of
formulas/models/rules
• Standardize presentation concepts for collaborative use
• Provide standardization for broad range of business
information concepts
• Put Users (not IT/software) in control
• Streamline business processes while lowering costs
• Similar impacts to how the UPC/Bar Code has transformed the retail
grocery supply chain and processes
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What is it A structured document
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XBRL is more than just tagging business information
CalculationsCash = Currency + Deposits with others
CalculationsCash = Currency + Deposits with others
FormulasCash ≥ 0
FormulasCash ≥ 0
References• Stat Regulation 1.2.(a)• IFRS Bound Volume
References• Stat Regulation 1.2.(a)• IFRS Bound Volume
DefinitionsRelated to Liquid Assets
DefinitionsRelated to Liquid Assets
ContextsUS $XFYE 2009 Budgeted
ContextsUS $XFYE 2009 Budgeted
XBRL<cash>“200”
XBRL<cash>“200”
LabelCash in Bank
LabelCash in Bank
• Multi-dimensional business and financial data representations
• Flexibility of business reporting vocabularies (i.e. taxonomies)
• Mathematical relationships between concepts
• Flexibility about how to present information to users
PresentationsCash & Cash Equivalents
PresentationsCash & Cash Equivalents
Presentationéquivalents d'argent comptant et d'argent comptant
Presentationéquivalents d'argent comptant et d'argent comptant
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Where is it relevant All along the supply chain
Others include: Corporate Actions, Mortgage Backed Securities, Risk & Return, Governance/Risk & Compliance, etc.
The business reporting supply chain
Processes
XBRL Global ledger
• SCOA• Payables Ledger• Receivables Ledger• Fixed Asset Ledger• Others
Transaction layer
• Rosettanet• ACORD • MISMO• FPML• Others
Businessoperations
Internalbusinessreporting
Externalbusinessreporting
XBRL external reporting
• Local GAAP • IFRS• GRI G3• WICI• KPI’s
Investment,lending,regulation
Economic policymaking
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The SEC Mandate
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Basics on XBRL and the SEC MandateUS SEC Mandate summary
Improving transparency and reuse
• XBRL Mandate impacting all public registrants including US GAAP/IFRS filers
- Companies = GAAP F/S
- Mutual Funds = Risk & Return Disclosures
• 3 year phase-in commencing for periods ending after June 15, 2009
- Year 1 = basic f/s and notes as ‘block text’
- Year 2 = basic f/s and note disclosures in detail
• 30 day grace period for initial submission in first two years
• Mandatory web site posting
• Limited Liability Provisions for first 2 years
• Mandate specifically excludes audit; voluntary AUPs are occurring
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US SEC Mandate summary
June 30, 2009 June 30, 2010 June 30, 2011 June 30, 2012 June 30, 2013
Large Accelerated Filers (~500 Companies)>$5B public float
Detailed Tagging of financials
Block tagging of notes/schedules
Detail & block tagging of notes/schedules
Liability “As Furnished”
Liability “As Furnished”
Liability “As Filed”
All Other Large Accelerated Filers (~1,200 Companies)
Detailed Tagging of financials
Block tagging of notes/schedules
Detail & block tagging of notes/schedules
Liability “As Furnished”
Liability “As Furnished”
Liability “As Filed”
All Remaining Filers (~7,200 Companies)
Detailed Tagging of financials
Block tagging of notes/schedules
Detail & block tagging of notes/schedules
Liability “As Furnished”
Liability “As Furnished”
Liability “As Filed”
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Basics on XBRL and the SEC MandateKey learning's & observations on initial XBRL submissionsCompliance with the Edgar Filer Manual
• 200+ fairly complex technical rules; some require financial reporting judgments
• Some validation rules are included within the SEC filing processes
Preparation and review processes and controls
• Start early and consider a ‘test’ run submission
• Knowledge of company financial statements more relevant than XBRL expertise
• Adjust reporting timeline to accommodate XBRL submission process
• Focus early on company specific taxonomy extension(s) to USGT
• Consider assessment of EDGAR Filer Manual rule compliance
• Internal reporting validation and analytical rules and controls
Consider SEC test filing to assess ‘some’ validation rules
Consider SEC Previewer to assess presentation views
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• Process implications of concurrent submission of the XBRL Exhibit
- Compression that exists in many companies reporting timetables
- Manual nature of such processes
- Is your current process sustainable, especially in the context of the detailed tagging required in 'Year 2'?
- Validation rules can be applied by companies and their constituents, including regulators and potentially used to:
◦ Enhance the quality of reported disclosures
◦ Enhance the quality of analysis of reported disclosures by third parties
Basics on XBRL and the SEC MandateKey learning's & observations on initial XBRL submissions (continued)
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Insights on 2011 USGT
• 2011 USGT available from FASB on January 18, 2011
http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1176157088011
• SEC Approved 2011 USGT effective February 28, 2011
http://www.sec.gov/info/edgar/edgartaxonomies.shtml
“The SEC staff strongly encourages companies to use the most recent version of the US GAAP taxonomy release for their Interactive Data submissions to take advantage of the most up to date tags related to new accounting standards and other improvements. However, due to the timing of the release of the US GAAP 2011 taxonomy in conjunction with the phase-in of the Rule, companies will be permitted to continue to use the US GAAP 2009 taxonomy.”
• Fiscal year-end transition may facilitate comparative analysis
• Additional elements may reduce some company specific extensions
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Scope of Disclosure TaggingHow granular is XBRL taxonomy mapping applied?
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Scope of Disclosure TaggingHow granular is XBRL taxonomy mapping applied?
Examples of Amounts NOT Required to be tagged:
- A footnote number itself- 1% fat milk- A meal of less than 500 calories- At an altitude of 27,000 feet- Depreciated using Section 179- No help was available within 2
miles- $1.99 pancake special- Docket no. 34-4589
- 21nd district court- FASB ASC 605-40-15- Drilling 700 feet- Open new stores no less than 2
miles from existing stores- Founded a new subsidiary in
2009- At least 20 entries under 250
calories
Source: March 23 SEC webcast
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Common Errors and Issues
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SEC Staff Observations on XBRL submissions
SEC Staff Observations (from June 15, 2011)
Observations for filers tagging the face of the financial statements
• Format of the statements
• Negative Values
• Extended elements
• Completeness of tagging
Additional Observations for Detail Tagged Filings:
• Modeling of Level 4 tagging
• Negative Values
• Units
• Other observations from certain filings include: monetary values, Article 12 schedules, footnotes, and calculation links.
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SEC Staff Observations on XBRL submissions
SEC Staff Observations (from November 1, 2010)
• Negative Values - Errors in positive and negative signs. (50% of errors)
• Extending for an element where an existing US GAAP Taxonomy element is appropriate
• Inappropriate Axis and Member use
• Lack of use of the US GAAP modeling for Axis and Members
• Tagging completeness — Parenthetical Amounts
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Other Observations on XBRL Submissions
• Company and period specific information in elements
• Calculation errors and anomalies, particularly in tables in the notes to the financial statements
• Supplemental Schedules omitted
• Company specific extensions created but unused
• Problems with dimensions and scenarios
• Errors in the use of decimals. (e.g., 0 rounded to the nearest 1,000,000)
• Tagging same number twice with multiple tags
• Failure to tag a number (as defined by the SEC)
• Failure to structure all footnotes included in the notes to the financial statements
• Mistakes in the unit of measure (e.g., incorrect use of “pure”)
• Use of future date contexts (e.g., future debt payments)
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Common Causes
• Company review based on Excel reports and not the underlying XBRL instance. Lack of tools used by management to adequately review the taxonomy/instances
• Tagging performed by individuals without full understanding of Company's financial reporting
• Tagging performed by individuals without a full understanding of XBRL and the SEC EDGAR Filer Manual
• Common and pervasive misunderstandings by service providers
• Focus on speed and lower cost over accuracy and completeness in tagging
• Time crunch required by outsourcing solution and limited turn-around time
• Lack of a defined process and timeline
• Focus on rendering rather than the structure of the disclosures
• Expectation gap of financial printers (lack of GAAP reporting expertise)
• Not a management priority related to liability protection for a 2 year period
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Modified Liability Provisions
Modified liability provisions – what does it mean?
• Submissions are subject to the federal securities laws in a modified manner when filed within 24-months of the first required filing but no later than October 31, 2014, provided:
• Good faith attempt
• Prompt correction
• Voluntary filings do not count towards the 24-month period
• The 24-month period is exclusive of a grace period
• Group 1 companies– be sensitive to the expiration of the modified liability provisions
• No change to external auditor involvement26
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When does the Modified Liability Provisions end?
Question: When does the SEC's Interactive Data Modified Liability Period end for companies currently submitting their XBRL Exhibits?
Answer: Guidance is provided within the SEC final rule here in section 232.406T which states:
"(d) Temporary section. Section 232.406T is a temporary section that applies to an Interactive Data File submitted to the Commission less than 24 months after the electronic filer first was required to submit an Interactive Data File to the Commission pursuant to § 232.405, not taking into account any grace period, but no later than October 31, 2014.“
Further, footnote 231 of the final rule provides additional guidance:
"For example, a large accelerated filer first required to submit interactive data for financial statements in a Form 10-Q for the fiscal period ended June 30, 2009, would be required to submit the interactive data by 30 days after the Form 10-Q's August 10, 2009 due date but its 24-month period would end August 10, 2011”.
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Implementation Considerations
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http://xbrl.us/Learn/Pages/catalog2.aspx
http://xbrl.us/Learn/Pages/ToolsAndServices.aspx
http://www.xbrl.org/tools/
Implementation Options
Implementation options Some potential vendors
“Bolt-On” – OutsourcingBowne, RR Donnelley, Merrill, EDGARizerX,BusinessWire, etc.
“Bolt-On” – In-houseRivet Software Crossfire, Fujitsu, Corefilings, etc.
“Built-in” – Report writer/consolidation
Clarity Systems FSR, Trintech Unity, SAP Disclosure Management, Oracle Disclosure Management, Tagetik, Rivet Software Crossfire, Webfilings, etc.
“Embedded” – Ledgers & Sub-ledgers
Altova (MapForce), Stylus (Studio), Fujitsu(XWand), Hitachi, Rivet Software, all ERPvendors, etc.
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Outsourcing
Expectations - Capacity during peak filing periods given scale of market
requirements- Turnaround times (48 to 72+ hours) - Service Level Agreements – turn-around time and ‘hand-offs’ - Confidentiality of data and transmissions, and ‘portability’ of
work productQuality control
- Review of XBRL report (vs. Excel mapping table, viewer rendering)
- Validation (EFM objective and subjective rules) - Review and validation tools - Issuer review and approval process- Knowledge of F/S and financial reporting – company-specific
extensions- XBRL expertise and instance document preparation experience
Other- Ownership of mapping IP and company specific extensions- Process implications, including detailed tagging in ‘Year 2’
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Beyond compliance with the SEC’s XBRL MandateAdoption alternatives pros and consImplementation options
Year 1
Mapping of 300 disclosure elements
Year 2
Mapping of 3,000+ disclosure elements
“Bolt-On” - mapping done subsequent to report completion and repeated for each report.
Pros
• Convenient mapping
• Low impact implementation
Cons
• Incremental Cost & Time
• Manual Controls
• Compresses reporting timeline
Pros
• Limited impact on existing process
Cons
• Repetitive mapping
• Incremental Cost & Time
• Manual Controls
• Compresses reporting timeline
“Built-in” - mapping done within reporting application and available for all subsequent reports.
Pros
• Lower Cost & Time
• Automates Controls
• Streamlines assembly & review processes
Cons
• One-time implementation effort
Pros
• Lower Cost & Time
• Automates Controls
• Streamlines assembly & review processes
• Platform for enhanced BI
Cons
• n/a
Standardize to Streamline Compliance Processes
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Current Manual Assembly/Review ProcessesCommon Year 1 ‘Bolt-on’ approach adds cost/time
ERP
Consolidation
Supplemental Data
10-Q in WordERP
ERP
10-Q in HTML
10-Q in XBRL
Outsourced and Bolt-on approaches
1. Linear Document Review
2. Distributed Document Review
3. Manual Assembly via two processes
4. Manual Spreadsheet Aggregation
5. Manual Queries of sub-ledgers
Review and Check Review and
Check
4
1 2
3
5
← Largely unaffected | Affected →
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Edgar
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Built-in Enables Enhanced ProcessesApplying standards earlier enables streamlined processes
ERP
Consolidation
Supplemental Data
ERP
ERP
Edgar
1. Contextual Review
2. Collaborative Review
3. Automated Assembly via a single process
4. Automated Aggregation
5. Automated Queries of sub-ledgers
4
5
Report Writer
10-Q in XBRL,Word, PDF
31 2
25% to 50%+ cost/time enhancements
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Benefits Beyond Compliance
Assembly process manual automated
centralized decentralized
Review process linear contextual
distributed collaborative
Controls manual streamlined/automated
Streamlined reports (not just 10K/10Q)
• Board of Directors Package / Audit Committee Package
• Press Releases, Quarterly Statistical Summary, Proxy
• Significant Accounting Issues Memo, Emerging Accounting Issues, Rep Letters
• Tax Returns, Statutory Financial Reports, Business Registration Documents
• Others
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US Registrants Using Built-In Solutions
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6/30
/200
9
9/30
/200
9
12/3
1/20
09
3/31
/201
0
6/30
/201
0
9/30
/201
0
12/3
1/20
10
3/31
/201
1
6/30
/201
1
Companies
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Some Relevant Vendors and Tools
“Built-in”• Altova MapForce• Clarity FSR• Corefilings Seahorse• Oracle Disclosure Manager• Rivet Crossfire Controller• SAP Disclosure Management • Tagetik• Trintech XFR• Webfilings
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“Bolt-on”• AltovXML Spy• EdgarizerX• Fujitsu XWand• Rivet Crossfire Compliance
Analytical• Altova StyleVision• Arelle•Corefiling Magnify•Fujitsu Interstage XWand•XBRLCloud•XBRL US Consistency Suite
http://xbrl.us/Learn/Pages/catalog2.aspx and http://xbrl.us/Learn/Pages/ToolsAndServices.aspx
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Software Considerations
• Nature (client server vs. SAAS)
• Pricing (size, volume, duration based)
• User-friendly features (US GAAP Taxonomy views, mapping, validation)
- Facilitate company-specific extensions
- Validate SEC public validation rules, EFM, and other ‘rules’
- Import, view and manage multiple taxonomies
- Wizard based taxonomy mapping features for tables, multiple elements
• Workflow and Controls
- Adequate Workflow and Control Administration
- Extensibility to broad domain of reporting participants
- Validation and analytical capabilities
• Technical Capabilities
- Compliance with XBRL Technical Specifications and relevant taxonomies
- Interoperability with existing company software applications
- Produce AND Consume XBRL (including iXBRL)
- Timeliness of support (access and responsiveness; 2011 USFRT; EFM versions; etc.)
Refer to “Appendix 1: XBRL Tool Considerations” for a list of questions to ask
the vendors.
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XBRL Tool ConsiderationsSome key questions to ask the vendors
1. Is the tool simply a bolt on that creates XBRL documents, or does it support the full creation of financial statements?
2. Does the tool allow for conditional assembly of the financial statements (e.g. automatically include certain MD&A sections based on performance)?
3. Can you extend the taxonomy using the tool itself, or do you need an external taxonomy editor?
4. Does the tool allow you to tag the same data with multiple taxonomies (e.g. IFRS and US GAAP)?
5. Does the tool currently support iXBRL? Are there plans for future support?
6. Does the tool allow you to quickly compare taxonomies (US GAAP 2009 versus 2011) and identify the impact on your instance document?
7. Does the tool suggest tags for the various concepts in the report? Is the search tool for tags easy to use? Is there taxonomy mapping wizard functionality? If so, how robust are its capabilities?
8. How does the tool allow you to rollforward from one period to the next?
9. Does the tool have appropriate security controls (segregation of duties, login and access by user, role, etc.)?
10. Does the tool enable workflow processes around the creation, maintenance and review of company reports?
11. Does the work flow functionality align to your company's demands? Does it enable decentralized mapping to source systems as well as to the relevant taxonomies?
12. Can the tool interface with your consolidation software? Can the tool import XBRL GL data?
13. Can the application consume XBRL from internal and/or external sources via Web Service and/or RSS feed?
14. Can the tool interface with your document management
system (e.g. Documentum)?15. Can the tool create units on the fly? Does the tool support
link:footnotes?16. Does it make HTML/XBRL GL a true transparent and
parallel process? Does changing the presentation order update the presentation linkbase?
17. What kind of validations does the tool allow you to perform on the XBRL instance document? Most tools validate that the instance document will be accepted by the SEC. Are there validations built in that check more sections of the Edgar Filer Manual? Does the tool allow you to write and check for your own validation rules?
18. Does the tool interoperable with the XBRL US Consistency Suite to enable taxonomy mapping and consistency validation assessments?
19. Does the tool allow you to easily check for calculation inconsistencies and easily identify all calculation relationships in the document?
20. Does the tool allow you to easily identify the attributes of each fact (e.g. data type, unit, decimals, balance, etc.) in a standard report?
21. Does the tool enable EDGARization of company reports and submission directly to Edgar? Does it facilitate corporate website posting?
22. Does the tool allow you to run comparative analysis on your peers of both numerical and narrative disclosures?
23. How quickly does the vendor respond and provide updates related to new issuances of the US GAAP taxonomy and the Edgar Filer Manual?
24. Does the tool fit within your IT infrastructure (e.g. client server) or is it deployed via a Cloud implementation?
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Project Planning
Project team:- Core group to include supporting accounting teams- Assess group and/or individuals in charge of tagging efforts- Train team on Taxonomy mapping and extension process
◦ Need an efficient means of building/managing taxonomy components
Workflows:- Define workflow for mapping and review efforts (divisional teams,
topical groups, etc.) - Develop validation processes and acquire relevant tools- Assess process and control modifications and ICFR implications
Policy Matters:- Modified liability provision timeline for company- Company specific extensions (documentation support)
Timeline: - Mandated compliance reports- Priorities for other relevant reports, materials and risk assessments
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Taxonomy Considerations
• US GAAP Taxonomy – SEC Approved Taxonomies
- 2009 Taxonomy
- 2011 Taxonomy“The SEC staff strongly encourages companies to use the most recent version of the US GAAP taxonomy release for their Interactive Data submissions to take advantage of the most up to date tags related to new accounting standards and other improvements.”
• Hierarchical structure = Conceptual Accounting Framework
• Commercial & Industrial Taxonomy view
- Browse
- Search
- Definitions
- References
- Calculations
• IFRS Taxonomy
• Corporate Actions Taxonomy
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Compliance Process Considerations
Bolt-on / Outsourcing solutions are simply not scalable or sustainable
Transition to Built-in approach to streamline and automate current manual report assembly and review process steps as well as lay a foundation for other efficiencies
Anticipate SBR styled compliance environment in the next 3 to 5 years
IFRS relevant to compliance reporting across broad range of countries
Leverage Built-in reporting processes for compliance requirements in all jurisdictions; minimize current territory specific manual compliance reporting shops
Provide greater oversight and governance from above
Greater control for reconciliation between regions, reporting requirements
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Who is using XBRL?
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Why analysts use XBRL?Enhance cost and time to access, reuse , analyze, report and act• Traditional data sources are error prone, incomplete, slow
to market and expensive
• Company has no control or input on third party tagging (Please see Appendix A that compares company reported disclosures and data aggregator data on the company)
• Third party data aggregator parsing errors and normalization of company reported disclosures
• Typically 20% to 25% error rate on primary tables
• Note disclosures are limited to non-existent
• XBRL enhances: Speed, Accuracy, Completeness, Cost effectiveness, analytical capabilities
• Company has limited insights on analyst use of company disclosures or analytical drivers; social analytical platforms provide a collaborative model
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Examples of XBRL Enabled Analysts Applications
MicroStrategy Bank Performance iPhone App
XBRL US EDGAR Viewer
BlueMatrix Analyst Suite
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Examples of Social AnalyticsSocial analytics - Standards enable collaborative development and maintenance of formulas and models among authorized individuals
PricewaterhouseCoopers iDP
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Analysts Reflect on Company Specific ExtensionsQuality of XBRL submissions is of interest to analystsCompany specific extensions are often created when USGT elements are available for disclosure element.
Institutional Analysts, in particular, are focused on the inappropriate use of extensions as outlined in this blog:
“XBRL Usability Part 2: Checking the Extension Cord”
http://institutionalrisk.blogspot.com/2011/02/xbrl-usability-part-2-checking.html
Also: IRA's 2011 XBRL Dynamic Renderer
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Implementation Considerations Supplement Website Posting Requirement
XBRL Submission required to be posted on company website
◦ Need not be made available in a format comparable to paper-based information. No viewer necessary.
◦ Link to SEC EDGAR to satisfy the posting requirement is prohibited
◦ Many companies are providing a link to third-party services that host their SEC filings and often provide a viewer
Investor Relations related considerations
◦ Virtual renderings provide efficiency opportunity (example here)
◦ Be aware of EDGAR RSS Feeds
◦ Consider Company IR RSS Feeds
› Direct communication with relevant analysts / stakeholders
› ‘Fact Sheet’, Press Release, Proxy, etc.
◦ Consideration of Corporation Actions Taxonomy
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RSS Feeds – html vs. XBRLDirect vs. Indirect communications
RSS feeds of XBRL are actionable by software and can be analyzed immediately; while the html pages may require some degree of human intervention. The company may want to consider RSS feeds with XBRL files.
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html
XBRL
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Company RSS Feeds - Financial
There is no content in the Company RSS Feeds for Financial content.
This provides an opportunity to publish relevant financial content in the XBRL structured format that is highly reusable by analysts.
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Company Earnings Press Release
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Structured IR ContentEnables automation of information relationships
Structured content enables automation of content development and relationships with broad range of relevant supporting content.
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What is Going on Around the World
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How many countries have migrated their regulatory reporting format to XBRL?XBRL in the G20: AR, AU, BR, CA, CN, FR, DE, IN, ID, IT, JP, MX, RS, SA, ZA, KR, TR, UK, US, EU
XBRL outside of the G20: AE, BE, BM, DK, FR, HK, IE, IL, LU, NL, PL, RO, SG, TH, TW, ES, SE, CH
XBRL Planet and XBRL International provide useful up to date information on country compliance projects
“Convergence” redefined = “Standard Business Reporting”
• Regulatory burden reduction via convergence of agencies compliance processes
• Harmonisation/reduction of reported data using IFRS Taxonomy
• Regulators & business sharing a common language
• SBR Mandated by Dutch MoF effective 1/1/2013
Official SBR participants – AU, CA, CN, IN, JP, NL, PL, SG, TW, TH, UK
53Key: Red = In production; Blue = In development
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IFRS Taxonomy
Collaborative development expanding to capture broadest range of common reporting disclosure concepts.
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UK HMRC iXBRL Mandate
Each of the 1.6 million UK companies required to file a tax return is affected by HMRC's new requirement for XBRL electronic tags to both the tax computations and the statutory financial statements. The requirement takes effect for returns submitted after April 1, 2011. Companies with legal entities in the UK should consider these new requirements.
Learn more here: http://www.pwc.co.uk/eng/issues/xbrl.html
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What can you do
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Agreed Upon Procedures
Creation of Extensions and
Use of USGT Tags
Tagging is Accurately and
Consistently Applied
Completeness of XBRL-tagged
Data
Tagging of Note Disclosures
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Additional Opportunities to Consider
Benchmarking of tagging over USGT standard
tags and extended tags to peer companies.
Training/knowledge sharing on SEC requirements, considerations and process implications, training on more detailed year 2 taxonomy
mapping requirements.
Assessment of readiness and/or implementation
options, tools, processes, controls.
Map existing SEC instance document to revised SEC USGAAP taxonomy.
For example: US GAAP Taxonomy Transition from 2009 to 2011
In a Built - In model: Process and control assessments
related to standardization of internal reporting and
compliance processes.
Assess compliance with certain EDGAR Filer
Manual and other validation rules.
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Appendix A – Data Aggregators vs. Company Reports
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Sample Data Aggregator Distortions
Following are a few example of the distortion and omission that exists within the data that supply chain data aggregators provide to the analyst community. These are examples from the publicly available query sites.
Items highlighted in the red boxes reflect disclosures that are “different” between what the company reported and what is available via data aggregator feeds available to the analyst community.
Typically, the level of detail is normalized into summary concepts that tend to limit company specific disclosures.
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Company vs. Google Finance (Income)
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Company vs. Yahoo Finance (Income)
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Company vs. Google Finance (Assets)
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Company vs. Yahoo Finance (Assets)
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Company vs. Google Finance (Liabilities)
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Company vs. Yahoo Finance (Liabilities)
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Company vs. Google Finance (Cash Flow)
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Company vs. Yahoo Finance (Cash Flow)
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Appendix B - Resources
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Other ‘Built-In’ Resource Articles
• ‘Standardize to Streamline’
• ‘Making Sense of XBRL in the US and the UK’
• FEI Issue Alert: “Year 2 of the SEC’s XBRL Mandate: Caution and Opportunities on Compliance Requirements”
• FEI Magazine Article: “The Time is Right for Standard Business Reporting”
• FEI Magazine Article: “Benefits of Comprehensive Integrated Reporting”
• Breathing New Life into Old Systems with XBRL GL – Wacoal Case Study
PwC
PwC Webinar: How to make the best out of the XBRL situation?
The May 11, 2011 webinar covers:
Rules: Mandatory SEC XBRL requirements, specifically, implications of the transition from year 1 to year 2 as well as the end of the modified liability provisions for XBRL submissions. Results: Reporting considerations and insights including common errors and issues, ramifications for poor quality reports, and reporting best practices. Rewards: Compliance process and control enhancements realized by companies migrating from outsourcing/bolt-on to built-in implementations. Also, a clear answer to the "Who is using XBRL?" question directly from a leader in the Research community. Rest of the World: Transition of regulatory compliance processes from paper to the Internet by governments around the world and the related company considerations.
Recording Access: http://event.on24.com/r.htm?e=302048&s=1&k=16042203D8FF3360662148188178923C
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PwC
Automating the last mileThe role of XBRL in streamlining financial reporting
PwC webinar on “Automating the last mile: The role of XBRL in streamlining financial reporting”
Recording Access: https://www302.livemeeting.com/cc/pwclivemeetingroom/view?id=4FQZP6
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PwC
AICPA ASEC XBRL ASSURANCE TASK FORCE
PROPOSED PRINCIPLES AND CRITERIA FOR XBRL-FORMATTED INFORMATION
COMMENTS REQUESTED BY JULY 15, 2011
Primary Criteria:
Completeness
Mapping
Accuracy
Structure
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This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, [insert legal name of the PwC firm], its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.
© 2011. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers LLP which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.
