When I talk with finance executives about implementing XBRL,nearly everyone asks,“What will auditors be looking for?Do they care about XBRL?”The answer is no,they don’t.But they do care about your ntrols,and that relates directly to how you design and document your due diligence in XBRL creation process.Ultimately,as XBRL gets built into your close process,the more it may start to fall into the SOX environment.

While XBRL exhibits are not subject to SOX 404internal ntrols over financial reporting,they are nevertheless subject to disclosure ntrols and procres (DC&P).This means that management is responsible for the implementation of ntrols over the XBRL creation process as well as documentation that the DC&P are performed and reviewed.How can mpanies provide evidence to their auditors that management,including the CEO and CFO,have evaluated the effectiveness of the design and operation of DC&P?

To design proper DC&P ntrols,you first need to ask,“How do you know your XBRL files are mplete,aurate,nsistently mapped and mply with the mandated XBRL structure?”A best practice is to develop an XBRL technical and mpliance checklist to document every aspect of your XBRL creation process,from taxonomy mapping and appropriate extensions to mmon error reviews,technical and SEC validations,structure mpliance issues.You may also want to involve your disclosure or audit mmittee in the review and nsideration of your DC&P process and get them on board with your XBRL strategy.

As XBRL technology bemes more embedded into your overall financial reporting process and integrated into the creation and preparation of your financial statements,XBRL ntrols may start to fall within the spe of SOX 404.As this happens,you should reevaluate your XBRL ntrols under SOX 404framework.