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If your company is among those reporting in XBRL, or eXtensible Business Reporting Language, you'll want to know about the suggestions and recommendations received by the American Institute of CPAs in response to its exposure draft, called "Proposed Principles and Criteria for XBRL-Formatted Information.“ The draft, issued in June, was intended to present the approach to be used by accountants evaluating information presented in XBRL. "The XBRL principles and criteria represent a means for assessing the quality of XBRL Files," the draft states. The comment period ended Nov. 30, after having been extended from its original time frame of 45 days.
The principles and criteria in the exposure draft focus on four areas:
Completeness: That is, the required information is formatted at the required levels.
Mapping: The elements selected are consistent with the meaning of the associated concepts.
Accuracy: The amounts, dates and other information are consistent with source information.
Structure: The XBRL files are structured in accordance with the requirements of the organization's reporting environment.
As of mid-December, the AICPA had posted comments from 10 organizations, primarily accounting firms. While some letters focused on specific wording in the exposure draft, several offered suggestions and recommendations of a broader scope. Among them:
From Deloitte: Add a principle stating that the source information that underlies the XBRL files is complete and accurate, and that it is important for management to determine this.
From KPMG: Change the title of the "accuracy" principle to "consistency." In its letter, KPMG says, "The term "consistency" implies that the XBRL-formatted information has been prepared consistently with the underlying data, without connoting that the underlying data are accurate or that the process of formatting data in XBRL improves the quality of the underlying data."
From BDO: Include a principle and related criteria covering the controls an entity should have over its XBRL process. "We suggest adding controls as the first principle and including guidance as to what controls should be in place and how the existence of such controls impacts an evaluation of the other principles.
From URS Corp., a provider of engineering and construction services, as well as an accelerated XBRL filer: Clarify the use of the term "unaudited" in XBRL files. "It is important for users of such files to understand that the files are based on, for example, unaudited quarterly financial statements."
From Colm OhAonghusa, a chartered accountant: Reconsider the expression 'XBRL-formatted information." OhAonghusa points out that "for ordinary business users, formatting has connotations of font, size, style and the like, none of which add meaning the item being formatted." Instead, the term "tagging" best describes the XBRL process of taking data and associating it with additional pieces of information to add meaning to the figure.
The integrity of many organizations' XBRL-reported information increased in importance this year, as the largest public companies -- those who were first to file in XBRL -- now are liable for the accuracy of their submissions; the SEC had limited their liability for a period of two years, as this legal brief from Skadden points out. The second wave of companies lose their liability exemption next year. |