Regarding Public and Internal

U.S. Securities and

Exchange Commission

SEMI-ANNUAL REPORT

TO CONGRESS

Regarding Public and Internal

Use of Machine-Readable Data for

Corporate Disclosures

June 2025

Introduction

The Financial Data Transparency Act of 2022 (“FDTA”), which was signed into law on

December 23, 2022, as Title LVIII of the James M. Inhofe National Defense Authorization Act

for Fiscal Year 2023, 1 requires the Securities and Exchange Commission (“Commission”) to

report semi-annually on the public and internal use of machine-readable data for corporate

disclosures. 2 The FDTA requires the Commission to submit this report to the Committee on

Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of

the House of Representatives every 180 days until December 23, 2029, when the provision

requiring the report sunsets. 3

FDTA Section 5825(b) requires that this report include: (1) an identification of which corporate

disclosures required under specified provisions of the securities laws are expressed as

machine-readable data and which are not; (2) an analysis of the costs and benefits of the use of

machine-readable data in corporate disclosure to investors, markets, the Commission, and

issuers; (3) a summary of enforcement actions that result from the use or analysis of machinereadable data collected under the specified statutory provisions; and (4) an analysis of how the

Commission uses the machine-readable data it collects. 4

This report contains the following new information since the last report: additional Commission

rulemaking releases adopting structured data tagging requirements, proposed joint data

standards, updated statistics in the analysis of the costs and benefits of the use of machinereadable data, and additional Enforcement actions resulting from the use or analysis of

machine-readable data that the Commission collects.

Identification of Corporate Disclosures Expressed as

Machine-Readable Data

FDTA Section 5825(b)(2)(A) requires an identification of which corporate disclosures required

under Section 7 of the Securities Act of 1933 (the “Securities Act”), 5 Section 13 of the Securities

Exchange Act of 1934 (the “Exchange Act”), 6 and Section 14 of the Exchange Act 7 are

expressed as machine-readable data and which are not. Please refer to the Appendix.

Existing Machine-Readable Data Requirements

Over the years, the Commission has refined many of its rules by requiring open and freely

available, machine-readable, standardized formats promulgated by standards organizations or

voluntary consensus standards bodies.

In 2005, the Commission adopted rules requiring certain disclosures in eXtensible Markup

Language (“XML”), 8 which is a machine-readable, structured data language often used for

standard-format disclosure. For such filings, filers are typically provided the option either to

submit the filing directly according to the XML specifications for a given filing, or to manually

input the information into a fillable web-based form developed by the Commission that converts

for the filer the completed form into XML format. 9 The Commission continues to support XML for

various reporting requirements. 10

In 2009, the Commission adopted rules requiring operating companies to provide the

information from the financial statements in their registration statements and periodic and

current reports using eXtensible Business Reporting Language (“XBRL”), 11 which is a machinereadable, structured data language used for standardized reporting of business information,

including information relating to the financial performance of companies. 12 That same year, the

Commission similarly required open-end management investment companies (“mutual funds”)

to provide risk/return summary information in their prospectuses in XBRL format. 13

In 2018, the Commission adopted amendments requiring the use, on a phased-in basis, of

Inline XBRL for operating company financial statement information and fund risk/return

summary information. 14 Whereas previously filers generated an HTML document of their

financial statement information or risk/return summary information and then tagged a copy of

the data to create a separate XBRL exhibit, Inline XBRL allows filers to prepare a single

document that is both human-readable and machine-readable. 15 The Commission continues to

support Inline XBRL for various disclosure requirements. 16

Machine-Readable Data Requirements Adopted Since Last Report

Since the last report, the Commission has not adopted any rules that require electronic filing or

submission in whole or in part in Inline XBRL or XML of any forms, schedules, or statements

containing disclosures required under Securities Act Section 7, Exchange Act Section 13, or

Exchange Act Section 14. There are currently 55 forms, schedules, and statements containing

disclosures required under Securities Act Section 7, Exchange Act Section 13, or Exchange Act

Section 14. About three-quarters (43 of 55) of those forms, schedules, and statements require

some machine-readable data, while about one-quarter (12) 17 do not require any machinereadable data.

Proposed Joint Agency Data Standards

In August 2024, the Commission, along with the Office of the Comptroller of the Currency,

Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation,

National Credit Union Administration, Consumer Financial Protection Bureau, Federal Housing

Finance Agency, Commodity Futures Trading Commission, and the Department of the

Treasury, proposed a rule to establish data standards to promote interoperability of financial

regulatory data across these agencies. 18 The agencies proposed this rule as required by the

FDTA. The proposed joint data standards include common identifiers related to entities,

financial instruments, geographic locations, dates, and certain products and currencies.

Pursuant to the FDTA, once joint standards have been established, each agency is responsible

for adopting agency-specific standards for certain collections of information in separate

rulemakings by the agencies or through other actions taken by the agencies. As of the date of

this report, the agencies have received over 140 comment letters on the proposed joint

standards. The agencies continue to consider these comments and work together toward

adopting a final rule that establishes final joint standards.

Analysis of the Costs and Benefits of the Use of MachineReadable Data

FDTA Section 5825(b)(2)(B) requires an analysis of the costs and benefits of using machinereadable data in corporate disclosure to investors, markets, the Commission, and issuers. 19

Benefits

Studies show that machine-readable disclosures benefit investors, markets, and issuers. With

respect to investors and, more broadly, to markets, making corporate disclosures machinereadable has decreased information asymmetry between firms and investors by reducing

information processing costs, making stock prices more informative (i.e., more reflective of firmspecific information), and reducing market inefficiencies and risks. 20 Machine-readability has

enhanced market competition by, for example, reducing insider advantages relative to noninsiders and local investor advantages relative to non-locals. 21 The reduction in information

processing costs has heightened monitoring of issuers by investors and other external parties

(e.g., financial analysts, press, data aggregators, academic researchers, and financial media)

which often helps to inform investors and markets. 22 Greater monitoring has driven firms to

provide more quantitative disclosure and report earnings in a more consistent manner. 23 Such

benefits may increase over time as tools for investor use of machine-readable data become

more widely available.

Issuers have, in some instances, benefitted from decreased audit fees and increased timeliness

of audit and financial reports as a result of machine-readable disclosures. 24 Issuers have

experienced additional benefits associated with machine-readable disclosures, including: higher

liquidity; lower cost of capital; higher return on investment; and improved performance

benchmarking and acquisition analysis. 25 Finally, machine-readable disclosures have facilitated

the Commission’s investor protection efforts, enabling staff to analyze large quantities of

information in support of risk assessment, rulemaking, and enforcement activities, including as

part of its internally developed structured data applications. 26 Freely usable technical validation

rules also allow issuers to check for certain errors before the machine-readable data is

submitted, which can further streamline the compliance process by reducing Commission staff

time that would otherwise be spent pinpointing and communicating the existence of technical

errors to issuers, and by reducing issuer time that would otherwise be spent resolving such

errors and resubmitting the machine-readable data file. 27

Costs

The cost of machine-readable disclosure largely affects filers and the Commission. Filers must

comply with machine-readable disclosure requirements; and the Commission mandates and

implements machine-readable disclosure requirements. Investors and other data users (e.g.,

financial analysts, asset managers, and academic researchers) are not bound to use machinereadable versions of corporate disclosures, because the disclosures are human-readable as

well. 28 Furthermore, while commercial XBRL research software is available for a cost, investors

and other data users can access and download machine-readable corporate disclosures at no

cost. 29

Filers incur compliance costs to apply machine-readable tags to their disclosures or pay a thirdparty tagging service provider to do so. Compliance costs for new tagging requirements tend to

be higher, but generally decline as filers and service providers gain experience and develop

new tools to adapt to the requirements. 30 These compliance costs are likely reduced for those

filers with experience applying tags to their disclosures, whether through other machinereadability requirements or through the use of machine-readable data in their internal enterprise

resource planning systems. 31 Compliance costs also vary based on the type of filer, because

some types of filers are subject to more extensive tagging requirements than other types of

filers. For example, business development companies (BDCs) and registered closed-end funds

both are subject to Form N-2 prospectus and cover page tagging, but BDCs, because they are

registered under the Exchange Act, are also subject to financial statement tagging and thus

incur additional tagging compliance costs as compared to registered closed-end funds.

Registered closed-end funds are subject to Form N-2 prospectus and cover page tagging, but

are not subject to financial statement tagging, and thus incur lower tagging compliance costs

than BDCs do.

With respect to the magnitude of these compliance costs, an American Institute of Certified

Public Accountants survey of 1,032 smaller reporting companies in 2018 found a median cost of

$2,500 per year for fully outsourced XBRL creation and filing. 32 A separate survey of 139

Nasdaq-listed filers and other responding companies in 2018 found higher XBRL compliance

costs, including a median XBRL compliance cost of $7,500 per Form 10-Q. 33 The discrepancy

may be because Nasdaq-listed companies include many companies that are not smaller

reporting companies (SRCs). Many of these non-SRCs have longer, more detailed, and more

complex financial statements than SRCs do, and thus have more tags that they need to apply to

their documents, resulting in more time and effort needed to tag discrete disclosures (such as

numbers, blocks of narrative text, checkboxes, etc.) and ultimately increased compliance costs

compared to SRCs. 34

Both surveys were conducted before the compliance dates for the Commission’s transition from

XBRL to Inline XBRL and before the implementation of cover page and other tagging

requirements for periodic reports. For the purposes of the Paperwork Reduction Act of 1995, as

amended, 35 Commission staff estimated in the Inline XBRL Filing of Tagged Data Adopting

Release, that the effect of using Inline XBRL rather than XBRL to tag financial statements would

be to reduce the existing aggregate average internal burden of 56 hours per response for

reporting companies by 2 hours during each of the first three years of the Inline XBRL

requirements, and increase the aggregate average out-of-pocket cost to $6,175 per response. 36

In 2022, Commission staff updated this burden estimate to 53 hours per response, while noting

that the actual burdens will likely vary among individual companies based on the size of their

organization. 37

In 2023, the Commission stated in a proposed rule release that, based on the staff’s

understanding of third-party structured data compliance pricing, smaller filers typically pay

between $1,500 and $5,000 per year for third-party structured data compliance services and/or

software, while larger filers typically pay between $5,000 and $30,000 per year for such services

and/or software. 38 The Commission also cited a number of factors that affect the cost of

compliance, including the particular filing or submission on which structured data is required, the

number of data points to be structured, the size of the entity providing the data, the industry to

which the entity belongs, the number of individual users of the structured data compliance

software, the extent to which the structuring is fully outsourced, and others. 39

The Commission incurs costs to develop taxonomies and schemas for new structured

disclosures and to set up the infrastructure for structured data intake, validation, publication, and

use. This includes the cost of updating the Commission’s Electronic Data Gathering, Analysis,

and Retrieval (“EDGAR”) filing system, the integration of new structured data into databases

and internal applications, and the publication of structured datasets. Such costs can vary based

on the volume, complexity, and novelty of new structured disclosure requirements. For example,

rules which add a limited number of newly tagged disclosures to already tagged disclosure

forms will generally entail less implementation time and cost than rules which add a significant

number of newly tagged disclosures to disclosure forms that were previously untagged. The

Commission also incurs costs to update taxonomies and schemas and the related EDGAR

intake and validation functions on a periodic basis.

Summary of Enforcement Actions Resulting from the Use or

Analysis of the Machine-Readable Data That the

Commission Collects

The availability of machine-readable data that has been submitted to the Commission has

enabled staff in the Division of Enforcement (“Enforcement”) to perform more efficient analyses

of individual issuers’ disclosures and accounting practices and more sophisticated analyses of

disclosures and accounting practices across wide-ranging cross-sections of issuers. Both types

of analyses, together with traditional investigative tools, have resulted in the filing of actions

against issuers and related individuals alleging various types of misconduct that violated the

federal securities laws. Without the use or analysis of machine-readable data, the alleged

violations would have been significantly more difficult to detect and pursue in a cost-effective or

timely manner.

Enforcement utilized risk-based data analytics to uncover potential accounting-related

disclosure irregularities caused by, among other things, earnings management practices.

Machine-readable data enabled Enforcement staff to review the financial data of thousands of

public issuers to detect indicia of earnings management or other types of financial misconduct.

The initiative resulted in charges against six public companies and several related individuals

over a several year period for violations of the federal securities laws related to their engaging in

certain practices that gave the appearance of meeting or exceeding consensus earnings-pershare (EPS) estimates. 40

Enforcement used and analyzed machine-readable data during the underlying investigation of

an action brought in 2023. While performing background due diligence, Enforcement reviewed

financial statements and notes and was able to view period-over-period changes more

efficiently due to the machine-readability of the data. 41

Among actions that result from the use or analysis of machine-readable data collected under the

specified statutory provisions, Enforcement analyzed machine-readable data in connection with

an investigation concerning cybersecurity disclosures by public issuers. The investigation

resulted in charges against four public companies in October 2024. 42

Analysis of How the Commission’s Staff Uses the MachineReadable Data That the Commission Collects

Current Applications Used to Analyze Machine-Readable Data

The Commission’s staff uses several applications to analyze machine-readable data. The

following applications are internally developed and available to Commission staff:

 Filer Profile provides instant access to certain key data points, such as financial data, auditrelated information, and other data for operating companies. It highlights potentially high-risk

data points or topic areas and facilitates further analysis via links to data sources.

Additionally, Filer Profile allows users to identify quickly specific areas and topics of interest.

 Financial Statement Query Viewer (“FSQV”) offers users a convenient means of comparing

machine-readable financial statement data (including notes and schedules), cover-page

data, and certain executive compensation data for operating companies and BDCs, as well

as cover-page data and certain prospectus data for registered closed-end funds and BDCs.

FSQV facilitates comparative data analyses across multiple filings and periods. In FSQV,

users can query tagged narrative or numeric disclosures. FSQV has various features, such

as the ability to track a filer’s changes in footnotes across reporting periods and share

queries with other users.

 iView leverages the open-source, freely and publicly available Inline XBRL Viewer. iView

includes various filters and query capabilities, such as the identification of disclosures with

custom tags (i.e., filers creating tags instead of using standard tags) and the sorting of

machine-readable data by scale (e.g., amounts in thousands, millions, or billions). iView also

offers time-series charting and benchmark analyses for numeric values and tracking

changes in narrative disclosures.

Current Division Uses of Machine-Readable Data

Division of Corporation Finance (“Corporation Finance”) staff uses machine-readable data in a

variety of ways:

 Corporation Finance staff uses machine-readable data to help identify issuers that are

subject to the disclosure and submission requirements of, and potentially subject to a

trading prohibition under, the Holding Foreign Companies Accountable Act (“CommissionIdentified Issuers”). 43 Specifically, the staff uses data in Forms 10-K, 20-F, and 40-F

identifying the auditor (or auditors) who provided opinions related to the financial statements

presented in the issuer’s annual report, the location where the auditor’s report was issued,

and the Public Company Accounting Oversight Board (“PCAOB”) ID Number(s) of the audit

firm(s) or branch(es) providing the opinion(s).

 Corporation Finance staff uses several items of machine-readable data that appear on the

cover pages of registrants’ annual reports (Forms 10-K, 20-F, and 40-F) to identify, count,

sort, compare, and analyze registrants and their disclosures (e.g., to identify more readily

and accurately issuers that are listed on a specific exchange or that have identified

themselves as well-known seasoned issuers).

 Corporation Finance staff and Division of Economic and Risk Analysis (“DERA”) staff review

machine-readable financial statement information contained in filings under Commission

rules. In connection with these reviews, the staff has issued comment letters to some

individual issuers regarding the Inline XBRL tagging requirements. The staff has also used

its findings to publish observations on data quality and analyses of custom tags. On

September 7, 2023, Corporation Finance published a sample letter to companies regarding

their XBRL disclosures. 44 The letter included sample comments that, depending on the

particular facts and circumstances, and type of filing under review, Corporation Finance staff

may issue to certain companies.

 Corporation Finance staff uses machine-readable data to make preliminary assessments of

compliance with the Commission’s pay-versus-performance disclosure requirements.

Division of Investment Management (“Investment Management”) staff also uses machinereadable data in a variety of ways:

 Investment Management staff uses machine-readable data for fund disclosures to readily

detect errors and inconsistencies within filings and to identify funds with particular

characteristics or disclosures, as well as funds with certain holdings, exposures or risk

parameters. 45 The ability to scan across the industry for funds with certain disclosures and

characteristics enhances Investment Management’s disclosure review program, 46 informs

staff recommendations for Commission rulemakings and other policy initiatives, and

supports the staff’s coordination with other federal agencies.

 Structured data analysis may also better enable Investment Management staff to identify

fund and adviser data errors. For example, when Investment Management staff identified

common errors as a result of Investment Management’s own use of structured data, the staff

published information highlighting common tagging issues to facilitate more accurate fund

disclosure. 47 Investment Management staff also analyzes structured data provided by

investment advisers on Form ADV to scan across the industry for advisers with certain

disclosures and characteristics, inform staff recommendations for Commission rulemakings

and other policy initiatives, and support the staff’s coordination with other federal agencies.

 Investment Management staff has also used machine-readable information regarding fund

holdings, among other data, to evaluate fund compliance with the federal securities laws

and to identify trends and risks faced by the fund industry. This information can be shared

with the Divisions of Examinations and/or Enforcement when it suggests non-compliance

with law or other heightened risks.

Other Divisions and Offices use machine-readable data in similar ways:

 Office of the Chief Accountant (“OCA”) staff uses the Commission’s analytical applications,

including FSQV, iView, and others, to perform searches based on key words and XBRL

tagging. OCA staff uses the output of these searches to conduct research for accounting

consultations, information gathering relevant to accounting standard-setting projects and

requests from other regulators, and the preparation of responses to specific data requests

regarding registrants’ application of accounting principles. OCA staff additionally uses the

outputs in researching the identification of independent auditors concentrated in specific

industries, identifying issuers subject to the Holding Foreign Companies Accountable Act,

and supporting Enforcement on auditor-related matters.

 Adopted in 2021, 48 the tagging requirements of filing fee-related information, will enable

EDGAR to determine automatically in many cases whether a registrant’s filing fee

calculations have been performed correctly. Filings that use the SEC’s optional fee-tagging

tool and test filings that do not pass specific validation tests will be flagged before the

related live filing is filed. This will allow filers to correct any filing fee calculation errors

without needing to wait for Commission staff to verify the calculations manually, and without

having to subsequently revise an already-filed document and adjust any fees owed due to

an erroneous calculation.

Public Use of the Machine-Readable Data That the

Commission Collects

FDTA Section 5825(b)(2)(1) requires a report regarding the “public . . . use of machine-readable

data for corporate disclosures.” 49 Users of machine-readable corporate disclosures include

institutional investors, 50 asset managers, 51 issuers, 52 financial analysts and research firms, 53

individual investors, 54 data aggregators, 55 the financial press, 56 other regulators, 57 and

academics. 58 For example, academic studies indicate that the implementation of XBRL data

requirements appears to be correlated with increased forecast accuracy by financial analysts. 59

Also, financial academics have used XBRL data to study topics such as financial reporting

complexity and dual-class voting structures. 60 Further, staff members of the Financial

Accounting Standards Board (“FASB”) have used XBRL data to complete more than 200

research projects over the past several years. 61 Public users retrieve XBRL data by

downloading them from individual Commission filings and from aggregated datasets that

Commission staff compiles from individual Commission filings and makes available on the

Commission’s website. 62

Financial analysts and press also use data from Commission filings that are in XML, such as

data from Form 13F (quarterly equity holdings reports filed by large institutional investment

managers). 63 For example, since August 2022 (when the Form 13F datasets first became

available), there have been over 2,088,000 Form 13F dataset downloads. 64

Conclusion

The FDTA’s directives coincide with internal Commission and staff efforts 65 to improve the

management and use of data across the agency, consistent with other statutory directives 66 as

well as overall strategic goals to work more efficiently.

Appendix

FDTA Section 5825(b)(2)(A) requires an identification of which corporate disclosures required under

Securities Act Section 7 and Exchange Act Sections 13 and 14 are expressed as machine-readable data

and which are not. The Commission collects these disclosures via the submission of forms and

schedules through the EDGAR System. This Appendix identifies the disclosures expressed in a

machine-readable format on an individual form, schedule, and statement basis. 67 All other required

disclosures in these filings are submitted in a non-machine-readable format. The Appendix also identifies

the forms, schedules, or statements that do not collect any machine-readable information. The Appendix

does not include other collections of information with machine-readable data that are not required under

these statutory provisions.

The Commission’s requirement to file information tagged in XBRL (Inline XBRL, except where noted) is

implemented primarily through Rule 405 of Regulation S-T. Rule 405 addresses the obligation to tag

financial statements 68 and disclosure regarding pay-versus-performance, action to recover erroneously

awarded compensation, insider trading arrangements and policies, policies and practices related to the

grant of certain equity awards close in time to the release of material non-public information,

cybersecurity risk management, strategy, and governance, and special purpose acquisition company

(“SPAC”) initial public offerings and business combination transactions with private companies. Rule 405

also addresses the obligation to tag certain fund prospectus, semi-annual report, and annual report

disclosures in Forms N-1A, N-2, N-3, N-4, N-6, N-8B-2, S-6, and N-CSR. Rule 406 of Regulation S-T

addresses the obligation to tag the cover page of Forms 10-K, 10-Q, 8-K, 20-F, and 40-F. Rule 408 of

Regulation S-T addresses the obligation to tag the filing fee exhibit for registration statements and

related fee-bearing prospectus supplements (excluding SF-1, SF-3, S-20, Schedule B, F-6, F-7, F-8 and

F-80), fee-bearing Schedules 14A, 14C, 13E-3, 13E-4F, TO, and 14D-1F, and statements under Rule

13e-1 (phase-in began in July 2024 and is ongoing). The information in this Appendix is as of May 1,

2025.

Corporate Disclosures in Forms and Schedules under Securities Act Section 7

Securities Act Registration Statements 69

Form S-1 70

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

• Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Form S-3 71

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form S-4 72

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

•

Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Form S-8 73

• Filing fee exhibits must be tagged in Inline XBRL.

Form S-11 74

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-1 75

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

• Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Form F-376

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form F-4 77

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

• Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Form F-1078

• Financial statements must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form SF-1/SF-3 79 (registration forms used by certain types of asset-backed issuers)

• If an asset-backed issuer registrant’s asset pool includes residential mortgages, commercial

mortgages, automobile loans, automobile leases, debt securities or re-securitizations of asset-backed

securities, certain asset-level information 80 is required to be filed under cover of Form ABS-EE in

XML format. 81 The initial asset-level disclosure filing is incorporated by reference into the relevant

registration statement filing or related prospectus filing.

•

Filing fee exhibits are not required to be tagged, but may be tagged, in Inline XBRL.

No machine-readable data is required in Forms F-6, F-7, F-8 and F-80 (registration statements available

only to a registrant that is incorporated or organized under the laws of Canada or any Canadian province

or territory and meets certain other conditions).

No machine-readable data is required in Form S-20 (used to register standardized options under the

Securities Act if specified conditions are met) or in Schedule B (a registration statement available only to

a registrant that is a foreign government).

Corporate Disclosures in Forms, Schedules, and Statements under Exchange Act

Section 13

Form 10-K 82

•

•

•

•

•

•

•

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.

The identity of the auditor (or auditors) who have provided opinions related to the financial

statements presented in the registrant’s annual report, the location where the auditor’s report has

been issued, and the PCAOB ID Number(s) of the audit firm(s) or branch(es) providing the opinion(s)

must be tagged in Inline XBRL.

Disclosure required by Item 106 of Regulation S-K (registrant’s cybersecurity risk management,

strategy, and governance) must be tagged in Inline XBRL.

Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover erroneously

awarded compensation) must be tagged in Inline XBRL.

Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and practices related to

the grant of certain equity awards close in time to the release of material non-public information) must

be tagged in Inline XBRL.

Disclosure required by Item 408(a) and (b)(1) of Regulation S-K (registrant’s insider trading

arrangements and policies) must be tagged in Inline XBRL.

Form 10-Q 83

•

•

•

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.

Form 11-K 84

•

Financial statements must be tagged in Inline XBRL (beginning in 2025).

Form 20-F 85

•

•

•

•

•

Cover page information must be tagged in Inline XBRL (when Form 20-F is filed as an annual report).

Disclosure required by Item 6.F (registrant’s action to recover erroneously awarded compensation)

must be tagged in Inline XBRL.

Disclosure required by Item 16J (insider trading policies) must be tagged in Inline XBRL.

Disclosure required by Item 16K (registrant’s cybersecurity risk management, strategy, and

governance) must be tagged in Inline XBRL.

Financial statements must be tagged in Inline XBRL.

•

The identity of the auditor (or auditors) who have provided opinions related to the financial

statements presented in the registrant’s annual report, the location where the auditor’s report has

been issued, and the PCAOB ID Number(s) of the audit firm(s) or branch(es) providing the opinion(s)

must be tagged in Inline XBRL.

Form 40-F 86

• Cover page information must be tagged in Inline XBRL (when Form 40-F is filed as an annual report).

• Disclosure required by General Instruction B, paragraph (19) (registrant’s action to recover

erroneously awarded compensation) must be tagged in Inline XBRL.

• Financial statements must be tagged in Inline XBRL.

• The identity of the auditor (or auditors) who have provided opinions related to the financial

statements presented in the registrant’s annual report, the location where the auditor’s report has

been issued, and the PCAOB ID Number(s) of the audit firm(s) or branch(es) providing the

opinion(s), must be tagged in Inline XBRL.

Form ABS-EE87

• The information in Form ABS-EE must be filed in XML format.

Form 8-K 88

• Cover page information (e.g., registrant name, form type, date of report) must be tagged in Inline

XBRL.

• Disclosure required by Item 1.05 (disclosure of material cybersecurity incidents) must be tagged in

Inline XBRL.

• Disclosure required by Item 1609(a) and (b) of Regulation S-K (disclosure related to projections in

connection with business combination transactions with private companies) must be tagged in Inline

XBRL.

• Financial statements must be tagged in Inline XBRL (when the form includes audited annual financial

statements that are a revised version of financial statements that previously were filed with the

Commission).

Form 6-K 89

• Financial statements must be tagged in Inline XBRL (when the form includes audited annual financial

statements that are a revised version of financial statements that previously were filed with the

Commission, or current interim financial statements are included pursuant to the nine-month updating

requirement of Item 8.A.5 of Form 20-F).

Form SD90

• Information included in the Resource Extraction Issuer Disclosure Report (Exhibit 2.01) must be filed

in XBRL.

Form 10-D 91

• ABS issuers generally are required to file standard Exchange Act filings, including Forms 10-K and 8K. Additionally, ABS issuers are required to file ongoing reports (typically monthly) on Form 10-D,

which include the distribution report sent to the holders of the ABS. If the issuer’s asset pool includes

residential mortgages, commercial mortgages, automobile loans, automobile leases, debt securities

or re-securitizations of asset-backed securities, Form 10-D must also incorporate by reference the

current asset-level disclosure filing on Form ABS-EE, which must be filed in XML format.

Schedules 13D and 13G 92

• The information in Schedules 13D and 13G (other than the exhibits to those schedules) must be filed

in XML format.

Schedules 13E-3 and 13E-4F and Statements under Rule 13e-193

• Filing fee exhibits must be tagged in Inline XBRL.

No machine-readable data is required in Form 18-K (annual report form used by foreign governments or

political subdivisions of foreign governments with securities listed on a United States exchange).

Exchange Act Section 13(n) requires Security-Based Swap Data Repositories to file registration

statements (“Form SDR”). Commission Rules 13n-1(b) and 13n-11(f)(5) require entities to file Form SDR

and all amendments “electronically in a tagged data format.” The Commission has stated that for a

period of four years following Regulation SBSR’s Compliance Date 1, “an entity submitting an application

to register would not need to comply with the requirement in Rule 13n-1(b) and Rule 13n-11(f)(5) to file

Form SDR and all amendments ‘electronically in a tagged data format’ but instead would be able to

submit such documents to the Commission electronically as portable document format (PDF) files,

consistent with the CFTC SDR application procedures under Part 49.3(a)(1).775.” 94

Corporate Disclosures in Schedules under Exchange Act Section 14

Schedules 14A/14C95

• Disclosure required by Item 402(v) of Regulation S-K (pay versus performance) must be tagged in

Inline XBRL.

• Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover erroneously

awarded compensation) must be tagged in Inline XBRL.

• Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and practices related to

the grant of certain equity awards close in time to the release of material non-public information) must

be tagged in Inline XBRL.

• Disclosure required by Item 408(b)(1) of Regulation S-K (registrant’s insider trading arrangements

and policies) must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

• Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Schedule TO 96

• Filing fee exhibits must be tagged in Inline XBRL.

• Disclosure required by Subpart 1600 of Regulation S-K (disclosures for SPAC initial public offerings

and business combination transactions with private companies) must be tagged in Inline XBRL.

Schedule 14D-1F 97

• Filing fee exhibits must be tagged in Inline XBRL.

No machine-readable data is required in Schedules 14D-9, 14D-9F, or 14N.

Fund Structured Data Requirements

Specific forms govern the disclosures made by mutual funds, exchange-traded funds (“ETFs”), money

market funds, variable and certain non-variable insurance products, closed-end funds and BDCs

(together, “funds”). Funds are subject to a number of disclosure requirements, several of which are

required to be machine-readable. Institutional investment managers are also required to periodically

disclose certain holdings. The list below provides a complete list of such machine-readable disclosure

requirements for these entities.

List of Machine-Readable Fund Disclosures under Securities Act Section 7 and Exchange Act

Sections 13 and 14

Fund Disclosures in Forms under Securities Act Section 7

Securities Act Registration Statements

Form N-1A 98

• Items 2 through 4 of Form N-1A must be tagged in Inline XBRL. (Mutual funds and ETFs are required

to tag their investment objectives including how terms used in fund names are defined, fee tables,

principal strategies, principal risks, and performance information.)

Form N-2 99

• Cover page information of Form N-2 (e.g., registrant name, form type, approximate date of proposed

public offering) must be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 10.3, and 10.5

of Form N-2 must be tagged in Inline XBRL. (Closed-end funds and BDCs are required to tag their

fee table, senior securities table, investment objectives and policies including how terms used in fund

names are defined, risk factors, share price data, and capital stock, long-term debt and other

securities. This information may be tagged in the prospectus or in periodic reports.)

• Filing fee exhibits must be tagged in Inline XBRL. (Closed-end funds that are not interval funds are

required to tag their filing fee exhibits.)

Form N-3 100

• Items 2, 4, 5, 11, 18, and 19 of Form N-3 for contracts available to new investors must be tagged in

Inline XBRL. (Variable insurance contracts are required to tag their key information table, fee table,

principal risks, information about benefits, and investment options.)

Form N-4 101

• Items 2(b)(2), 2(d), 3, 4, 5, 6(a) (instruction), 6(d), 6(e), 7(e), 10, 17, 26(c), and 31A of Form N-4 for

contracts available to new investors must be tagged in Inline XBRL. (All filers are required to tag the

key information table, fee table, principal risks, information about benefits, whether the filer is relying

on an exception from Exchange Act reporting, and investment options. Issuers of relevant nonvariable annuities must also tag specified portions of the prospectus that provide information about

the annuities’ features, census-type information about the annuities, historical limits on returns, and

information about changes in and disagreements with accountants.)

Form N-6 102

• Items 2, 4, 5, 10, 11, and 18 of Form N-6 for contracts available to new investors must be tagged in

Inline XBRL. (Variable insurance contracts are required to tag their key information table, fee table,

principal risks, information about benefits, and investment options.)

Form N-14 103

• Filing fee exhibits must be tagged in Inline XBRL. (Closed-end funds that are not interval funds are

required to tag their filing fee exhibits.)

Forms N-8B-2 and S-6 104

• Information provided in response to Instruction 2 to Item 11 of Form N-8B-2 must be tagged in Inline

XBRL. Form S-6 incorporates the disclosure and tagging requirements of Form N-8B-2. (Unit

investment trusts registering on Forms N-8B-2 and S-6 are required to tag how terms used in fund

names are defined.)

No machine-readable data is required in Form N-5.

Fund Disclosures in Forms under Exchange Act Section 13

Form N-CSR 105

• Item 27A of Form N-1A is required to be tagged in Inline XBRL. (Mutual funds and ETFs are required

to tag their shareholder reports, which includes fee, performance, holdings, material changes and

other specified fund information.)

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 10.3, and 10.5

of Form N-2 must be tagged in Inline XBRL. (Closed-end funds are required to tag their fee table,

senior securities table, investment objectives and policies, risk factors, share price data, and capital

stock, long-term debt and other securities. This information may be tagged in the N-CSR filing to the

extent this information is included.)

• Item 18 of Form N-CSR is required to be tagged in Inline XBRL. (Internally managed closed-end

funds are required to tag disclosure related to the recovery of erroneously awarded compensation.)

Form N-CEN 106

• Form N-CEN must be filed in XML format. (Form N-CEN provides annual census information for

nearly all registered investment companies. The filing of Form N-CEN satisfies Exchange Act

reporting obligations for unit investment trusts.)

Form 10-K (Only for BDCs) 107

• Cover page information (e.g., registrant name, form type, filer size, public float, ticker symbol) must

be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 10.3, and 10.5

of Form N-2 must be tagged in Inline XBRL. (BDCs are required to tag their fee table, senior

securities table, investment objectives and policies, risk factors, share price data, and capital stock,

•

•

•

•

•

•

long-term debt and other securities. This information may be tagged in the 10-K to the extent this

information is included in the Exchange Act report.)

Financial statements and schedules listing various BDC investments must be tagged in Inline XBRL.

The identity of the auditor (or auditors) who have provided opinions related to the financial

statements presented in the registrant’s annual report, the location where the auditor’s report has

been issued, and the PCAOB ID Number(s) of the audit firm(s) or branch(es) providing the opinion(s)

must be tagged in Inline XBRL.

Disclosure required by Item 106 of Regulation S-K (registrant’s cybersecurity risk management,

strategy, and governance) must be tagged in Inline XBRL.

Disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover erroneously

awarded compensation) must be tagged in Inline XBRL.

Disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and practices related to

the grant of certain equity awards close in time to the release of material non-public information) must

be tagged in Inline XBRL.

Disclosure required by Item 408(a) and 408(b)(1) of Regulation S-K (registrant’s insider trading

arrangements and policies) must be tagged in Inline XBRL.

Form 10-Q (Only for BDCs) 108

• Cover page information (e.g., registrant name, form type, filer size, public float, ticker symbol) must

be tagged in Inline XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 10.3, and 10.5

of Form N-2 must be tagged in Inline XBRL. (BDCs are required to tag their fee table, senior

securities table, investment objectives and policies, risk factors, share price data, and capital stock,

long-term debt and other securities. This information may be tagged in the 10-Q to the extent this

information is updated in the Exchange Act report.)

• 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.

Form 8-K (Only for BDCs; optional for registered closed-end funds) 109

• Cover page information (e.g., registrant name, form type, date of report) must be tagged in Inline

XBRL.

• Items 3.1, 4.3, 8.2.b, 8.2.d, 8.3.a, 8.3.b, 8.5.b, 8.5.c, 8.5.e, 10.1.a-d, 10.2.a-c, 10.2.e, 10.3, and 10.5

of Form N-2 must be tagged in Inline XBRL. (BDCs are required to tag their fee table, senior

securities table, investment objectives and policies, risk factors, share price data, and capital stock,

long-term debt and other securities. This information may be tagged in the 8-K to the extent this

information is updated in the Exchange Act report.)

• Disclosure required by Item 1.05 of Form 8-K (disclosure of material cybersecurity incidents) must be

tagged in Inline XBRL.

• Financial statements must be tagged in Inline XBRL (when the form includes audited annual financial

statements that are a revised version of financial statements that previously were filed with the

Commission).

Form 13F110

• Form 13F must be filed in XML format. (Form 13F is a quarterly report of certain holdings filed by

institutional investment managers that manage equity securities, generally exchange-listed, with a

value of $100 million or more. This includes investment advisers, banks, insurance companies,

broker-dealers, pension funds, and corporations.)

Form SHO 111

• Form SHO, a monthly report of certain short position data and short activity data for certain equity

securities that is required of institutional investment managers that meet certain reporting thresholds,

must be filed in XML format. 112

Fund Disclosures in Schedules and Forms under Exchange Act Section 14

Schedules 14A/14C113

• For BDCs, disclosure required by Item 402(v) of Regulation S-K (pay versus performance) must be

tagged in Inline XBRL.

• For BDCs, disclosure required by Item 402(w) of Regulation S-K (registrant’s action to recover

erroneously awarded compensation) must be tagged in Inline XBRL.

• For BDCs, disclosure required by Item 402(x) of Regulation S-K (registrant’s policies and practices

related to the grant of certain equity awards close in time to the release of material non-public

information) must be tagged in Inline XBRL.

• For BDCs, disclosure required by Item 408(b)(1) of Regulation S-K (registrant’s insider trading

arrangements and policies) must be tagged in Inline XBRL.

• Filing fee exhibits must be tagged in Inline XBRL.

Form N-PX 114

• Form N-PX must be filed in XML format. (Form N-PX is used by registered management investment

companies (other than SBICs) and institutional investment managers to file annual reports that

contain their proxy voting records. The filing of Form N-PX satisfies Exchange Act reporting

obligations for institutional investment managers.)

1

See James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, Pub. L. No. 117-263, 136 Stat. 2395 (2022).

2 See FDTA Section 5825(b).

3 See FDTA Section 5825(c) (“Beginning on the date that is 7 years after the date of enactment of this Act, this section shall have no force or

effect.”).

4 See FDTA Section 5825(b)(2). A separate provision of the FDTA states that the term “machine-readable,” when used with respect to data,

means data in a format that can be easily processed by a computer without human intervention while ensuring no semantic meaning is lost.

See FDTA Section 5811 (providing that the term “machine-readable” shall have the meaning given in 44 U.S.C. 3502(18)).

5 15 U.S.C. 77g.

6 15 U.S.C. 78m.

7 15 U.S.C. 78n.

8 See Rulemaking for EDGAR System, Release No. 33-8590 (July 18, 2005) [70 FR 43558 (July 27, 2005)].

EDGAR FILER MANUAL, Ch. 8-9 (Version 74, Mar. 24, 2025), SEC. & EXCH. COMM’N, available at

https://www.sec.gov/edgar/filermanual.

9 See

10 See, e.g., Electronic Submission of Orders Under the Advisers Act and the Investment Company Act, Confidential Treatment Requests

for Filings on Form 13F, and Form ADV-NR; Amendments to Form 13F, Release No. 34-95148 (Jun. 23, 2022) [87 FR 38943 (Jun. 30,

2022)] (see infra Section IV.B. stating that fund managers submit Form 13F on EDGAR in XML); Short Position and Short Activity

Reporting by Institutional Investment Managers, Release No. 34-98738 (Oct. 13, 2023) [88 FR 75100 (Nov. 1, 2023)] (“Short Reporting

Adopting Release”) (see infra Section II.A.4.b discussing decision to adopt XML as Form SHO reporting format).

11 See Interactive Data to Improve Financial Reporting, Release No. 33-9002 (Jan. 30, 2009) (adopting release) [74 FR 6776 (Feb. 9, 2009)]

(“Interactive Data to Improve Financial Reporting”) as corrected by Interactive Data to Improve Financial Reporting, Release No. 33-9002A

[74 FR 15666 (Apr. 7, 2009)].

12 See Interactive Data to Improve Financial Reporting, supra note 11, at 6778 (describing how financial reporting in XBRL involves the

use of standard tags that cover “financial concepts that can be read and understood by software applications”). See also XBRL: What Is It?

Why the FASB? Who Uses It?, FASB.ORG (Apr. 1, 2021), available at https://www.fasb.org/Page/ShowPdf?path=FASB_in_Focus-XBRL_(4-21).pdf (“[XBRL] is the open international standard for digital business reporting. XBRL is used to deliver human-readable

financial statements in a machine-readable, structured data format.”).

13 See Interactive Data for Mutual Fund Risk/Return Summary, Release No. 33-9006 (Feb. 11, 2009) (adopting release) [74 FR 7748 (Feb.

19, 2009)] as corrected by Interactive Data for Mutual Fund Risk/Return Summary; Correction, Release No. 33-9006A [74 FR 21255

(May 7, 2009)].

14 See Inline XBRL Filing of Tagged Data, Release No. 33-10514 (Jun. 28, 2018) (Adopting Release) [83 FR 40846 (Aug. 16, 2018)]

(“Inline XBRL Filing of Tagged Data Adopting Release”).

15 See Inline XBRL Filing of Tagged Data Adopting Release, supra note 14, at Section III.A.1.a. Structured data is data that is tagged to

make it machine-readable.

16 See, e.g., FAST Act Modernization and Simplification of Regulation S-K, Release No. 33-10618 (Mar. 20, 2019) (adopting release) [84

FR 12674 (Apr. 2, 2019)] as corrected by FAST Act Modernization and Simplification of Regulation S-K; Correction, Release No.

33-10618A [84 FR 39966 (Aug. 13, 2019)]; Filing Fee Disclosure and Payment Methods Modernization, Release No. 33-10997 (Oct. 13,

2021) (adopting release) [86 FR 70166 (Dec. 9, 2021)] (“Filing Fee Disclosure and Payment Methods Modernization Adopting Release”);

Holding Foreign Companies Accountable Act Disclosure, Release No. 34-93701 (Dec. 2, 2021) (adopting release) [86 FR 70027 (Dec. 9,

2021)]; Insider Trading Arrangements and Related Disclosures, Release No. 33-11138 (Dec. 14, 2022) [87 FR 80362 (Dec. 29, 2022)];

Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure, Release No. 33-11216 (July 26, 2023) [88 FR 51896 (Aug.

4, 2023)]; Investment Company Names, Release No. 33-11238 (Sep. 20, 2023) [88 FR 70436 (Oct. 11, 2023)]; Special Purpose Acquisition

Companies, Shell Companies, and Projections, Release No. 33-11265 (Jan. 24, 2024) [89 FR 14158 (Feb. 26, 2024)]; Registration for IndexLinked Annuities; Amendments to Form N-4 for Index-Linked and Variable Annuities, Release No. IC-35273 (July 1, 2024) [89 FR 59978

(July 24, 2024)]. See also Standard Taxonomies, Sec. & Exch. Comm’n (last modified Feb. 4, 2025), available at

https://www.sec.gov/info/edgar/edgartaxonomies (providing information on the current taxonomies supported by the Commission’s Interactive

Data program).

On April 4, 2024, the Commission issued an order staying the climate-related disclosure rules it adopted on March 6, 2024. This delayed the

effective date of those rules pending the completion of judicial review of consolidated Eighth Circuit petitions. See Order Issuing Stay, Release

No. 34-11280 (Apr. 4, 2024) [89 FR 25804 (Apr. 12, 2024)]; see also The Enhancement and Standardization of Climate-Related Disclosures

for Investors, Release No. 33-11275 (Mar. 6, 2024) (adopting release) [89 FR 21668 (Mar. 28, 2024)] (“Climate Risk Disclosure Rule”).

Consequently, the Climate Risk Disclosure Rule’s structured data tagging requirements are not in effect and will not go into effect unless or

until the Commission publishes a notice of a new effective date. On March 27, 2025, the Commission voted to end its defense of the rules.

Following the Commission’s vote, Commission staff sent a letter to the court stating that the Commission withdrew its defense of the rules,

and that Commission counsel are no longer authorized to advance the arguments in the brief the Commission had filed.

17 Including Form SDR discussed in the Appendix at A-5.

18 See Financial Data Transparency Act Joint Data Standards, Release No. 33-11295 (Aug. 2, 2024) [89 FR 67890 (Aug. 22, 2024)].

19 See FDTA Section 5825(b).

20 See, e.g., Xin Luo et al., Initial Evidence on the Market Impact of the iXBRL Adoption, 37 ACCT. HORIZONS 143 (2023); Yuyun Huang et

al., Information Processing Costs and Stock Price Informativeness: Evidence from the XBRL Mandate, 46 AUSTL. J. MGMT. 110 (2021)

(“Information Processing Costs”); Ju-Chun Yen & Tawei Wang, The Association Between XBRL Adoption and Market Reactions to

Earnings Surprises, 29 J. INFO. SYS. 51 (2015); Yi Dong et al., Does Information-Processing Cost Affect Firm-Specific Information

Acquisition? Evidence from XBRL Adoption, 51 J. FIN. & QUANTITATIVE ANALYSIS 435 (2016); Yanan Zhang et al., XBRL Adoption and

Expected Crash Risk, 38 J. ACCT. & PUB. POL’Y 31 (2019); Jap Efendi et al., Do XBRL Filings Enhance Informational Efficiency? Early

Evidence from Post-earnings Announcement Drift, 67 J. BUS. RSCH. 1099 (2014). See also J. Efrim Boritz & Won Gyun No, How Significant

Are the Differences in Financial Data Provided by Key Data Sources? A Comparison of XBRL, Compustat, Yahoo! Finance, and Google

Finance, 34 J. INFO. SYS. 47 (2020); Raunaq S. Pungaliya & Yanbo Wang, Machine Invasion: Automation in Information Acquisition and

the Cross-Section of Stock Returns, 64 J. FIN. MARKETS. (2023); Marcin Jaskowski & Daniel Rettl, Information Acquisition Costs and Credit

Spreads, 149 J. BANKING FIN. (2023).

21 See,

e.g., Yuyun Huang et al., Information Processing Costs, supra note 20; Bing Li et al., The Impact of XBRL Adoption on Local Bias:

Evidence from Mandated US Filers, 39 J. ACCT. & PUB. POL’Y 106767 (2020). See also Jeong-Bon Kim et al., Information‐Processing Costs

and Breadth of Ownership, 36 CONTEMP. ACCT. RSCH. 2408 (2019); Nilabhra Bhattacharya et al., Leveling the Playing Field Between Large

and Small Institutions: Evidence from the SEC’s XBRL Mandate, 93 ACCT. REV. 51 (2018); but see Elizabeth Blankespoor et al., Initial

Evidence on the Market Impact of the XBRL Mandate, 19 REV. ACCT. STUD. 1468 (2014).

22 See, e.g., Andrew J. Felo et al., Can XBRL Detailed Tagging of Footnotes Improve Financial Analysts’ Information Environment? 28

INT’L. J. ACCT. INFO. SYS. 45 (2018) (“XBRL Detailed Tagging of Footnotes”); Marcus Kirk et al., From Print to Practice: XBRL Extension

Use and Analyst Forecast Properties (Aug. 18, 2016), available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2826159 (retrieved

from SSRN Elsevier database); Chunhui Liu et al., XBRL’s Impact on Analyst Forecast Behavior: An Empirical Study, 33 J. ACCT. & PUB.

POL’Y 69 (2014); but see Sherwood Lane Lambert et al., Analysts’ Forecasts Timeliness and Accuracy Post-XBRL, 27 INT’L J. ACCT. & INFO.

MGMT. 151 (2019). See also Alastair Lawrence et al., Investor Demand for Sell-Side Research, 92 ACCT. REV. 123 (2017); See also, e.g., Nina

Trentmann, Companies Adjust Earnings for Covid-19 Costs, But Are They Still a One-Time Expense?, WALL ST. J. (2020) (citing an XBRL

research software provider as a source for the analysis described in the article); Bloomberg Lists BSE XBRL Data, XBRL.ORG (Mar. 17,

2019).

23 See, e.g., Elizabeth Blankespoor, The Impact of Information Processing Costs on Firm Disclosure Choice: Evidence from the XBRL

Mandate, 57 J. ACCT. RSCH. 919 (2019); Jeong-Bon Ki et al., Does XBRL Adoption Constrain Earnings Management? Early Evidence from

Mandated U.S. Filers, 36 CONTEMP. ACCT. RSCH. 2610 (2019). See also Steve Yang et al., The Impact of XBRL on Financial Statement

Structural Comparability, in NETWORK, SMART AND OPEN: THREE KEYWORDS FOR INFORMATION SYSTEMS INNOVATION 193 (Rita Lamboglia

et al., ed. 2018); but see Sandip Dhole et al., Effects of the SEC’s XBRL Mandate on Financial Reporting Comparability, 19 INT’L J. ACCT.

INFO. SYS. 29 (2015).

e.g., Yuan George Shan & Indrit Troshani, Does XBRL Benefit Financial Statement Auditing? 54 J. COMPUT. INFO. SYS. 11 (2014)

(finding XBRL adoption to be negatively associated with audit fees due to its facilitation of the auditing process through enhancement of

financial statement transparency); Hui Du & Kean Wu, XBRL Mandate and Timeliness of Financial Reporting: Do XBRL Filings Take

Longer? 15 J. EMERG. TECH. ACCT. 57 (2018) (finding decreased reporting lags for XBRL filings compared to non-XBRL filings from

accelerated and large accelerated filers, but not for non-accelerated filers, and postulating that accelerated and large accelerated filers have

24 See,

updated their computer system to use a systemic accounting ecosystem); Keval Amin et al., The Effect of the SEC’s XBRL Mandate on Audit

Report Lags, 32 ACCT. HORIZONS 1 (2018) (finding decrease in audit report lags and audit fees following the mandatory adoption of

XBRL, likely driven at least in part by auditor efficiency gains).

25 See Wafa Sassi et al., The Impact of Mandatory Adoption of XBRL on Firm’s Stock Liquidity: A Cross-Country Study, 19 J. FIN.

REPORTING & ACCT. 299 (2021); Chae-Won Ra & Ho-Young Lee, XBRL Adoption, Information Asymmetry, Cost of Capital, and Reporting

Lags, 10 IBUSINESS, 93 (2018); Syou-Ching Lai et al., 23 XBRL Adoption and Cost of Debt, INT’L. J. ACCT. & INFO. MGMT. 199 (2015);

Tienshih Hsieh & Jean C. Bedard, Impact of XBRL on Voluntary Adopters’ Financial Reporting Quality and Cost of Equity Capital, 15 J.

EMERGING TECHNOLOGIES IN ACCT. 45 (2018); Xin Cheng et al., How Does Information Processing Efficiency Relate to Investment

Efficiency? Evidence from XBRL Adoption, 35 J. INFO. SYS. 1 (2021); Olivia Berkman, XBRL: What are the Benefits, FEI DAILY (Aug. 29,

2019), available at https://www.financialexecutives.org/FEI-Daily/August-2019/XBRL-What-are-the-Benefits.aspx (“Berkman, XBRL

Benefits”); Marcin Jaskowski & Daniel Rettl, Information Acquisition Costs and Credit Spreads, 149 J. BANKING FIN. 106775 (2023).

26 Specific examples of Commission staff usage of machine-readable disclosures are provided in subsequent sections. Other Financial

Stability Oversight Council member-agency staff use the Commission’s machine-readable data to inform their regulatory efforts. See, e.g.,

Samuel

J. Hempelatethttps://doi.org/10.17016/2380-7172.3412

al., Money Market Fund Repo and the ON

RRPcustom

Facility,

FEDS

Notes,

BD. G

OVERNORS

FEDhow

. RSRV

. SYS.market

(Dec. 15,

2023), available

(using

XML

Form

N-MFP

data

to examine

money

funds’

investments in the Fed’s overnight reverse repurchase facility impacted their lending to the private repo market).

27 For example, the Negative Values validation rule can automatically check for instances where negative values are reported for elements that

must always be positive or zero. See Approved Validation Rules, XBRL US (Mar. 2025), available at https://xbrl.us/data-quality/rulesguidance/; Negative Values, XBRL US (last modified Jun. 27, 2024), available at https://xbrl.us/data-rule/dqc_0015/. See also EDGAR XBRL

Validation Errors, SEC. & EXCH. COMM’N (last modified Mar. 17, 2025), available at

https://www.sec.gov/structureddata/edgarvalidationerrors; EDGAR XBRL Validation Warnings, SEC. & EXCH. COMM’N (last modified Mar.

17, 2025), available at https://www.sec.gov/page/osd_edgarvalidationwarnings.

28 Inline XBRL documents are both human-readable and machine-readable. XML documents are rendered into human-readable versions on

the Commission’s public-facing website, https://www.sec.gov/edgar/searchedgar/companysearch.

29 See DERA Data Library, SEC. & EXCH. COMM’N (last modified Mar. 11, 2025), available at https://www.sec.gov/about/divisions-offices/

division-economic-risk-analysis/dera-data-library; Structured Disclosure RSS Feeds, SEC. & EXCH. COMM’N (last modified Jun. 25, 2024),

available at https://www.sec.gov/structureddata/rss-feeds ; EDGAR Application Programming Interfaces, SEC. & EXCH. COMM’N (last

modified April 8, 2025), available at https://www.sec.gov/edgar/sec-api-documentation; see infra p. 15, Public Use of the MachineReadable Data That the Commission Collects (describing other data users).

30 See AICPA, XBRL Cost Study Reveals Lower Than Expected Filing Costs (2023), available at https://www.aicpa-cima.com/professional-

insights/download/xbrl-cost-study-reveals-lower-than-expected-filing-costs (Republishing a XBRL US and AICPA 2018 study that found a

45% decline in XBRL costs for small companies from 2014 to 2017).

31 See Feng Guo, Xin Luo, Patrick R. Wheeler, Liu Yang, Xinlei Zhao, & Yiyang Zhang, Enterprise Resource Planning Systems and XBRL

Reporting Quality, 35 J. INFO. SYS. 77-106 (2021).

32 See AICPA, XBRL Cost Study Reveals Lower Than Expected Filing Costs, supra note 30. While the survey did not specify the particular

filings covered, XBRL filing requirements for reporting companies at the time of the sample included the XBRL (non-Inline) tagging of

quarterly and annual financial statements filed in periodic reports (e.g., Forms 10-Q, 10-K, and 20-F) and registration statements (e.g., Forms

S-1, S-3, and F-1) that included a price or price range and were filed after the first 10-Q, 20-F, or 40-F following the company’s initial public

offering.

33 See letter from Nasdaq, Inc. (Mar. 21, 2019), available at https://www.sec.gov/comments/s7-26-18/s72618-5177722-183507.pdf, Request

for Comment on Earnings Releases and Quarterly Reports, Release No. 33-10588 [83 FR 65601 (Dec. 21, 2018)].

34 See, e.g., Electronic Submission of Certain Material Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS

Report, Release No. 33-11176 (Mar. 22, 2023) (proposing release) [88 FR 23920 (Apr. 18, 2023)] (“Electronic Submission Proposing

Release”) (observing a greater amount of tagged information in filings from a population of Nasdaq-listed companies than in filings from a

population of small companies). See also Bok Baik et al., Organizational Complexity, Financial Reporting Complexity, and Firms’

Information Environment, (Apr. 19, 2023), available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4413814 (retrieved from

SSRN Elsevier database) (finding organization complexity, as measured by number of subsidiaries and layers in the corporate hierarchy,

influences

financial reporting complexity and managers of complex firms find it beneficial to ameliorate information asymmetries by increasing

voluntary disclosure).

35 44 U.S.C. § 3501 et seq.

36 A “response” is a filing that requires Inline XBRL tagging; see Inline XBRL Filing of Tagged Data Adopting Release, supra note 14, at

40869. These figures represent the costs of tagging financial statements in Inline XBRL (not the costs of switching from XBRL to Inline

XBRL) for operating companies subject to financial statement tagging requirements.

37 See OMB, Supporting Statement for the Paperwork Reduction Act Information Collection Submission for Interactive Data: OMB Control

Number 3235–0645, Attachment A (Jun. 6, 2022), available at https://omb.report/icr/202203-3235-001/doc/122014900.

38 See Electronic Submission Proposing Release, supra note 34, at 23986. Some compliance service providers publicly disclose or advertise

pricing information on their websites. See, e.g., EDGAR Filing Services, ADVANCED COMP. INNOVATIONS, INC., available at

http://www.edgar-services.com/ (last visited Mar. 21, 2025). Other compliance service providers do not publicly disclose pricing

information on their websites, instead requiring individual pricing consultations.

39 See Electronic Submission Proposing Release, supra note 35, at 23986.

40 The six EPS cases covered a wide variety of practices that impacted EPS. See In re Interface, Inc., Release Nos. 33-10854, 34-90018 (Sep.

28, 2020) (settled action); In re Fulton Fin. Corp., Release No. 34-90017 (Sep. 28, 2020) (settled action); In re Healthcare Services Grp., Inc.,

Release Nos. 33-10967, 34-92735 (Aug. 21, 2021) (settled action); In re Rollins Inc., Release Nos. 33-11052, 34-94742 (Apr. 18, 2022)

(settled action); SEC v. Hutchison, No. 1:22-cv-02296 (D.D.C. filed Aug. 3, 2022) (litigated action and In re Surgalign Holdings, Inc.,

Release No. 33-11088 (Aug. 3, 2022) (settled action); and In re Gentex Corp., Release No. 34-96819 (Feb. 7, 2023) (settled action).

41 See In re Grupo Aval Acciones y Valores S.A. and Corporación Financiera Colombiana S.A., Release No. 34-98103 (Aug. 10, 2023) (settled

action).

42 See In re Avaya Holdings Corp., Release No. 33-11320 (Oct. 22, 2024) (settled action); In re Check Point Software Technologies Ltd.,

Release No. 11321 (Oct. 22, 2024) (settled action); In re Mimecast Limited, Release No. 33-11322 (Oct. 22, 2024) (settled action); In re

Unisys Corporation, Release No. 33-11323 (Oct. 22, 2024) (settled action).

43 Information and lists of Commission-Identified Issuers under the Holding Foreign Companies Accountable Act are available on the

Commission’s website at https://www.sec.gov/hfcaa.

Division of Corporation Finance, Sample Letter to Companies Regarding Their XBRL Disclosures, SEC. & EXCH. COMM’N (Sep. 7,

2023), https://www.sec.gov/corpfin/sample-letter-companies-regarding-their-xbrl-disclosures.

44 See

Division of Investment Management, Accounting and Disclosure Information 2019-09, Performance and Fee Issues, SEC. & EXCH.

COMM’N (Oct. 2, 2019) (“Investment Management, Accounting and Disclosure Information 2019-09”),

https://www.sec.gov/investment/accounting-and-disclosure-information/performance/adi-2019-09-performance-and-fee-issues. See also

Division of Investment Management, Accounting and Disclosure Information 202419-14, Tailored Shareholder Report Common Issues, SEC.

& EXCH. COMM’N (Nov. 14, 2024) at Section 7, https://www.sec.gov/about/divisions-offices/division-investment-management/accountingdisclosure-information/adi-2024-14-tailored-shareholder-report-common-issues.

45 See

46 The disclosure review program

refers to the staff’s review of fund registration statements, proxy materials, shareholder reports and other

disclosures.

47 See Investment Management, Accounting and Disclosure Information 2019-09, supra note

45.

Filing Fee Disclosure and Payment Methods Modernization Adopting Release, supra note 17. The Commission opted to phase in the

structuring requirements over time but otherwise require compliance upon effectiveness of the rules. For large accelerated filers, the

compliance date for the structuring requirements is for filings submitted on or after July 31, 2024. For accelerated filers, certain investment

companies that file registration statements on Forms N-2 and N-14, and all other filers, the compliance date for the structuring requirements is

for filings submitted on or after July 31, 2025. Filers are now permitted to file the structured information before their applicable compliance

dates. See id. at Section II.A.6.

48 See

49 See FDTA Section 5825.

50 See, e.g., Research on Net Operating Losses, CALCBENCH (June 2, 2024), available at

https://www.calcbench.com/blog/post/blogger1440602637628276271/Research-on-Net-Operating-Losses (citing a Morgan Stanley research

note that uses a XBRL data source to analyze net operating losses carried on company books).

51 See, e.g., 2019 Pension Review First Take: Flat to Down, GOLDMAN SACHS ASSET MGMT. (2020) (an example of asset manager use of

XBRL data), available at

https://www.gsam.com/content/dam/gsam/pdfs/common/en/public/articles/2020/2019_Pension_First_Take.pdf?sa=n&rd=n (citing an

XBRL research software provider as a data source).

52 See Berkman, XBRL Benefits, supra note 25.

53 See, e.g., A Final Update on Q4 Earnings, CALCBENCH (Feb. 28, 2015), available at

https://www.calcbench.com/blog/post/blogger396660381590226168/A-Final-Update-on-Q4-Earnings (using XBRL earnings data from

fourth quarter 2024 to discuss year over year earnings trends).

54 See, e.g., Jeong-Bon Kim, Bing Li, & Zhenbin Liu, Information-Processing Costs and Breadth of Ownership, 36 CONTEMP. ACCT. RSCH.

2408 (2019) (finding that the decreased information-processing costs brought about by XBRL help firms establish a level playing field by

reducing the information disadvantages of individual and foreign institutional investors over domestic institutional investors).

55 See How Third Party Data Providers Use Structured Data and Why, supra note 53.

56 See, e.g., Stuart Kirk, A beginner’s guide to US earnings season, FIN. TIMES (Oct. 17, 2024), available at

https://www.ft.com/content/60b1e2a5-8667-47b8-ac04-00d4ad85e01f (citing an XBRL research software provider as a data source).

57 See

Investment Management, Accounting and Disclosure Information 2019-09, supra note 53.

58 See, e.g., Rani Hoitash & Udi Hoitash, Measuring Accounting Reporting Complexity with XBRL, 93 ACCT. REV. 259-287 (2018)

(“Hoitash & Hoitash, Measuring Accounting Reporting Complexity”).

59 See

XBRL Detailed Tagging of Footnotes (and related citations), supra note 22.

60 See Hoitash & Hoitash, Measuring Accounting Reporting Complexity, supra note 67; Rimona Palas et al., Does Wedge Size Matter?

Financial Reporting Quality and Effective Regulation of Dual-class Firms. FIN. RES. LETTERS 54 (2023) (using XBRL financial statement

data to assess reporting patterns in firms with dual-class share structures).

61 XBRL: What Is It? Why the FASB? Who Uses It?, FASB.org, available at

https://www.fasb.org/page/PageContent?pageId=/staticpages/what-is-xbrl.html&isstaticpage=true.

62 For

example, the Commission’s quarterly XBRL datasets for mutual fund prospectus risk/return summaries garnered over 32,000 page

views from over 11,500 unique visitors from February 2024 to February 2025, according to a Splunk query of the Commission’s XBRL

dataset webpage, which is available at https://www.sec.gov/data-research/sec-markets-data/mutual-fund-prospectus-riskreturn-summary-datasets.

63 See, e.g., Jamie Chisholm, Tesla was hot, Apple was not, Hedge-Fund Holdings Filings Show, MARKETWATCH (Feb. 19, 2025), available

at https://www.marketwatch.com/story/tesla-was-hot-apple-was-not-hedge-fund-filings-show-5f86601c (example of news media article

analyzing 13F data); Travis A. Dyer, The Demand for Public Information by Local and Non-local Investors: Evidence from Investor-Level

Data, 72 J. ACCT. & ECON. 1 (Aug. 2021); Ron Kaniel & Pingle Wang, Unmasking Mutual Fund Use During COVID-19 Crisis, 49 COVID

ECON. 172 (Sept. 18, 2020) (example of academic research using the XML dataset from the Commission’s Form N-PORT).

64 Based on Splunk results for Form 13F data set downloads between August 1, 2022, and Feb. 28, 2025, accessed on Mar. 14, 2025.

65 See, e.g., Press Release, SEC. & EXCH. COMM’N, SEC Publishes FY22-26 Strategic Plan (Nov. 23, 2022), available at

https://www.sec.gov/news/press-release/2022-210. See also SEC Office of the Chief Data Officer, Data Strategy For Fiscal Years 2022-2026

(Jan. 26, 2023), available at https://www.sec.gov/files/2022-ocdo-data-strategy-fy2022-2026.pdf; SEC and Markets Data (includes structured

datasets extracted from individual XML submissions), available at https://www.sec.gov/data-research/sec-markets-data; Investment

Management Data (includes Commission staff reports with downloadable statistics), available at https://www.sec.gov/dataresearch/investment-management-data.

66 See, e.g., Foundations for Evidence-Based Policymaking Act of 2018, Pub. L. No. 115-435, 132 Stat. 5529 (“Evidence Act”). Title II of

the Evidence Act, enacted as the Open, Public, Electronic, and Necessary (OPEN) Government Data Act, sets forth a framework for

managing government information as a strategic asset at each stage of the information’s life cycle to promote accessibility and usability. See

Pub. L. No. 115-435, 132 Stat. 5534.

67 Filers are not yet required to provide some of the disclosures and structured data tags described in this Appendix.

68 As used in this report, the reference to financial statements means the face of the financial statements and accompanying footnotes. The

face of the financial statements refers to the statement of financial position (balance sheet), income statement, statement of comprehensive

income, statement of cash flows, and statement of owners’ equity, as required by Commission regulations. References to the financial

statements as required for interactive data reporting include any required schedules to the financial statements, unless otherwise stated.

69 Financial statements in Securities Act registration

statements are required to be tagged when physically included (i.e., not incorporated by

reference) unless the registration statement is for an initial public offering (IPO), in which case, the financial statements are not required to be

tagged. See Rule 601(b)(101)(i)(A) and paragraph (101)(a)(i) of Part II - Information Not Required to be Delivered to Offerees or

Purchasers of Form F-10.

70 A reference copy of Form S-1 is available at https://www.sec.gov/files/forms-1.pdf.

71 A reference copy of Form S-3 is available at https://www.sec.gov/files/forms-3.pdf.

72 A reference copy of Form S-4 is available at https://www.sec.gov/files/forms-4.pdf.

73 A reference copy of Form S-8 is available at https://www.sec.gov/files/forms-8.pdf.

74 A reference copy of Form S-11 is available at https://www.sec.gov/files/forms-11.pdf.

75 A reference copy of Form F-1 is available at https://www.sec.gov/files/formf-1.pdf.

76 A reference copy of Form F-3 is available at https://www.sec.gov/files/formf-3.pdf.

77 A reference copy of Form F-4 is available at https://www.sec.gov/files/formf-4.pdf.

78 A reference copy of Form F-10 is available at https://www.sec.gov/files/formf-10.pdf.

79 A reference copy of Form SF-1 is available at https://www.sec.gov/files/formsf-1.pdf; A reference copy of Form SF-3 is available at https://

www.sec.gov/files/formsf-3.pdf.

80 See Asset-Backed Securities Disclosure and Registration, Release No. 33-9638 (Sep. 4, 2014) (adopting release) [79 FR 57183 (Sep. 24,

2014)] at Section III. The asset-level item requirements are located in 17 CFR 229.1125. The required asset-level information includes: data

points about the payment stream related to a particular asset, such as the contractual terms, scheduled payment amounts, basis for interest rate

calculations and whether and how payment terms change over time; data points that allow for an analysis of the collateral related to the asset,

such as the geographic location of the property, property valuation data and loan-to-value (“LTV”) ratio; data points about the performance

of each asset over time, for example, data about whether an obligor is making payments as scheduled; and data points about the loss

mitigation efforts by the servicer to collect amounts past due and the losses that may be passed on to the investors.

81 The Commission maintains an XML technical specification that includes rules for validation and permitted response codes for each XML

tag. See EDGAR ABS XML Technical Specification (Version 3.1) (Sept. 18, 2023), available at https://www.sec.gov/submitfilings/technical-specifications .

82 A reference copy of Form 10-K is available at https://www.sec.gov/about/forms/form10-k.pdf.

83 A reference copy of Form 10-Q is available at https://www.sec.gov/about/forms/form10-q.pdf.

84 A reference copy of Form 11-K is available at https://www.sec.gov/files/form11-k.pdf.

85 A reference copy of Form 20-F is available at https://www.sec.gov/files/form20-f.pdf.

86 A reference copy of Form 40-F is available at https://www.sec.gov/files/form40-f.pdf.

87 A reference copy of Form ABS-EE is available at https://www.sec.gov/files/formabs-ee.pdf.

88 A reference copy of Form 8-K is available at https://www.sec.gov/about/forms/form8-k.pdf.

89 A reference copy of Form 6-K is available at https://www.sec.gov/about/forms/form6-k.pdf.

90 A reference copy of Form SD is available at https://www.sec.gov/about/forms/formsd.pdf.

91 A reference copy of Form 10-D is available at https://www.sec.gov/files/form10d.pdf.

92 A reference copy of Schedule 13D is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-

ECFR7ce825ff9acf140/section-240.13d-101; A reference copy of Schedule 13G is available at https://www.ecfr.gov/current/title17/chapter-II/part-240/subpart-A/subject-group-ECFR7ce825ff9acf140/section-240.13d-102.

93 A reference copy of Schedule 13E-3 is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-

ECFR7ce825ff9acf140/section-240.13e-100; A reference copy of Schedule 13E-4F is available at https://www.ecfr.gov/current/title17/chapter-II/part-240/subpart-A/subject-group-ECFR7ce825ff9acf140/section-240.13e-102; A reference copy of the statement under Rule

13e-1 is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-ECFR7ce825ff9acf140/

section-240.13e-1.

94 See Cross-Border Application of Certain Security-Based Swap Requirements, Release No. 34-87780 (Dec. 18, 2019) (adopting release) [85

FR 6270 (Feb. 4, 2020)].

95 A reference copy of Schedule 14A is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-

ECFR8c9733e13b955d6/section-240.14a-101; A reference copy of Schedule 14C is available at https://www.ecfr.gov/current/title17/chapter-II/part-240/subpart-A/subject-group-ECFR39f2044c974eb3d/section-240.14c-101.

96 A reference copy of Schedule TO is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-

ECFR7c5428565389260/section-240.14d-100

97 A reference copy of Schedule 14D-1F is available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-group-

ECFR7c5428565389260/section-240.14d-102

98 A reference copy of Form N-1A is available at https://www.sec.gov/files/form-n-1a.pdf.

99 A reference copy of Form N-2 is available at https://www.sec.gov/files/formn-2.pdf.

100 A reference copy of Form N-3 is available at https://www.sec.gov/files/formn-3.pdf.

101 A reference copy of Form N-4 is available at https://www.sec.gov/files/formn-4.pdf.

102 A reference copy of Form N-6 is available at https://www.sec.gov/files/formn-6.pdf.

103 A reference copy of Form N-14 is available at https://www.sec.gov/files/formn-14.pdf.

104 A reference copy of Form N-8B-2 is available at https://www.sec.gov/about/forms/formn-8b-2.pdf; A reference copy of Form S-6 is

available at https://www.sec.gov/files/forms-6.pdf.

105 A reference copy of Form N-CSR is available at https://www.sec.gov/files/formn-csr.pdf.

106 A reference copy of Form N-CEN is available at https://www.sec.gov/files/formn-cen.pdf.

107 See supra note 89.

108 See supra note 9083.

109 See supra note 95.

110 A reference copy of Form 13F is available at https://www.sec.gov/pdf/form13f.pdf.

111 A reference copy of Form SHO is available at https://www.federalregister.gov/documents/2023/11/01/2023-23050/short-position-and-

short-activity-reporting-by-institutional-investment-managers#h-194.

112 The Commission has extended the compliance date for the rule until 2026. See Order Granting Temporary Exemption Pursuant to Section

13(f)(3) of the Securities Exchange Act of 1934 From Compliance With Rule 13f-2 and Form SHO [Release No. 34-102380 (Feb. 13,

2025)].

113 See supra note 102.

114 A reference copy of Form N-PX is available at https://www.sec.gov/files/formnpx.pdf.

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