# Regarding Public and Internal

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3A322650caa47e44ea

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

U.S. Securities and
Exchange Commission

SEMI-ANNUAL REPORT
TO CONGRESS
Regarding Public and Internal
Use of Machine-Readable Data
for Corporate Disclosures
December 2025

This is a report prepared by staff of the U.S. Securities and Exchange Commission. The Commission has expressed no view
regarding any analysis, findings, or conclusions contained herein.

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 2 on the public and internal use of machine-readable data for corporate
disclosures. 3 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. 4
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. 5
This report contains the following new information since the last report: 6 updated
statistics in the analysis of the costs and benefits of the use of machine-readable data.

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”), 7 Section 13 of the
Securities Exchange Act of 1934 (the “Exchange Act”), 8 and Section 14 of the Exchange Act 9
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 the use of 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”), 10 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. 11 The Commission continues to support XML
for various reporting requirements. 12

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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”), 13 which is a machinereadable, structured data language used for standardized reporting of business information,
including information relating to the financial performance of companies. 14 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. 15
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. 16 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. 17 The Commission continues to support Inline
XBRL for various disclosure requirements. 18

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) 19 do not require
any machine-readable 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. 20 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. 21The agencies continue to consider these comments and work together toward
adopting a final rule that establishes final joint standards.

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Analysis of the Costs and Benefits of the Use of Machine-Readable Data
FDTA Section 5825(b)(2)(B) requires an analysis of the costs and benefits of using
machine-readable data in corporate disclosure to investors, markets, the Commission, and
issuers. 22

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. 23 Machine-readability has
enhanced market competition by, for example, reducing insider advantages relative to noninsiders and local investor advantages relative to non-locals. 24 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. 25 Greater monitoring has driven firms to
provide more quantitative disclosure and report earnings in a more consistent manner. 26 Such
benefits may increase over time as tools for investor use of machine-readable data become more
widely available. Machine-readable data also includes metadata that provides contextual
information that is highly relevant for training artificial intelligence (AI) and enabling machinelearning analyses, which are increasingly being used by investors. 27 Studies have also found that
providing large language models (LLMs) with structured data reduces error rates compared to
HTML or unstructured data, and improved LLM performance and cost-effectiveness on financial
tasks. 28 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. 29 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. 30 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. 31 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. 32

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 machine-3-

readable versions of corporate disclosures, because the disclosures are human-readable as well. 33
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. 34
Filers incur compliance costs to apply machine-readable tags to their disclosures or pay a
third-party 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. 35 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. 36 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 are both
subject to Form N-2 prospectus and cover page tagging requirements. Because BDCs are
registered under the Exchange Act, they are also subject to financial statement tagging
requirements 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 (“SRCs”) in 2018
found a median cost of $2,500 per year for fully outsourced XBRL creation and filing. 37 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. 38
The discrepancy may be because Nasdaq-listed companies include many companies that are not
SRCs. Many of these non-SRCs have longer, more detailed, and more complex financial
statements than SRCs, and thus have more tags that they may 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 leading to increased compliance costs compared
to SRCs.39
Both surveys were conducted before the compliance dates for the Commission’s
transition from XBRL to Inline XBRL 40 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, 41 Commission staff estimated in the Inline XBRL Filing of Tagged Data
Adopting Release that using Inline XBRL rather than XBRL to tag financial statements would
reduce the existing aggregate average internal burden of 56 hours per response for reporting
companies by two (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. 42 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. 43 In 2025, in response to a request for comment 44 on the burden estimate, XBRL
U.S. conducted a survey of 26 issuers to better assess the burden on issuers. 45 Based on hours
spent by all respondents, XBRL U.S. estimated that the average internal time spent by an issuer
(i.e., not including time spent by its service provider) on XBRL preparation is around 22 hours
and commented accordingly. 46 Notwithstanding the survey, Commission staff maintained the
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internal burden estimate of 53 hours per response, stating, in part, that the comment may not be
representative of the average respondent to which the estimate is directed. 47
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. 48 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. 49
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. These costs include 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 used and analyzed machine-readable data during the underlying
investigation of an action brought in 2023. 50
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. 51

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Analysis of How the Commission’s Staff Uses the Machine-Readable
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,
audit-related 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
(“Commission-Identified Issuers”). 52 Specifically, the staff uses data in Forms 10-K, 20F, 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).

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•

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. 53 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
machine-readable 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. 54 The ability to scan across the industry for funds with certain disclosures
and characteristics enhances Investment Management’s disclosure review program, 55
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. 56 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 noncompliance with law or other heightened risks.
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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, gather information relevant to accounting standardsetting projects and requests from other regulators, and prepare 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, 57 the tagging requirements of filing fee-related information 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 feetagging tool and test filings that do not pass specific validation tests will be flagged
before the related live filing is filed. This allows 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 machinereadable data for corporate disclosures.” 58 Users of machine-readable corporate disclosures
include institutional investors, 59 asset managers, 60 issuers, 61 financial analysts and research
firms, 62 individual investors, 63 data aggregators, 64 the financial press, 65 other regulators, 66 and
academics. 67 For example, academic studies indicate that the implementation of XBRL data
requirements appears to be correlated with increased forecast accuracy by financial analysts. 68
Also, financial academics have used XBRL data to study topics such as financial reporting
complexity and dual-class voting structures. 69 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. 70 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. 71 Academics have also studied the use of AI read and report correctly data from
financial statements. 72
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). 73 For example, since August 2022 (when the Form 13F datasets first became
available), there have been over 2,405,438 Form 13F dataset downloads. 74

Conclusion
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The FDTA’s directives coincide with internal Commission and staff efforts 75 to improve
the management and use of data across the agency, consistent with other statutory directives 76 as
well as overall strategic goals to work more efficiently.

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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. 77 All other required disclosures in these filings are submitted in a non-machinereadable 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 78 and disclosure regarding pay-versusperformance, 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. The information in this Appendix is as of January 29,
2026.
Corporate Disclosures in Forms and Schedules under Securities Act Section 7
Securities Act Registration Statements 79
Form S-1 80
• 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 81
• Financial statements must be tagged in Inline XBRL.
• Filing fee exhibits must be tagged in Inline XBRL.
Form S-4 82
• Financial statements must be tagged in Inline XBRL.
A-1

•
•

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 83
• Filing fee exhibits must be tagged in Inline XBRL.
Form S-11 84
• Financial statements must be tagged in Inline XBRL.
• Filing fee exhibits must be tagged in Inline XBRL.
Form F-1 85
• 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-3 86
• Financial statements must be tagged in Inline XBRL.
• Filing fee exhibits must be tagged in Inline XBRL.
Form F-4 87
• 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-10 88
• Financial statements must be tagged in Inline XBRL.
• Filing fee exhibits must be tagged in Inline XBRL.
Form SF-1/SF-3 89 (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 resecuritizations of asset-backed securities, certain asset-level information 90 is required to
be filed under cover of Form ABS-EE in XML format. 91 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.

A-2

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 92
• 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 nonpublic 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 93
• 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 94
• Financial statements must be tagged in Inline XBRL.
Form 20-F 95
• 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.
A-3

•
•
•

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 96
• 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-EE 97
• The information in Form ABS-EE must be filed in XML format.
Form 8-K 98
• 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 99
• 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 SD 100
• Information included in the Resource Extraction Issuer Disclosure Report (Exhibit 2.01)
must be filed in XBRL.
Form 10-D 101
A-4

•

ABS issuers generally are required to file standard Exchange Act filings, including Forms
10-K and 8-K. 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 102
• 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-1 103
• 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 until November 5, 2029 it would not be a basis for enforcement action if “an entity
submitting an application to register would not need to comply with the requirement in Rule 13n1(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.” 104
Corporate Disclosures in Schedules under Exchange Act Section 14
Schedules 14A/14C 105
• 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 nonpublic 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.
A-5

Schedule TO 106
• 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 107
• 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 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 108
• 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-2 109
• 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.)
A-6

•

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-3 110
• 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-4 111
• 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 non-variable annuities must also tag specified
portions of the prospectus that provide information about the annuities’ features, censustype information about the annuities, historical limits on returns, and information about
changes in and disagreements with accountants.)
Form N-6 112
• 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-14 113
• 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-6 114
• 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 115
• 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,
A-7

•

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 116
• 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) 117
• 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 nonpublic 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) 118
• 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.
A-8

Form 8-K (Only for BDCs; optional for registered closed-end funds) 119
• 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 13F 120
• 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 121
• 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. 122
Fund Disclosures in Schedules and Forms under Exchange Act Section 14
Schedules 14A/14C 123
• 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 124
• 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.)
A-9

See James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, Pub. L. No. 117-263, 136 Stat.
2395 (2022).
2
Publication of the December 2025 Semi-Annual Report to Congress Regarding Public and Internal Use of
Machine-Readable Data for Corporate Disclosures was delayed due to the lapse in appropriations from October 1,
2025, through November 12, 2025.
3
See FDTA Section 5825(b).
4
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.”).
5
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 “machinereadable” shall have the meaning given in 44 U.S.C. 3502(18)).
6
U.S. SEC. & EXCH COMM’N, Semi-Annual Report to Congress Regarding Public and Internal Use of MachineReadable Data for Corporate Disclosures, June 2025, available at https://www.sec.gov/files/2025-fdta-machinereadable-data-report.pdf.
7
15 U.S.C. 77g.
8
15 U.S.C. 78m.
9
15 U.S.C. 78n.
10
See Rulemaking for EDGAR System, Release No. 33-8590 (July 18, 2005) [70 FR 43558 (July 27, 2005)].
11
See EDGAR FILER MANUAL, Ch. 8-9 (Volume II, Version 76, Sept. 15, 2025), SEC. & EXCH. COMM’N, available at
https://www.sec.gov/edgar/filermanual.
12
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. 3495148 (Jun. 23, 2022) [87 FR 38943, 38944 (Jun. 30, 2022)] (stating that fund managers submit Form 13F on
EDGAR in XML); Enhanced Reporting of Proxy Votes by Registered Management Investment Companies;
Reporting of Executive Compensation Votes by Institutional Investment Managers, Release No. 33-11131 (Nov. 2,
2022) [87 FR 78770, 78785-86 (Dec. 22, 2022)] (“Enhanced Reporting of Proxy Votes Adopting
Release”)(discussing decision to adopt XML as Form N-PX reporting data language); Short Position and Short
Activity Reporting by Institutional Investment Managers, Release No. 34-98738 (Oct. 13, 2023) [88 FR 75100,
75117-18 (Nov. 1, 2023)] (“Short Reporting Adopting Release”) (discussing decision to adopt XML as Form SHO
reporting format). On December 3, 2025, partly in response to an opinion from the U.S. Court of Appeals for the
Fifth Circuit, the Commission issued an order granting a temporary exemption from compliance with Rule 13f-2 and
Form SHO until January 2, 2028. See Order Granting Temporary Exemptive Relief, Pursuant to Sections 13(f)(3)
and 36(a)(1) of the Securities Exchange Act of 1934 from Compliance with Rule 13f-2 and Form SHO, and
Pursuant to Section 36(a)(1) of the Securities Exchange Act of 1934 from Certain Aspects of Rule 10c-1a [Release
No. 34-104303 (Dec. 3, 2025)] (“Exemptive Relief Order”).
13
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)].
14
See Interactive Data to Improve Financial Reporting, supra note 13, 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 machinereadable, structured data format.”).
15
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)].
16
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”).
17
See Inline XBRL Filing of Tagged Data Adopting Release, supra note 16, at 40851. Structured data is data that is
tagged to make it machine-readable.
18
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
1

A - 10

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. 3311238 (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).
19
Including Form SDR discussed in the Appendix at A-5.
20
See Financial Data Transparency Act Joint Data Standards, Release No. 33-11295 (Aug. 2, 2024) [89 FR 67890
(Aug. 22, 2024)].
21
The comments submitted to the Commission are publicly available at: https://www.sec.gov/comments/s7-202405/s7202405.htm.
22
See FDTA Section 5825(b).
23
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. MKTS art. no. 100788 (2023); Marcin Jaskowski & Daniel Rettl,
Information Acquisition Costs and Credit Spreads, 149 J. BANKING FIN. 106756 (2023) (“Information Acquisition
Costs and Credit Spreads”).
24
See, e.g., Yuyun Huang et al., Information Processing Costs, supra note 23; 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).
25
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. (Sept. 24, 2020), available at
https://www.wsj.com/articles/companies-adjust-earnings-for-covid-19-costs-but-are-they-still-a-one-time-expense11600939813 (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).
26
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

A - 11

(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).
27
See e.g., Amos Baranes et al, Predicting Earnings Directional Movement Utilizing Recurrent Neural Networks
(RNN), 19 J. OF EMER. TECH. IN ACCT 43 (2022) (providing neural networks with XBRL financial statement data to
predict changes of directions in company earnings); Darren Bernard et al., Using GPT to Measure Business
Complexity (Jun. 25, 2023), available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4480309 (using
structured financial statement footnotes and inline XBRL tags to train the LLM to measure the complexity of
business transactions); CFA Institute, How Machine Learning is Transforming the Investment Process, available at
https://www.cfainstitute.org/insights/articles/how-machine-learning-is-transforming-the-investment-process (Mar. 4,
2024).
28
See Farr, Marcelo et al., Can AI be trusted with financial data? (Sept. 15, 2025), available at
https://ssrn.com/abstract=5316518 (providing context in HTML and XBRL formatting greatly improves the scale
accuracy of the AI results and scale errors are virtually eliminated when using an XBRL format); See also XBRL,
Why Structured Data and Definitions Vastly Outperform Unstructured PDFs in LLM Analysis (Dec. 19, 2024),
available at https://www.xbrl.org/why-structured-data-and-definitions-vastly-outperform-unstructured-pdfs-in-llmanalysis/.
29
See, 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
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).
30
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/August2019/XBRL-What-are-the-Benefits.aspx (“Berkman, XBRL Benefits”); Marcin Jaskowski & Daniel Rettl,
Information Acquisition Costs and Credit Spreads, supra note 23 at 106775.
31
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. Hempel et al., Money Market Fund Repo and the ON RRP
Facility, FEDS Notes, BD. GOVERNORS FED. RSRV. SYS. (Dec. 15, 2023), available at
https://doi.org/10.17016/2380-7172.3412 (using custom XML Form N-MFP data to examine how money market
funds’ investments in the Fed’s overnight reverse repurchase facility impacted their lending to the private repo
market).
32
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 (Nov. . 2025),
available at https://xbrl.us/data-quality/rules-guidance/; Negative Values, XBRL US (last modified Feb. 10, 2025),
available at https://xbrl.us/data-rule/dqc_0015/. See also EDGAR XBRL Validation Errors, SEC. & EXCH. COMM’N
(last modified Oct. 14, 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.
33
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.

A - 12

See DERA Data Library, SEC. & EXCH. COMM’N (last modified Dec. 9 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. 13, Public
Use of the Machine-Readable Data That the Commission Collects (describing other data users).
35
See AICPA, XBRL Cost Study Reveals Lower Than Expected Filing Costs (2023), available at https://www.aicpacima.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).
36
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, 77-106 (2021).
37
See AICPA, XBRL Cost Study Reveals Lower Than Expected Filing Costs, supra note 35. 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.
Generally, a registrant qualifies as an SRC if it has a public float of less than $250 million or if it has annual
revenues of less than $100 million and either no public float or a public float of less than $700 million. See Item
10(f) of Regulation S-K, Rule 405 under the Securities Act, and Rule 12b-2 under the Exchange Act.
38
See Letter from Nasdaq, Inc. (Mar. 21, 2019), available at https://www.sec.gov/comments/s7-26-18/s726185177722-183507.pdf; Request for Comment on Earnings Releases and Quarterly Reports, Release No. 33-10588 [83
FR 65601 (Dec. 21, 2018)].
39
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).
40
See Inline XBRL Filing of Tagged Data Adopting Release, supra note 16, at 40857-58. (Large accelerated filers
that prepare their financial statements in accordance with U.S. GAAP had a compliance date of June 15, 2019. Other
accelerated filers had a compliance date of June 15, 2020. All other filers had a compliance date of June 15, 2021.).
41
44 U.S.C. § 3501 et seq.
42
A “response” is a filing that requires Inline XBRL tagging; see Inline XBRL Filing of Tagged Data Adopting
Release, supra note 16, 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.
43
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://www.reginfo.gov/public/do/DownloadDocument?objectID=122014901
44
See Request for Comment on Proposed Collection; Comment Request; Extension: Interactive Data, OMB Control
No. 3235-0645, [90 FR 13918 (Mar. 27, 2025)].
45
See Letter from XBRL U.S. (May 27, 2025), available at
https://www.reginfo.gov/public/do/DownloadDocument?objectID=158312500 (responding to a Request for
Comment on Proposed Collection; Comment Request; Extension: Interactive Data, OMB Control No. 3235-0645,
[90 FR 13918 (Mar. 27, 2025)].
46
Id.
47
See OMB, Supporting Statement for the Paperwork Reduction Act Information Collection Submission for
Interactive Data: OMB Control Number 3235–0645, (Sep. 15, 2025), available at
https://www.reginfo.gov/public/do/DownloadDocument?objectID=159008102.
34

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See Electronic Submission Proposing Release, supra note 39, 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.
49
See Electronic Submission Proposing Release, supra note 39, at 23986.
50
See In re Grupo Aval Acciones y Valores S.A. and Corporación Financiera Colombiana S.A., Release No. 3498103 (Aug. 10, 2023) (settled action).
51
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).
52
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.
53
See 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-xbrldisclosures.
54
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”), available at https://www.sec.gov/investment/accounting-and-disclosure-information/performance/adi2019-09-performance-and-fee-issues. See also Division of Investment Management, Accounting and Disclosure
Information 2024-14, Tailored Shareholder Report Common Issues, SEC. & EXCH. COMM’N (Nov. 14, 2024)
available at https://www.sec.gov/about/divisions-offices/division-investment-management/accounting-disclosureinformation/adi-2024-14-tailored-shareholder-report-common-issues.
55
The disclosure review program refers to the staff’s review of fund registration statements, proxy materials,
shareholder reports and other disclosures.
56
See Investment Management, Accounting and Disclosure Information 2019-09, supra note 54.
57
See Filing Fee Disclosure and Payment Methods Modernization Adopting Release, supra note 18, at 70166.
58
See FDTA Section 5825.
59
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).
60
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).
61
See Berkman, XBRL Benefits, supra note 30.
62
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).
63
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).
64
See, How Third Party Data Providers Use Structured Data and Why, XBRL US, (March 2016), available at
https://xbrl.us/ events/analyst-webinar-160323.
65
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).
66
See Investment Management, Accounting and Disclosure Information 2019-09, supra note 54.
67
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”).
68
See XBRL Detailed Tagging of Footnotes (and related citations), supra note 25.
48

A - 14

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).
70
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.
71
For example, the Commission’s quarterly XBRL datasets for mutual fund prospectus risk/return summaries
garnered over 45,435 page views from over 18,778 unique visitors from February 2024 to September 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-data-sets.
72
See, e.g., Farr, Marcelo et al, supra note 27.
73
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-filingsshow-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).
74
Based on Splunk results for Form 13F data set downloads between August 1, 2022, and Feb. 28, 2025, accessed
on Sept. 29, 2025.
75
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-datastrategy-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.
76
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 (OGDA), 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 Id., 132 Stat. 5534.
77
Filers are not yet required to provide some of the disclosures and structured data tags described in this Appendix.
78
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.
79
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.
80
A reference copy of Form S-1 is available at https://www.sec.gov/files/forms-1.pdf.
81
A reference copy of Form S-3 is available at https://www.sec.gov/files/forms-3.pdf.
82
A reference copy of Form S-4 is available at https://www.sec.gov/files/forms-4.pdf.
83
A reference copy of Form S-8 is available at https://www.sec.gov/files/forms-8.pdf.
84
A reference copy of Form S-11 is available at https://www.sec.gov/files/forms-11.pdf.
85
A reference copy of Form F-1 is available at https://www.sec.gov/files/formf-1.pdf.
86
A reference copy of Form F-3 is available at https://www.sec.gov/files/formf-3.pdf.
87
A reference copy of Form F-4 is available at https://www.sec.gov/files/formf-4.pdf.
88
A reference copy of Form F-10 is available at https://www.sec.gov/files/formf-10.pdf.
89
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.
90
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 specified in 17 CFR 229.1125.
69

A - 15

The required asset-level information includes: data 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 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
about the loss mitigation efforts by the servicer to collect amounts past due and the losses that may be passed on to
the investors.
91
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/submit-filings/technical-specifications .
92
A reference copy of Form 10-K is available at https://www.sec.gov/about/forms/form10-k.pdf.
93
A reference copy of Form 10-Q is available at https://www.sec.gov/about/forms/form10-q.pdf.
94
A reference copy of Form 11-K is available at https://www.sec.gov/files/form11-k.pdf.
95
A reference copy of Form 20-F is available at https://www.sec.gov/files/form20-f.pdf.
96
A reference copy of Form 40-F is available at https://www.sec.gov/files/form40-f.pdf.
97
A reference copy of Form ABS-EE is available at https://www.sec.gov/files/formabs-ee.pdf.
98
A reference copy of Form 8-K is available at https://www.sec.gov/about/forms/form8-k.pdf.
99
A reference copy of Form 6-K is available at https://www.sec.gov/about/forms/form6-k.pdf.
100
A reference copy of Form SD is available at https://www.sec.gov/about/forms/formsd.pdf.
101
A reference copy of Form 10-D is available at https://www.sec.gov/files/form10d.pdf.
102
A reference copy of Schedule 13D is available at https://www.ecfr.gov/current/title-17/chapter-II/part240/subpart-A/subject-group-ECFR7ce825ff9acf140/section-240.13d-101; A reference copy of Schedule 13G is
available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-groupECFR7ce825ff9acf140/section-240.13d-102.
103
A reference copy of Schedule 13E-3 is available at https://www.ecfr.gov/current/title-17/chapter-II/part240/subpart-A/subject-group-ECFR7ce825ff9acf140/section-240.13e-100; A reference copy of Schedule 13E-4F is
available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-groupECFR7ce825ff9acf140/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/section240.13e-1.
104
See Cross-Border Application of Certain Security-Based Swap Requirements, Release No. 34-87780 (Dec. 18,
2019) (adopting release) [85 FR 6270, 6348 (Feb. 4, 2020)] & Regulation SBR (Reporting and Dissemination of
Security-Based Swap Information and Security-Based Swap Data Repository Rules; Extension, Release No. 34102886 [90 FR 17225 (Apr. 24, 2025)].
105
A reference copy of Schedule 14A is available at https://www.ecfr.gov/current/title-17/chapter-II/part240/subpart-A/subject-group-ECFR8c9733e13b955d6/section-240.14a-101; A reference copy of Schedule 14C is
available at https://www.ecfr.gov/current/title-17/chapter-II/part-240/subpart-A/subject-groupECFR39f2044c974eb3d/section-240.14c-101.
106
A reference copy of Schedule TO is available at https://www.ecfr.gov/current/title-17/chapter-II/part240/subpart-A/subject-group-ECFR7c5428565389260/section-240.14d-100
107
A reference copy of Schedule 14D-1F is available at https://www.ecfr.gov/current/title-17/chapter-II/part240/subpart-A/subject-group-ECFR7c5428565389260/section-240.14d-102
108
A reference copy of Form N-1A is available at https://www.sec.gov/files/form-n-1a.pdf.
109
A reference copy of Form N-2 is available at https://www.sec.gov/files/formn-2.pdf.
110
A reference copy of Form N-3 is available at https://www.sec.gov/files/formn-3.pdf.
111
A reference copy of Form N-4 is available at https://www.sec.gov/files/formn-4.pdf.
112
A reference copy of Form N-6 is available at https://www.sec.gov/files/formn-6.pdf.
113
A reference copy of Form N-14 is available at https://www.sec.gov/files/formn-14.pdf.
114
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.
115
A reference copy of Form N-CSR is available at https://www.sec.gov/files/formn-csr.pdf.
116
A reference copy of Form N-CEN is available at https://www.sec.gov/files/formn-cen.pdf.
117
See supra note 92.
118
See supra note 93.

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See supra note 98.
A reference copy of Form 13F is available at https://www.sec.gov/pdf/form13f.pdf.
121
A reference copy of Form SHO is available at https://www.federalregister.gov/documents/2023/11/01/202323050/short-position-and-short-activity-reporting-by-institutional-investment-managers#h-194.
122
The Commission issued an order granting a temporary exemption from compliance with Rule 13f-2 and Form
SHO until January 2, 2028. See Exemptive Relief Order, supra note 18.
123
See supra note 105.
124
A reference copy of Form N-PX is available at https://www.sec.gov/files/formnpx.pdf.
119
120

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U.S. Securities and
Exchange Commission
100 F Street NE
Washington, DC 20549
SEC.gov

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3A322650caa47e44ea. Public record. Not legal advice.