Talk:European Filing Rules

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Contents 1 Comments 1.1 Comment-01 1.2 Comment-02 1.3 Comment-03 1.4 Comment-04 1.5 Comment-05 1.6 Comment-06 1.7 Comment-07 1.8 Comment-08 1.9 Comment-09 1.10 Comment-10 1.11 Comment-11 1.12 Comment-12 1.13 Comment-13 1.14 Comment-14 1.15 Comment-15 1.16 Comment-16 1.17 Comment-17 1.18 Comment-18 1.19 Comment-19 1.20 Comment-20 1.21 Comment-21 1.22 Comment-22 1.23 Comment-23 1.24 Comment-24 1.25 Comment-25 1.26 Comment-26 1.27 Suggestions

Comments

Comment-01

RH: Can we use only 'instance' as the term for a report, XBRL document, filing document etc.?
KH: I agree. I'm going to change it to instance document.
The discussion is closed, the following action has been taken: Changed by KH

Comment-02

RH: This 'rule' states that there is no rule for instance naming. I suggest to alter the rule to: Any taxonomy author MUST prescribe instance file naming conventions. We can make a couple of suggestions on how other projects have created such rules.
KH: There need not be any file name conventions. So I would suggest to use CAN instead of MUST.
RH: This touches on a more basic point; if we do not set rules on anything, should we mention it at all? Are examples than still appropriate? IMO it is required to have it explicit (I always favor explicit to implicit). For rules MUST and MAY are the most appropriate terms. So this one should revert to a MAY rule. TD: Is this aspect of file naming not something that should be in the Architecture Document (Roland saying that the author of a taxonomy must provide for a file naming convention. So that instance documents generated on the basis of such a schema will have per definition a file name)
RH: CEN meeting 2012-10-29: Rules should be made explicit, also when the rule is 'to have no rule'.
The discussion is closed, the following action has been taken: Rules have been explicit by RH

Comment-03

Rule: 2.22 xbrli:xbrl/xbrli:unit declarations SHOULD adhere to XBRL international unit registry content
KH: Rule should be reformulated.
RH: Suggestion has been made, SHOULD NOT rule on creating units that are in utr.

Comment-04

KH: Should it be allowed ot define units?
RH: CEN meeting 2012-10-29: No scale on numerics is allowed. Rather: NSA's should conform to the utr of XII and put any new units in there.
The discussion is closed, the following action has been taken: RH: rule is no scale allowed.

Comment-05

KH: Rule to be added that no extension of reporting entities on European taxonomies are allowed.
RH: CEN meeting 2012-10-29, not extensions by reporters allowed
The discussion is closed, the following action has been taken: Rule 1.8 no extensions allowed created.

Comment-06

KH: The schemaRef should contain the full schemalocation because the version is not contained in the namespace.
The discussion is closed, the following action has been taken: RH: comment processed in rule.

Comment-07

TD: In general: the word to be defined should not appear in the definition
The discussion is closed, the following action has been taken: RH: comment processed in rule.

Comment-08

TD: I would add a definition for the "filer" and include there the fact that the filer should own the name of the authority. I would also add a defintion for "to file", in case this is a technical term here.
The discussion is closed, the following action has been taken: RH: comment processed in entry, to file is the general process of filing anything with an authority.

Comment-09

TD: For "entity" I found this deinfition (http://www.aasb.gov.au/admin/file/content102/c3/SAC1_8-90_2001V.pdf)

"entity" means any legal, administrative, or fiduciary arrangement, organisational structure or other party (including a person) having the capacity to deploy scarce resources in order to achieve objectives; and

again, we should avoid to have the (parts of) term we define, inside the definition.

KH: The definition has be reformulated.

The discussion is closed, the following action has been taken: RH: comment processed.

Comment-10

TD: The additional sentence "A listing of all taxonomy files respective modules recognised in the filing system should be provided on a web location. " is not necessary
RH: What this text is showing is that DTS authors MUST provide a list of URL's to entrypoints on the internet. Maybe the rule is self explaining?

Comment-11

TD: I think that the concept "Entry Point" should be defined before
The discussion is closed, the following action has been taken: Included by RH

Comment-12

KH: A rule should be added that always the complete package (file) should be sent, not only an update.
DDB: I think this makes it less flexible, partial submission can be very efficient.
RH: CEN meeting 2012-10-29: Allowing partial data brings a lot of technical complexity because validation and presentation of the instance is no longer possible. OTOH the internal processes at reporters may be designed to create only parts of certain reports. Forcing only complete submissions would force internal restructuring with these reporters. Golden rule is that every XBRL instance is XBRL standards valid.
Interesting case: if, because of size restrictions, the instance is being split across multiple instances, a 'total' assertion may not be functioning correctly. In this case the 'golden rule' is being broken because of technical reasons. The DTS owner allowing partial submissions need to guarantee ex-post that all original rules of the DTS are processable.
Sending partial submissions by reporters becomes a choice of the NSA. The header of the message will cater for an element that states if the instance is a 'full' replacement or a 'incremental' submission.
All risks involved with partial submissions are upon the NSA allowing it. The recommendation will be to sent complete packages. (the term Package is not defined!)

Comment-13

RH: Where is the 'default' language declared? Better not have any implicit meaning since every country will allow it's own 'default' which would result in a mess at central European regulators.
Propose to change the rule into: Non numeric facts MUST be clarified to what language is being used.
The purpose of the xml:lang is to enable the receiver to match presentation templates with the facts in the same language as the (non-numeric) facts have been put. ENABLE, not FORCES.

The discussion is closed, the proposed solutions has been adopted: Included by KH

Comment-14

RH/KH: Because of size restrictions, the instance could be split across multiple instances, a 'total' assertion based on XBRL Formula may not be functioning correctly. In this case the instance document wouldn't be valid. The receiver of the data allowing the splitting of submissions need to guarantee ex-post that all original rules of the DTS including Formulas are processable.

Comment-15

TD: The Abbreviation "CWA" occurs here for the first time and has not been introduced. Maybe the whole chapter should start with a sentence like "The present CWA (Full Wording) on European Filing Rules specifies...."

The discussion is closed, CWA has been put in, in full: Included by RH

Comment-16

TD: I think that examples should have a different layout. It might be useful to add after the definition a line stating: Example: The xs:element xyz can be viewed as a ...". I would like to suggest this editorial strategy for all examples (it is used in ISO documents), but still have to check the layout format in CEN.

The discussion is closed, the proposal is included, in full: Included by RH

Comment-17

KH: Should there be a rule to prohibit XML fragments in scenario and segment?

Comment-18

TD: Maybe write "An XBRL taxonomy" instead of "A taxonomy". Just to stress again the link to XBRL, and having XBRL as the decision point.

The discussion is closed, the proposed solutions has been adopted: Included by RH

Comment-19

TD: Maybe write "the applicable taxonomy" instead of "the taxonomy". This refers then to the definition. Maybe mark the string in bold face to mark that it refers to a definition.

The discussion is closed, the proposed solutions has been adopted: Included by RH

Comment-20

TD: Second part of the definition is difficult to read!

1) I think it is not enough to write that an instance document is an XBRL file (so is the taxonomy also). I guess it would enough to add that an instance contains concrete values for the elements of the applicable XBRL taxonomy

The discussion is closed, the proposed solutions has been adopted: Included by RH

2) In any case: the second part of the text is in my opinion rather a note, and not part of the definition. In ISO documents, one can add a NOTE to a definition (similar to the EXAMPLE case). If you agree I would go next very soon to the whole document and re-edit the definition, separating the NOTE parts from the definition part.

Comment-21

TD: Not sure about this comment now (since linkbase and formula should be known by the reader), but since the terms link base and formula are occuring quite often, mybe add a short definition for both terms.

The discussion is closed, the proposed solutions has been adopted: Included by RH

Comment-22

TD: "Data points" has not been introduced so far (it seems to me that this points to the Data Point Model, but maybe I am wrong here). Either leave the word "point" out, or add a definition about "data point".

The discussion is closed, the proposed solutions has been adopted: Included by RH

Comment-23

TD: Maybe for all subsections here, add a short intro line, explaining what is the special case. What is a "context", a "footnote" etc. Or add "unit", "fact", "footnote" and "context" in the definitions.
RH: These are XBRL syntax elements that contain aspects of the facts reported. The definition can be found in the XBRL 2.1 specification. I would be careful to copy all kinds of definitions from other specs.

Comment-24

CSSF/EB: We have had no need up to now for managing language versions of text contents in the past in spite of being a multi-language country; the content of the facts speaks for itself whatever language is used. If still you add such a facility, I hope for a clearer choice in the next version of the document because I do at present not know how to adapt our system to take this into account (I don't want to add several ways but only a single one to deal with languages of text fields).

RH: For human interpretation you are right that looking at the text you are able to tell what language it is (well, most times anyway). But computers are not that smart. So if you have a system that is presenting the instance in a template on the screen you may want to match the template language to the language retrieved from the instance. For your purpose I would guess that you would make a filing rule that states that only one language is allowed in an instance and that language can only be xx, yy, zz and is MUST be stated on the instance root element only. But we leave other regulators free in how they would like to deal with multi-language situations. Essentially the only rule is that ‘a’ language attribute must be in the instance if texts are in there.

CSSF/EB: Regarding 2.30, I am not too happy with the explanations because you there give no SHOULD or MUST rule that could be reinforced by an authority in case of need, but an alternative ("place a language attribute at one of several possible places, wherever the local authority of the local country feels like requiring it"). This creates again unnecessary incompatibilities which filing rules should try to eliminate among european instances. I remain of the opinion that if multi-language is felt to be a real european need in instances, then ONE mechanism with ONE way / place to put the attribute SHOULD be defined.

RH: In general there are two options in allowing multiple languages:

1. one language per instance (ergo: multiple instances, one per language, the Belgian way)
2. one instance with multiple languages (ergo: language per text based element, the Danish way)

Pro and cons
Pro 1: Formula validation implicitFiltering works, processing of a complete instance, rendering based on language aspect Con 1: Each instance needs to carry all facts, also the dates and numerics. Extra validation is required to asses if all instances carry the same non string based values. Some validations may need to span all instances. Pro 2: All numerics and dates are communicated once, the texts have multiple languages in the same instance rendering based on XML file Con 2: Need to validate if all texts have all the used languages, formula don’t consider xml:lang as an predefined aspect so implicitFiltering mechanism may suffer (there is no designed filter, you would need a generalfilter or customattributefilter).

I would be hesitant to state one of these two mechanisms is the ‘better’ way. Maybe we can point to a ‘preferred’ way in Frankfurt.

CSSF/EB: as we are not strongly concerned (one language is enough, we'll probably impose the choice of any of the official languages in LU for use in all fields and instances of a report), we'll have a single instance per dataset resp. one (the same) language attribute for all text based fields. So we can use any of these 2 mechanisms without heavy changes to our system (We'll probably ignore the language feature anyway in internal procedures as we have neither means nor need to store that information, string contents being self-explaining to human readers). Let's hope Frankfurt gives the necessary input to choose a light solution in the spirit of the KISS principle without creating too many collateral disadvantages. I also hope to have in the end clear indications on how regulators that allow NO multiple languages should work to stay compatible with their multi-language colleagues.

May be we should add over here to our traditional:

1. single entity per instance
2. single reporting period per instance
3. single currency per instance
4. single consolidation status per instance (consolidated, sub-consolidated, solo)
5. single audit status per instance (audited, not audited figures)

a 6th one

1. single language for text fields per instance

Comment-25

IB: rule 2.23 is

2.23   xbrli:segment MUST NOT be used.
As xbrli:scenario and xbrli:segment elements are treated as mutually exclusive, using both of them is prohibited.

It is suggested explaining the practical reasons and rephrase as RECOMMENDATION. Some Supervisors seems to use xbrli:segment when defining additional dimensions to the primary taxonomy, as fast solution instead extending dimensions.

2.23   xbrli:scenario is REQUIRED.
xbrli:scenario and xbrli:segment elements are both equivalent containers (especially for dimensional information in the instance document). The European best practice is using only xbrli:scenario, hence simplifying the creation and consumption of instances by not using xbrli:segment. Using simultaneously xbrli:scenario and xbrli:segment is unnecessarily more complex.

Comment-26

RH: The argument for removal of the @xml:base as a recommendation (because the software is more mature now) seems odd. It's not only about rendering and validation software that may be more mature nowadays, but is also about mapping software which many reporters and receivers are creating for themselves which is not mature at all. Since the original argument (no semantic reason for the attribute) is still valid I see no reason to drop the rule (as a recommendation).

Suggestions

RH: As per telecall 20121108 a couple of rules MAY be merged. These are:
There MUST NOT be more than one link:schemaRef in an instance
Reporting entities SHOULD use only one of entrypoint schemas as specified in the applicable taxonomy.
link:schemaRef MUST contain the full URL as published on the internet
Reporting entities SHOULD use one of the taxonomies as specified in the filing system as the applicable taxonomy.

Suggestion:
A single entrypoint using link:schemaRef addressing the official applicable taxonomy through an URL MUST be used.