SEC Confirms IFRS Filers Will Not be Required to Provide Interactive Data Until SEC Specifies Taxonomy

April 12, 2011

The U.S. SEC has issued a no-action letter confirming that non-U.S. issuers that file financial statements in IFRS as issued by the IASB will not be required to provide financial statements in interactive data format (often referred to as “XBRL”) until the SEC provides certain information needed for this purpose.

Under the original XBRL implementation schedule, non-U.S. issuers that file financial statements in IFRS as issued by the IASB would be required to provide XBRL financial statements for fiscal periods ending on or after June 15, 2011 (i.e., the 2011 Form 20-F for calendar year-end companies).   In order to prepare XBRL statements, issuers require a taxonomy, which is an electronic dictionary of business reporting elements used to report business data in XBRL.  The SEC has not yet specified the XBRL taxonomy for IFRS financial statements and has not provided any guidance as to when it will be specified, making it currently unfeasible to provide IFRS financial statements in XBRL.

The SEC’s no-action response does not address when it will specify the taxonomy or whether it will provide IFRS filers with an extension of the original deadline to process and implement the IFRS taxonomy once it is specified. However, we are hopeful that the staff will provide sufficient time for non-U.S. filers to comply after the taxonomy is specified.

Non-U.S. issuers that file financial statements in accordance with their home country GAAP other than IFRS as issued by the IASB are not subject to the XBRL requirement. The XBRL requirement for non-U.S. issuers that file U.S. GAAP financial statements was phased in over a two-year period with the last group of U.S. GAAP filers becoming subject to the XBRL requirement in their first fiscal year ending on or after June 15, 2010.

See the Davis Polk Newsflash, SEC Issues Rules Outlining Mandatory XBRL Requirement, for further discussion of the XBRL requirement as it relates to non-U.S. issuers.



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