Question:  How should registrants subject to Inline XBRL requirements identify the Interactive Data Files in the exhibit index of an applicable filing?

Answer:  Registrants subject to Inline XBRL requirements should identify any Interactive Data File required under Rule 405 of Regulation S-T as exhibit 101 in the exhibit index and any Cover Page Interactive Data File required under Rule 406 of Regulation S-T as exhibit 104 in the exhibit index.  Additionally, when an interactive data file is submitted using Inline XBRL, Instruction 1 to paragraphs (b)(101)(i) and (ii) of Regulation S-K Item 601 requires that the exhibit index include the word "Inline" within the title description for any such exhibit.

As described in Volume II, Chapter 6.3.2 of the EDGAR Filer Manual, registrants should satisfy the requirement to submit a Cover Page Interactive Data File using an Inline XBRL Document Set with EX-101.* attachments other than EX-101.INS.  Accordingly, in the case of a Cover Page Interactive Data File identified as exhibit 104 in the exhibit index, the exhibit index should cross-reference to the Interactive Data Files submitted under EX-101.  For submissions made with Form 8-K, see Question 101.04. [Aug. 20, 2019]

Question:  If an issuer voluntarily submits Interactive Data Files in Inline XBRL format prior to its applicable phase-in date, must the issuer comply with the cover page data tagging requirements with those submissions?

Answer:  No.  Cover page data tagging requirements apply to issuers that are "required to submit Interactive Data Files in Inline XBRL format."  See Rule 406 of Regulation S-T.  Issuers that voluntarily submit Interactive Data Files in Inline XBRL format prior to their applicable phase-in date are not "required to submit Interactive Data Files in Inline XBRL format" and, therefore, such issuers are not subject to the cover page data tagging requirements. [Aug. 20, 2019]

Question: Registrants subject to Inline XBRL requirements are required to tag all of the information on the cover page of Form 10-K, Form 10-Q, Form 8-K, Form 20-F, and Form 40-F using Inline XBRL.  Are all Forms 8-K subject to this requirement?

Answer: Yes. All Forms 8‑K, not only those that contain financial statements for which XBRL data is required, are subject to this requirement. [Aug. 20, 2019]

Question: Item 601(b)(104) of Regulation S-K requires a Cover Page Interactive Data File to be filed as an exhibit to the respective forms listed in the exhibit table.  Are registrants subject to Inline XBRL requirements required to identify the Cover Page Interactive Data File as exhibit 104 under Item 9.01 of Form 8-K?

Answer: As discussed in Question 101.01 above, Cover Page Interactive Data Files required under Rule 406 of Regulation S-T should be identified as exhibit 104 in the exhibit index of an applicable filing.  If, however, the exhibit index of a Form 8-K would include only a Cover Page Interactive Data File as exhibit 104, and would not include any other exhibit, the staff will not object if the registrant does not add an exhibit index to the Form 8-K solely for the purpose of identifying the Cover Page Interactive Data File as an exhibit under Item 9.01 of Form 8-K. [Aug. 20, 2019]

Question: Registrants subject to Inline XBRL requirements are required to tag all of the information on the cover page of Form 10-K, Form 10-Q, Form 8-K, Form 20-F, and Form 40-F using Inline XBRL, including the company name.  How should registrants comply with the cover page tagging requirements where the company name, as it appears on the cover page of the applicable form, differs from the company name, as conformed to EDGAR naming conventions in the company's EDGAR file?

Answer: Where a company's name, as it appears on the cover page of a form, differs from its conformed name in EDGAR, it is permissible for the Inline XBRL tagged company name shown on the cover page to vary from the EDGAR conformed name in various ways.  Most such variations will not prevent the filing from being accepted and disseminated.  In rarer instances, a variation may result in a notice of suspension.  In those instances, the filer should contact EDGAR Filer Technical Support.  Registrants whose company name does not match their EDGAR conformed company name may wish to consider updating their conformed company name in EDGAR.  See Volume I, Chapter 5.4 of the EDGAR Filer Manual for instructions on how to edit your company information. [Aug. 20, 2019]

Question:  If an issuer elects to voluntarily submit Interactive Data Files in Inline XBRL format prior to its applicable phase-in date, can the issuer cease such voluntary submissions prior to its applicable phase-in date?

Answer:  Yes.  Issuers can cease such voluntary submissions until they are required to submit Interactive Data Files in Inline XBRL format pursuant to the phase-in schedule. [Aug. 20, 2019]

Question: Form 10-Q filers are required to comply with Inline XBRL beginning with their first Form 10-Q for a fiscal period ending on or after the applicable compliance date, as opposed to the first filing for a fiscal period ending on or after that date.  Where a registrant files a Form 8-K earlier on the same day as its first Form 10-Q for a fiscal period ending on or after the applicable compliance date, must the Form 8-K comply with Inline XBRL cover page tagging requirements?

Answer: No.  Because the Form 8-K was filed before the first Form 10-Q was due for a fiscal period ending on or after the applicable compliance date, the Form 8-K need not comply with Inline XBRL cover page tagging requirements. [Aug. 20, 2019]

Question: What is the applicable phase-in period for compliance with the Inline XBRL requirements for foreign private issuers?

Answer: Foreign private issuers will be required to comply with the Inline XBRL requirements based on their filer status and basis of accounting.  For a foreign private issuer that prepares its financial statements in accordance with U.S. GAAP, the phase-in of the Inline XBRL requirements is determined based on its filer status.  Large accelerated filers, including foreign private issuers, that prepare their financial statements in accordance with U.S. GAAP will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2019.  Accelerated filers, including foreign private issuers, that prepare their financial statements in accordance with U.S. GAAP will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2020.  All other filers, including foreign private issuers that prepare their financial statements in accordance with IFRS, will be required to comply with Inline XBRL for financial statements for fiscal periods ending on or after June 15, 2021. [Aug. 20, 2019]

Question: Form 10-Q filers are required to comply with Inline XBRL beginning with their first Form 10-Q for a fiscal period ending on or after the applicable compliance date.  How does this provision apply to Form 20-F and 40-F filers?

Answer: Form 20-F and 40-F filers do not have quarterly report filing obligations.  Therefore, these filers will be required to comply with Inline XBRL beginning with the first filing on a form for which Inline XBRL is required for a fiscal period ending on or after the applicable compliance date, as determined in accordance with Rule 405(f)(1)(i) of Regulation S-T. [Aug. 20, 2019]

Question: Item 601(a)(2) of Regulation S-K provides that an exhibit index does not need to include a hyperlink to an exhibit that is filed in XBRL. Does this exception apply to exhibits that are filed in Inline XBRL?

Answer: No. Item 601(a)(2)’s reference to exhibits filed in XBRL refers to exhibits that are filed in unconverted code, which is only machine-readable. See Release No. 33-10322 (Mar. 1, 2017). An exhibit that is tagged in Inline XBRL is not filed in unconverted code. [Nov. 20, 2023]