Temporary XBRL Relief for IFRS Financial Statements of Foreign Private Issuers

Client Advisory

June 6, 2011

Under SEC Regulations, foreign private issuers that prepare their financial statements in accordance IFRS should begin to include XBRL Interactive Data Files in their annual reports on Form 20-F or Form 40-F for fiscal periods ending on or after June 15, 2011. When preparing Interactive Data Files, registrants must “tag” the data in the financial statements with a label of what the associated data represents. The Regulations require that the tags themselves come from a specific “taxonomy” approved by the SEC, as specified on its website. However, the SEC has not yet specified an IFRS taxonomy on its website, and accordingly it is currently impossible for foreign private issuers reporting in IFRS to comply with XBRL requirements. 

In a “no-action” letter dated April 8, 2011, the Staff of the SEC advised that foreign private issuers that prepare their financial statements in accordance with IFRS need not submit to the SEC (and post on their corporate websites), Interactive Data Files until the SEC specifies on its website an IFRS taxonomy for use by such foreign private issuers in preparing their Interactive Data Files. The Staff has not provided guidance on when it expects to specify an IFRS taxonomy on its website. Until then, foreign private issuers following IFRS will not need to prepare and file Interactive Data Files.  

Questions regarding this advisory should be addressed to Steven J. Glusband (212-238-8605,, Guy P. Lander (212-238-8619, and Peter Flägel (212-238-8649,

Carter Ledyard & Milburn LLP uses Client Advisories to inform clients and other interested parties of noteworthy issues, decisions and legislation which may affect them or their businesses. A Client Advisory does not constitute legal advice or an opinion. This document was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. © 2020 Carter Ledyard & Milburn LLP.
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