SEC Reporting and the Impact of XBRL: 2011 Survey - Financial ...

SEC Reporting and the 

Impact of XBRL: 

2011 Survey 

WILLIAM M. SINNETT 

SENIOR DIRECTOR, RESEARCH 

FINANCIAL EXECUTIVES RESEARCH FOUNDATION 

The Source for Financial Solutions 

1250 Headquarters Plaza 

West Tower, 7th Floor 

Morristown, New Jersey 07960 

www.ferf.org 

The Research Affiliate of Financial Executives International

SEC REPORTING AND THE IMPACT OF XBRL: 

2011 SURVEY 

TABLE OF CONTENTS 

Executive Summary 1 

Purpose and Design of Survey 2 

Profile— Survey Respondents 4 

Size of SEC Reporting Team and Core Responsibilities 7 

SEC Reporting Filing Data 10 

SEC Reporting Practices 13 

XBRL Creation Approach 18 

Number of Hours to Create XBRL Reports 22 

XBRL Experiences 23 

Impact of XBRL on SEC Filing Date 27 

XBRL Providers 28 

“Pencils Down” Experience 29 

XBRL Provider Satisfaction 30 

Acknowledgements 32 

PAGE

Executive Summary 

For publicly-held companies that file reports with the U.S. Securities and Exchange Commission 

(SEC), the financial statements must be tagged using eXtensible Business Reporting Language 

(XBRL). XBRL tagging is now a key part of the financial statement production process. In many companies, 

this production process entails a number of different players using a variety of documents 

and spreadsheets, providing the opportunity for error, inconsistency and inflated costs. 

The SEC now requires tagging of quarterly and annual reports on Forms 10-Q and 10-K with XBRL. 

In their first year of compliance, companies must detail tag their face financial statements and 

block tag their footnotes. Compliance in the second and following years is more challenging because 

detail tagging of face financial statements and footnotes is required. 

To find out how companies are complying with these XBRL tagging requirements, FERF surveyed 

members of FEI and other financial statement preparers. Executives from 300 unique companies 

responded to the survey. 

Key Findings: 

• The most significant challenges mentioned in complying with the XBRL mandate are getting 

educated on XBRL and addressing the review process. 

• XBRL had a limited impact on respondents SEC filing dates: 

• 72% of large accelerated filers (Tier 1 and Tier 2) reported one day or less delay due to XBRL; and 

• Over 90% of Tier 3 filers reported one day or less delay due to XBRL. 

• The majority of respondents found that XBRL was either somewhat or significantly easier the second 

time around. 

• Tier 1 and Tier 2 XBRL filers predicted a higher likelihood than Tier 3 XBRL filers of changing 

their XBRL process, with the vast majority of companies anticipating a change opting for an in-house 

software solution. 

• In-house and built-in solutions continue to increase their significant market share. 

• Registrants using built-in solutions (software solutions used by in-house reporting teams in which the 

creation of the EDGAR document and XBRL instant report are fully integrated) are significantly more 

satisfied than those using other approaches. 

SEC REPORTING AND THE IMPACT OF XBRL: 2011 SURVEY 

EXECUTIVE SUMMARY -PAGE 1

Purpose and Design of Survey 

The SEC Reporting and the Impact of XBRL: 2011 Survey addressed two aspects of financial 

reporting. The first set of survey questions requested operational details, including: 

• The size and composition of the financial reporting team; and 

• The number of days necessary to complete and file financial reports with the SEC. 

The second section of the survey focused on respondents’ experience in meeting XBRL requirements, 

including: 

• The organization’s level of understanding and involvement in the XBRL tagging process; 

• The approach the organization took to implement an XBRL solution; 

• The type and amount of resources that the organization used and the amount of time that the 

organization invested in creating, reviewing and submitting the XBRL reports to the SEC; 

• The actual and potential impact of the XBRL requirement on the organization’s ability to meet its 

filing deadlines, including any “pencils down” requirements and delays in filing dates; 

• Areas of greatest concern about XBRL; 

• The name of the company’s XBRL provider; 

• The company’s level of satisfaction with that provider; and 

• Planned changes to the XBRL process. 

The survey was launched on July 19, 2011, via e-mail to over 5,000 FEI members and other 

financial statement preparers. The survey was taken down on October 4, 2011. 

We received a total of 321 responses to the survey, representing responses from 300 unique 

companies. 

The first set of questions requested specific information, including the: 

• Name and position of the person completing the survey; 

• Company name; 

• Ticker symbol; and 

• E-mail address of reporting person. 


PURPOSE AND DESIGN OF SURVEY (Continued) -PAGE 2

Personal and company information of all respondents will be protected. As stated in the survey, 

FERF: 

• Was collecting company specific information solely for the purpose of improving survey quality; and 

• Would not publish or otherwise disclose identifiable information without the express written 

permission of the respondent. 

FERF was thus able to: 

• Control for multiple responses from the same company; 

• Determine missing public information about the reporting company; 

• Request missing non-public information about the reporting company; and 

• Request clarification or corrected information from the reporting company. 


PURPOSE AND DESIGN OF SURVEY (Continued) -PAGE 3

Profile- Survey Respondents 

Throughout this document, we summarize and present the survey responses by both the SEC filing 

status (large accelerated filer, accelerated filer, non–accelerated filer and smaller reporting company) 

and the XBRL filing status (Tier 1, Tier 2 and Tier 3) of the respondents. 

SEC Filing Status: 

• Large accelerated filer - public float of $700 million or more 

• Accelerated filer - public float between $75 million and $700 million 

• Non-accelerated filer - public float of less than $75 million 

• Smaller reporting company - a sub-set of non-accelerated filers 

Levels of XBRL Reporting: 

• Level 1 - text block tags applied to the notes to the financial statements (this is accompanied with 

detailed tagging of face statements) 

• Level 2 - text block tags applied to each significant accounting policy 

• Level 3 - text block tags applied to each table within the notes to the financial statements 

• Level 4 - detailed tags applied to each amount in each table within the notes to the financial 

statements 

XBRL Filing Status 

• Tier 1 filers have the most experience with XBRL. They include large accelerated filers with over 

$5 billion of public float, and began filing XBRL reports for the quarter ended June 30, 2009. They 

are currently in their second year of providing detailed XBRL reports, and are now in the third 

year of XBRL filings. 

• Tier 2 filers include all of the other large accelerated filers. They are currently in their first year 

of providing detailed XBRL reports and began filing XBRL for the June 2010 quarter. 

• Tier 3 filers include accelerated, non-accelerated and smaller reporting companies— the least 

experienced XBRL filers. Tier 3 filers are currently filing Level 1 XBRL reports and began filing 

XBRL the first time for the June 2011 quarter. 


PROFILE- SURVEY RESPONDENTS (Continued) -PAGE 4

In general, companies that responded to this survey are larger and have more experience with XBRL than 

the population of publicly reporting companies, taken as a whole. For example, 

• Approximately 500 Tier 1 filers represent approximately 5% of all reporting companies, yet repre- 

sent 20% of the respondents of this survey. 

• Approximately 1,700 large accelerated filers represent 19% of reporting companies, yet repre- 

sent 58% of the respondents of this survey. 

Respondents by XBRL and SEC Filing Status 

XBRL Filing Status SEC Filing Status Number of Respondents % of Respondents 

Distribution of all 

2010 10-K Filers 1 

TIER 1 Large Accelerated Filer 59 20% 5% 

TIER 2 Large Accelerated Filer 112 38% 14% 

TIER 3 Accelerated Filer 70 23% 19% 

1 Source: LogixData 

XBRL Filing Status SEC Filing Status 

Non-Accelerated Filer 31 10% 13% 

Smaller Reporting Company 28 9% 49% 

300 100% 100% 

Revenue for the Most Recent Fiscal Year 

More Than 

$10 Billion 

$5 to $10 

Billion 

$1 to $5 

Billion 

Less Than 

$1 Billion 

Number of 

Respondents 

TIER 1 Large Accelerated Filer 46% 25% 27% 2% 59 


TIER 3 Accelerated Filer 1% 6% 26% 67% 70 

Non-Accelerated Filer —% 10% 23% 67% 31 

Smaller Reporting Company —% —% —% 100% 28 

300 




Percent of Revenue from International Operations 

More Than 

50% 

31% to 

50% 

10% to 

30% 

Less Than 

10% 


Respondents 





Non-Accelerated Filer 10% 6% 3% 81% 31 

Smaller Reporting Company 18% 4% 11% 68% 28 

Number of Reportable Business Segments 

Eight or 

More 

Five to 

Seven 

Three or 

Four 

One or 

Two 

292 


Respondents 



TIER 3 Accelerated Filer —% 6% 28% 66% 67 


Smaller Reporting Company —% 4% 21% 75% 28 

Number of Employees (Excluding Temporary or Seasonal Employees) 


More Than 

100,000 

25,000 to 

100,000 

1,000 to 

25,000 

Less Than 

1,000 

294 


Respondents 



TIER 3 Accelerated Filer —% 2% 52% 46% 69 


Smaller Reporting Company —% —% 14% 86% 28 

298 



Size of SEC Reporting Team and Core Responsibilities 

There was a wide range of responses from zero to 16 employees who spend substantially all of their time on 

SEC reporting matters. Companies that reported zero did so intentionally. Those companies stated that their 

financial reporting team handles a range of responsibilities and does not spend substantially all of their time 

on SEC reporting matters. 

How many employees spend all or substantially all of their time on SEC reporting matters? 

XBRL Filing Status SEC Filing Status Mean Median Minimum Maximum 


Respondents 

TIER 1 Large Accelerated Filer 3 3 — 10 58 

TIER 2 Large Accelerated Filer 3 3 1 16 112 

TIER 3 Accelerated Filer 2 2 — 7 70 

Non-Accelerated Filer 2 1 — 7 31 

Smaller Reporting Company 1 1 — 3 28 

The size of SEC reporting teams for large accelerated filers are one or two persons larger, on average, 

than Tier 3 companies. 

If you augment your core SEC reporting team with additional resources at peak times, 

where do you source the additional resources? 

XBRL 

Filing Status 

SEC Filing Status 

Employee(s) 

From Other 

Departments 

Part-time 

Employees 

Consultants Outsourcing Other 

299 


Respondents 

TIER 1 Large Accelerated Filer 81% 3% 16% 6% 13% 31 

TIER 2 Large Accelerated Filer 70% —% 19% 4% 23% 47 

TIER 3 Accelerated Filer 73% —% 21% 6% 15% 57 

Non–Accelerated Filer 84% —% 8% —% 8% 12 

Smaller Reporting Company 78% —% 33% 22% 11% 9 

Most companies utilize employees from other departments within the company at peak times. The 

percentages add up to more than 100% as many companies augment the core SEC reporting team from 

multiple sources. 

156 


SIZE OF SEC REPORTING TEAM AND CORE RESPONSIBILITIES -PAGE 7

What are the core responsibilities of the SEC reporting team? 

TIER 1 TIER 2 TIER 3 

Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 

Reporting 

Company 

Form 10-K 100% 100% 100% 100% 100% 

Form 10-Q 100% 100% 100% 100% 100% 

XBRL 98% 100% 99% 100% 100% 

Earnings Press Release Support/ Form 8-K Support 95% 96% 90% 84% 86% 

Technical Accounting Research 76% 88% 99% 81% 82% 

Proxy Statement (Supporting Role in Partnership with 

Legal or Outside Counsel) 

66% 72% 64% 52% 43% 

Audit Committee and/or Board of Directors Packages 54% 61% 68% 55% 71% 

Acquisition and Disposition Support 51% 57% 38% 42% 29% 

Proxy Statement (Primary Responsibility) 7% 12% 25% 19% 39% 

Other 37% 38% 36% 35% 32% 

Number of Respondents 59 112 69 31 28 299 

Many other areas of responsibility were mentioned (aggregated above with “Other”) but the five most frequently 

mentioned were: 

• Stock-based compensation; 

• SOX / internal controls; 

• Consolidation; 

• Internal management reporting; and 

• Close / accounting. 

Total 


SIZE OF SEC REPORTING TEAM AND CORE RESPONSIBILITIES (Continued) -PAGE 8

Which of the following participate in the review process of the 10-K/10-Q? 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

Chief Financial Officer 97% 98% 99% 94% 96% 

Independent Auditors 98% 96% 94% 100% 96% 

Audit Committee 100% 95% 97% 94% 86% 

Controller/ CAO 97% 97% 96% 94% 79% 

Outside Counsel 73% 76% 89% 74% 79% 

Disclosure Committee 92% 84% 74% 74% 43% 

Tax 86% 81% 69% 58% 32% 

Business Unit Leaders 71% 64% 39% 39% 39% 

Treasury 85% 73% 31% 23% 11% 

Financial Planning & Analysis 51% 49% 33% 35% 21% 

Internal Audit Staff 51% 44% 24% 29% 11% 

Functional Group Leaders 56% 36% 14% 29% 11% 


It is probable that some review processes are taking place outside of the view of the person completing the 

survey or that there were interpretation differences or survey errors as we assume that the CFO, audit committee 

and independent auditors, for example, are reviewing the filings at 100% of the respondent companies. 

Total 


SIZE OF SEC REPORTING TEAM AND CORE RESPONSIBILITIES (Continued) -PAGE 9

SEC Reporting Filing Data 

Large accelerated filers typically require less time to produce and file their annual and quarterly reports 

than accelerated, non-accelerated and smaller reporting company filers. Actual days to file for the most 

recent filing were used in the analysis (instead of the survey data) where available and was sourced from 

LogixData. This was attributed to ranges of responses provided by many companies- actual data was used 

for a more reliable analysis. 


Filing Status 

Number of Days After Year-End to File Form 10-K 

SEC Filing Status Mean Median Minimum Maximum Due Date 


Respondents 

TIER 1 Large Accelerated Filer 53 55 28 60 60 59 


TIER 3 Accelerated Filer 63 65 38 75 75 70 


Filing Status 

Non–Accelerated Filer 71 65 40 90 90 31 

Smaller Reporting Company 75 72 47 90 90 28 

Number of Days After Quarter-End to File Form 10-Q 

SEC Filing Status Mean Median Minimum Maximum Due Date 

300 


Respondents 



TIER 3 Accelerated Filer 35 36 26 40 40 70 

Non–Accelerated Filer 41 42 32 45 45 31 

Smaller Reporting Company 41 42 26 45 45 28 

300 


SEC REPORTING FILING DATA -PAGE 10


Filing Status 

Number of Days After Year-End to Report Earnings Release on Form 8-K 

SEC Filing Status Mean Median Minimum Maximum 


Respondents 



TIER 3 Accelerated Filer 49 48 26 75 67 


Filing Status 

Non–Accelerated Filer 55 58 25 90 26 

Smaller Reporting Company 60 56 25 90 23 

Number of Days After Quarter-End to Report Earnings Release on Form 8-K 

SEC Filing Status Mean Median Minimum Maximum 

286 


Respondents 






286 


SEC REPORTING FILING DATA (Continued) -PAGE 11

0 Days (8-K and 10-K on the 

Same Day) 

Number of Days From Earnings Release on Form 8-K to Filing of 10-K 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

3% 13% 21% 37% 29% 

1-5 Days 9% 22% 16% 13% 19% 

6-10 Days 15% 12% 6% 13% —% 

11-15 Days 14% 10% 19% 4% 5% 

16-20 Days 15% 10% 10% 8% 10% 

21-30 Days 29% 22% 15% 4% 9% 

> 30 Days 15% 11% 13% 21% 28% 


0 Days (8-K and 10-Q on the 

Same Day) 

Number of Days From Earnings Release on Form 8-K to Filing of 10-Q 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

10% 35% 43% 36% 29% 

1-5 Days 39% 27% 22% 44% 29% 

6-10 Days 30% 15% 24% 16% 5% 

11-15 Days 12% 15% 7% 4% 24% 

16-20 Days 7% 5% 3% — % 4% 

> 20 Days 2% 3% 1% —% 9% 


Total 

Total 


SEC REPORTING FILING DATA (Continued) -PAGE 12

SEC Reporting Practices 

What issue(s) do you consider your biggest bottleneck in the reporting function? 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

XBRL 45% 38% 5% —% 4% 

Review process 16% 25% 28% 22% 26% 

Timely collection of data 12% 16% 20% 13% 35% 

Closing the books 8% 10% 23% 26% 17% 

Staffing/Tight time schedules 12% 9% 7% 13% —% 

Late changes 6% 10% 7% 13% 9% 

Auditor review process 4% 7% 3% 9% 17% 

Systems —% 3% 8% 4% 13% 

Tax Entries 4% 2% 5% —% —% 

MD&A 4% 2% 2% —% —% 

Consolidation 4% 2% 5% —% —% 

Other 2% 3% —% —% 4% 


Percentages are based on the number of respondents indicating a particular bottleneck divided by the 

number of respondents in the XBRL and SEC filing group answering this question— column percentages 

may add up to more than 100%. 

The above table was compiled from narrative responses and overlap was noted among the various categories. 

Representative comments are highlighted in the table below. There was a broad range of issues 

mentioned as significant reporting bottlenecks. 

• XBRL was mentioned by 40% of large accelerated filers (aggregate of Tier 1 and Tier 2 companies). 

• Tier 3 XBRL filers were significantly less likely to consider XBRL as a significant bottleneck. 

• The review process is a frequently mentioned reporting bottleneck across SEC filing categories and was 

the most frequently mentioned issue by Tier 3 XBRL filers. 

• Timely collection of data and closing the books were also often mentioned by companies across all SEC 

filing categories --collection of “accurate” data was frequently mentioned. 

Total 


SEC REPORTING PRACTICES -PAGE 13

Significant Bottlenecks to the Reporting Process 

Summary Bottleneck Representative Detailed Comments 


Review process 

Timely collection of data 

Closing the books 

Staffing/ tight time 

schedule 

Late changes 

Auditor review process 

Systems 

XBRL compliance, XBRL tagging, outsourcing of tagging process for XBRL, slow 

turnaround time by printer/XBRL service provider, the XBRL turnaround from outside 

providers 

Distribution and review process, review of documents by the executive team, legal review, 

both external and internal, coordinating reviews and comments 

Having all departments meet internal time-lines, gathering information from many different 

sources (employees and/or systems), timely reporting by business units, obtaining 

timely and accurate information from internal sources 

Finalizing the close process, accounting not getting the books closed quickly and 

accurately, timely and accurate results from accounting, accounting close and late 

adjustments 

Insufficient headcount and a long close cycle, small team responsible for SEC reporting, 

which can cause the bottleneck, capacity constraints - volume of work at quarter 

end, lack of resources, getting financial results and other operational metrics in a 

timely manner 

Post closing adjustments, late changes to underlying financial information, unforeseen 

and/or late accounting issues, processing changes from executives and auditors 

Auditor review, audit timing, late response from external auditors, getting auditor sign-off 

on earnings release, audit team review of documents 

Level of manual effort to complete objectives, manual processes / resource constraints, 

Word/Excel documents updating and then making sure they are ready to EDGARize, lack 

of a good reporting tool, the manual nature of the 10-Q/10-K drafting 

Tax entries Tax provision, outsourced tax provision, finalization of tax entries (provision, deferred) 

MD&A 

Consolidation 

Other 

MD&A explanations from the various operational accounting groups, getting fluctuation 

analyses from the operating groups to explain variances and trends, variance analysis 

after books closed to prepare MD&A 

Consolidation of subsidiaries, consolidation, waiting on subsidiary financial statements, 

consolidation of entities in ERP system 

Version control, preparing committee materials, increasing complexity of new rules and 

regulations, communication, implementation of complex new accounting rules 


SEC REPORTING PRACTICES (Continued) -PAGE 14

Does your company use non-GAAP financial measures in its earnings press release? 

XBRL Filing Status SEC Filing Status Yes No 


Respondents 

TIER 1 Large Accelerated Filer 75% 25% 59 


TIER 3 Accelerated Filer 75% 25% 69 

Non–Accelerated Filer 86% 14% 29 

Smaller Reporting Company 36% 64% 28 

Does your company use non-GAAP financial measures in MD&A? 


296 


Respondents 






Does your company issue guidance? 


298 


Respondents 






296 



Does your company hold an analyst call after earnings release? 

XBRL Filing Status SEC Filing Status Yes No Number of Respondents 






How many hours per quarter do you spend supporting the press release process? 


Filing Status 


Fewer than 

10 hours 

10 to 20 

hours 

21 to 30 

hours 

31 to 40 

hours 

More than 

40 hours 

299 


Respondents 



TIER 3 Accelerated Filer 14% 26% 17% 13% 30% 69 

Non–Accelerated Filer 24% 24% 7% 17% 28% 29 

Smaller Reporting Company 43% 28% 7% 11% 11% 28 

How many working days does it take to close your books for a typical quarter-end? 


Filing Status 

SEC Filing Status Average Minimum Maximum Median Number of Respondents 






297 

259 



How many working days does it take to close your books for a typical year-end? 


Filing Status 

SEC Filing Status Average Minimum Maximum Median Number of Respondents 






Do you prepare a preliminary draft of the 

Form 10-K/ 10-Q prior to quarter-end? 







257 

296 



XBRL Creation Approach 

The key aspects of the XBRL implementation process include: 

• Mapping - matching the financial line items in the financial statements to the appropriate U.S. GAAP taxonomy 

concepts (tags). 

• Tagging - applying the tags selected to the financial data and setting appropriate XBRL attributes (decimals, units, 

negated values, dates, etc). 

• Review - XBRL technical validation, rendering, QA, etc. 

Most of the companies reported that they performed at least part of the XBRL process in-house. 

XBRL Filing 

Status 

How did your organization create and submit the XBRL-formatted 

financial statement exhibits? 


Outsourced 

entire 

process 

Outsourced part 

of the process, but 

mapped internally 

Used hired consultants/advisors 

and 

a software tool 

Used internal 

staff and a 

software tool 


Respondents 






283 


XBRL CREATION APPROACH -PAGE 18

XBRL Filing Status 

How did your organization create and submit the XBRL-formatted 

financial statement exhibits? 

Outsourced 

Entire Process 

Outsourced Part 

of the Process, but 

Mapped Internally 

Used Hired 

Consultants/ Advisors 

and a Software Tool 

Used Internal Staff 

and a Software Tool 


Respondents 

Clarity 7% —% 7% 86% 14 

Donnelley 72% 28% —% —% 90 

Merrill 72% 14% 7% 7% 14 

Rivet 46% 31% —% 23% 13 

Thomson Reuters 25% 20% 25% 30% 20 

WebFilings 17% 4% 31% 48% 114 

Other 33% 33% 23% 11% 9 

Did Not State 11% 33% 11% 45% 9 

283 

There was some range in how respondents indicated using a given solution. For example, of the 14 

respondents to this question who reported using Clarity, 12 respondents (86%) indicated using internal 

staff and the software tool, one respondent (7%) reported using Clarity’s software tool along with outside 

consultants to provide XBRL services and one respondent (7%) which reported using Clarity described the 

process as fully outsourced. 

The great majority of the companies using RR Donnelley and Merrill indicated that they outsourced the 

XBRL process while companies using Clarity overwhelmingly indicated that they used a software tool 

internally. Companies using Rivet, Thomson Reuters and WebFilings had more distributed responses, 

as these offerings allow for a range of services, from complete outsourcing of professional services to 

self–sufficiency using software internally (in–house). 

Will you continue the same process going forward? 


Don’t 

Know 

Number of Respondents 

TIER 1 Large Accelerated Filer 49% 34% 17% 59 


TIER 3 Accelerated Filer 74% 11% 15% 61 

Non–Accelerated Filer 68% 18% 14% 28 

Smaller Reporting Company 88% 4% 8% 25 

Tier 1 and 2 XBRL filers, who have the most experience with XBRL, were significantly more likely to predict 

a change in XBRL process going forward versus Tier 3 filers who have not yet had experience with 

detailed tagging. Of the respondents who indicated that they would change their process (“No” answer 

above), the vast majority projected adoption of an in-house software solution. 

282 


XBRL CREATION APPROACH (Continued) -PAGE 19


If you do not plan to continue the same process, 

what part of the process will you change to? 

Bringing In-House/ 

Software Solution 

Outsourcing Undecided 


Respondents 

TIER 1 Large Accelerated Filer 100% —% —% 16 


TIER 3 Accelerated Filer 100% —% —% 10 

Non-Accelerated Filer 100% —% —% 5 

Smaller Reporting Company 100% —% —% 1 

71 

There were two Tier 2 filers that indicated an outsourcing change. Both plan to change from one outsourced 

provider to another. Based on companies’ future plans for XBRL compliance, there does not appear 

to be any reversal of the trend from outsourcing XBRL to the use of in-house software solutions. 



What resources did you use when developing XBRL-formatted financial statements? 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

XBRL U.S. GAAP taxonomies 88% 85% 80% 82% 56% 

Service or tool provider support 71% 72% 67% 64% 48% 

Training rovided by software or 

service providers 

Review of competitor or industry 

public company filings 

64% 60% 67% 61% 52% 

49% 69% 62% 64% 36% 

Educational webinar 61% 59% 63% 50% 40% 

XBRL U.S. preparers guide 42% 41% 32% 29% 8% 

SEC resources 47% 37% 32% 11% 16% 

XBRL U.S. FAQs or other web 

tools (sample instances, articles, 

etc.) 

39% 23% 30% 11% 20% 

In-person training session 31% 27% 25% 29% 4% 

EDGAR filer manual 39% 28% 18% 18% 8% 

Filing agent resources 20% 18% 12% 11% 20% 

Help from auditor 10% 4% 3% 4% —% 

Direct questions to XBRL U.S. 

personnel 

5% 2% 3% —% 4% 


Total 



Number of Hours to Create XBRL Reports 

Less than half of large accelerated filers reported that they incurred more than 80 hours to review and 

coordinate with their third-party service provider for their Level 4 detailed XBRL reports. XBRL reports 

prepared in-house required more staff time than outsourced filings, reflecting the broader role taken on 

by in-house teams. Tier 3 filers reported a lower number of hours than Tier 1 and 2 filers which is reflective 

of the reduced complexity of their first year XBRL filings. 

If outsourced, how many hours did it take your company to review and coordinate 

with the 3rd party service provider to submit the XBRL files to the SEC? 


Less than 40 

hours 

41-80 

hours 

81-120 

hours 

More than 

120 hours 


Respondents 






183 

If in-house, how many hours did it take your organization to 

create, review and submit the XBRL files to the SEC? 


Less than 40 

hours 

41-80 

hours 

81-120 

hours 

More than 

120 hours 


Respondents 





Smaller Reporting Company 58% 33% —% 9% 12 

137 


NUMBER OF HOURS TO CREATE XBRL REPORTS -PAGE 22

XBRL Experiences 

What questions or concerns do you have now that you have done XBRL tagging? 

(Choose all that apply) 

How to increase efficiences in creation, 

review and submission 

Ongoing cost and difficulty of XBRL 

creation and submission 

How to better define and control the 

process 

More information on how to do detailed 

tagging 

Resource availability to meet ongoing 

processes 

Developments regarding auditors 

responsibility for XBRL-formatted 

financial statements 

Risk/liability for having the same 

financials available to the public in two 

different formats 

What is the readiness of market for 

financial analysis software tool development 

for individuals and small company 

users 

Reporting package and management 

information software tool availability 

Not being able to use the grace period in 

subsequent filings 

How to put a rendered version of my 

XBRL financials on my site 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

91% 92% 78% 75% 68% 

53% 60% 46% 46% 53% 

53% 51% 52% 29% 37% 

19% 25% 90% 67% 100% 

45% 52% 36% 33% 32% 

42% 40% 36% 21% 37% 

49% 35% 28% 38% 16% 

25% 20% 28% 17% 16% 

13% 22% 14% 4% 11% 

8% 8% 8% 4% 11% 

4% 5% 12% 4% 21% 


Total 


XBRL EXPERIENCES -PAGE 23


Status 

What is your familiarity with eXtensible Business Reporting Language (XBRL)? 


Expert 

Knowledge 

Advanced 

Knowledge 

Basic 

Knowledge 

Some 

Knowledge 

Does Not 

Apply 


Respondents 

TIER 1 Large Accelerated Filer 17% 59% —% 24% —% 59 

TIER 2 Large Accelerated Filer 11% 59% 5% 25% —% 111 

TIER 3 Accelerated Filer 1% 40% 8% 51% —% 68 


Status 

Non-Accelerated Filer 3% 32% 13% 52% —% 31 

Smaller Reporting Company 4% 25% 14% 53% 4% 28 

297 

What were the most challening aspects of the XBRL process? 


Getting 

Educated 

Review 

Process 

Mapping/ 

Tag 

Selection 

Negative 

Values 

Tagging 

Selecting a 

Tool and/ 

or Service 

Provider 

The majority of all registrants found that getting educated and the review process were the most challenging 

part of the XBRL process. The review process and the mapping / tag selection process were more 

challenging for the Tier 1 and Tier 2 filers with detailed XBRL filings than for the Tier 3 XBRL filers. 

Other 


Respondents 

TIER 1 Large Accelerated Filer 69% 71% 58% 32% 31% 19% 10% 59 

TIER 2 Large Accelerated Filer 57% 59% 56% 27% 26% 14% 11% 110 

TIER 3 Accelerated Filer 73% 44% 42% 31% 19% 29% 8% 62 

Non-Accelerated Filer 75% 50% 36% 21% 21% 14% 4% 28 

Smaller Reporting Company 64% 32% 40% 16% 20% 36% —% 25 

284 


XBRL EXPERIENCES -PAGE 24

How easy was it to prepare and submit XBRL-formatted financials for the second time? 


Status 


Significantly 

Easier 

Somewhat 

Easier 

About the 

Same 

Somewhat 

More 

Difficult 

Much More 

Difficult 


Respondents 

TIER 1 Large Accelerated Filer 27% 58% 13% —% 2% 56 


140 

Over 85% of Tier 1 and Tier 2 respondents found that XBRL was somewhat or significantly easier the 

second time around. Responses were provided for Tier 1 and Tier 2 large accelerated filers only as Tier 3 

XBRL filers had only filed their initial XBRL filing when they completed the survey. 

Do you expect to add additional resources to support XBRL filings? 






Smaller Reporting Company —% 100% 9 

The vast majority of respondents reported that they did not expect to add additional resources to prepare 

XBRL filings. 

127 


XBRL EXPERIENCES (Continued) -PAGE 25

Not enough resources, e.g., 

Staff, time 

What are your biggest concerns regarding XBRL? 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 

68% 78% 67% 69% 55% 

Cost/benefit proposition 77% 73% 44% 62% 73% 

Legal liability 95% 47% 52% 38% 18% 

Need to get educated 23% 44% 59% 46% 36% 

SEC validation process 45% 42% 41% 54% 36% 

Availability of help and support 

services 

Concern that submission will not 

go through 

41% 40% 30% 31% 36% 

18% 22% 19% 8% 18% 


Total 


XBRL EXPERIENCES (Continued) -PAGE 26

Impact of XBRL on SEC Filing Date 


Filing Status 

Have the XBRL requirements delayed your filing date? If so, by how long? 


Less than 

1 day 

1 day 

2 to 3 

days 

More than 

3 days 





Non-Accelerated Filer 77% 14% 9% —% 22 


Seventy two percent of large accelerated filer respondents indicated one day or less delay in SEC filing 

due to XBRL, with over 90% of Tier 3 companies indicating one day or less delay. 

Have the XBRL requirements delayed your filing date? If so, by how long? 

XBRL Provider Less than 1 day 1 day 2 to 3 days More than 3 days 

249 


Respondents 

Clarity 85% —% —% 15% 13 

Donnelley 47% 25% 26% 2% 84 

Merrill 46% 31% 15% 8% 13 

Rivet 50% 30% 20% —% 10 

Thomson Reuters 35% 25% 25% 15% 20 

WebFilings 85% 6% 7% 2% 97 

Other 63% 37% —% —% 8 

Did Not State 50% 25% —% 25% 4 

Many respondents did not initially answer this question. Upon follow–up, many respondents indicated that 

XBRL did not delay their filing date while a number of respondents mentioned that they had planned to file 

later because of XBRL— essentially, they had planned ahead to give themselves more time in case it was 

needed. 

249 


IMPACT OF XBRL ON SEC FILING DATE -PAGE 27

XBRL Providers 

While the surveys were broadly distributed, there appears to have been participation-bias, with 

a higher proportion of large accelerated and accelerated filers, and less proportional participation 

by non-accelerated and smaller reporting company filers. Furthermore, the representation of XBRL 

providers mentioned by respondents is not necessarily indicative of the providers’ market share. 


Provider 

Number of Survey Responses by XBRL Provider and Filing Status 


Large 

Accelerated 

Filer 

Large 

Accelerated 

Filer 

Accelerated 

Filer 

Non– 

Accelerated 

Filer 

Smaller 


Company 


Respondents 

Percentage of 

Respondents 

Clarity 4 7 2 3 — 16 5% 

Donnelley 24 39 19 7 4 93 31% 

Merrill — 8 4 — 2 14 5% 

Rivet 4 4 2 — 3 13 4% 

Thomson Reuters 4 9 3 2 2 20 7% 

WebFilings 21 41 31 16 10 119 39% 

Other 1 1 2 2 5 11 4% 

Did Not State 1 3 7 1 2 14 5% 


Respondents 

Percentage of 

Respondents 

XBRL Provider Includes the following responses 

59 112 70 31 28 300 

20% 37% 24% 10% 9% 

XBRL providers in the table above were categorized as follows: 

Clarity Bowne Compliance Driver, Clarity FSR and IBM— Cognos FSR 

Donnelley Bowne, Bowne Pure Compliance, RR Donnelley, RR Donnelley— EDGAR Online and Rivet 

Merrill Merrill 

Rivet Rivet and Rivet Crossfire 

Thomson Reuters EDGAR Filings, EDGARizer, EDGARizer X and Thomson Reuters 

WebFilings WebFilings 

Other Business Wire, EDGAR Online, Fujitsu, Issuer Direct, Public Ease, RDG Filings and Vintage Filings 


XBRL PROVIDERS -PAGE 28

“Pencils Down” Experience 

“Pencils down” refers to the period prior to the planned SEC filing when the service provider imposes a 

window in which no more changes are allowed. These are typically expressed in business days and in practice 

may vary for a 10–Q to a 10–K and depending on the peak load issues around the time of a particular 

registrant’s planned filing. The following table breaks out the survey responses regarding “pencils down” 

by XBRL provider. 


Provider 

Does your provider have a “pencils down” policy in order to ensure timely filing? 

If so, what is the amount of time? 

No pencils 

down 

Less than 

24 hours 

1 to 

2 days 

3 to 

4 days 

5 or more 

days 


Clarity 66% 7% 13% 7% 7% 15 

Donnelley 3% 9% 53% 26% 9% 93 

Merrill —% 29% 42% 29% —% 14 

Rivet 23% —% 54% 23% —% 13 

Thomson Reuters 44% —% 22% 28% 6% 19 

WebFilings 91% 5% 3% 1% —% 113 

Other 27% 9% 55% 9% —% 11 

Did Not State 25% 25% 25% 25% —% 8 

286 


“PENCILS DOWN” EXPERIENCE-PAGE 29

XBRL Provider Satisfaction 

Providers most closely associated with “built–in” XBRL solutions, Clarity and WebFilings, have the highest 

overall satisfaction levels. 


Provider 

How satisfied were you with your XBRL provider? (For all survey respondents) 

Very Satisfied Somewhat Satisfied Not Very Satisfied Number of Respondents 

Clarity 74% 13% 13% 15 

Donnelley 17% 64% 19% 93 

Merrill 43% 57% —% 14 

Rivet 25% 42% 33% 12 

Thomson Reuters 25% 40% 35% 20 

WebFilings 96% 4% —% 117 

Other 64% 27% 9% 11 

Did Not State 62% 25% 13% 8 

290 

Satisfaction rates varied for certain XBRL providers between the large accelerated filers (Tier 1 and Tier 2 

XBRL filers) who file level 4 detailed XBRL reports, and the Tier 3 XBRL filers. A breakout of the combined 

Tier 1 and Tier 2 XBRL filers and the Tier 3 respondents are provided below. 


Provider 

How satisfied were you with your XBRL provider? 

For Large Accelerated Filers (Tier 1 and 2 XBRL Filers) 


Clarity 73% 18% 9% 11 

Donnelley 13% 59% 28% 63 

Merrill 38% 62% —% 8 

Rivet 38% 25% 37% 8 



Other 50% 50% —% 2 

Did Not State 50% —% 50% 2 

168 


XBRL PROVIDER SATISFACTION -PAGE 30


Provider 

How satisfied were you with your XBRL provider? 

(Tier 3 XBRL Filers) 


Clarity 75% —% 25% 4 

Donnelley 27% 73% —% 30 

Merrill 50% 50% —% 6 

Rivet —% 75% 25% 4 



Other 67% 22% 11% 9 

Did Not State 67% 33% —% 6 

122 


XBRL PROVIDER SATISFACTION (Continued)-PAGE 31

ACKNOWLEDGMENTS 

FERF offers a special thank you to the following individuals for their assistance with this survey: 

Nadine Bonney, Senior Manager, Financial Reporting, Intuit, Inc. 

Carrie Dostal, Life Accounting Manager, FBL Financial Group 

Vincenzo DiMaggio, Vice President & Assistant Corporate Controller, The New York Times Company 

Lorraine Malonza, Director, Accounting Policy and Financial Research, FEI 

Robert Morse, Senior Business Leader, MasterCard 

Elaine Sabatino, Vice President, Enterprise Accounting & Reporting, Franklin Templeton Investments 

ABOUT THE AUTHOR 

William M. Sinnett is Senior Director, Research for Financial Executives Research Foundation, Inc. 

(FERF). He received his Masters of Business Administration degree from the University of Pittsburgh. 

Prior to joining FERF, he held positions in financial management with Mellon Bank and Carnegie- 

Mellon University in Pittsburgh. 

Bill can be reached at bsinnett@financialexecutives.org or (973) 765-1004 


ACKNOWLEDGMENTS -PAGE 32

About Financial Executives Research Foundation, Inc. 

Financial Executives Research Foundation (FERF) is the non-profit 501(c)(3) research affiliate of 

Financial Executives International (FEI). FERF researchers identify key financial issues and develop 

impartial, timely research reports for FEI members and non- members alike, in a variety of publication 

formats. FERF relies primarily on voluntary tax-deductible contributions from corporations and individuals. 

Questions about FERF can be directed to bsinnett@financialexecutives.org. 

The views set forth in this publication are those of the author and do not necessarily represent 

those of the FERF Board as a whole, individual trustees, employees, or the members of the Advisory 

Committee. FERF shall be held harmless against any claims, demands, suits, damages, injuries, 

costs, or expenses of any kind or nature whatsoever except such liabilities as may result solely from 

misconduct or improper performance by the Foundation or any of its representatives. 

FERF publications can be ordered by logging onto http://www.ferf.org. 

Copyright © 2011 by Financial Executives Research Foundation, Inc. 

All rights reserved. No part of this publication may be reproduced in any form or by any means without written permission from 

the publisher. 

International Standard Book Number 

978-1-61509-084-6 

Printed in the United States of America 

First Printing 

Authorization to photocopy items for internal or personal use, or the internal or personal use of specific clients, is granted 

by Financial Executives Research Foundation, Inc. provided that an appropriate fee is paid to Copyright Clearance Center, 222 

Rosewood Drive, Danvers, MA 01923. Fee inquiries can be directed to Copyright Clearance Center at 978-750-8400. For further 

information please check Copyright Clearance Center online at http://www.copyright.com. 


PAGE 33

FINANCIAL EXECUTIVES RESEARCH FOUNDATION, INC. would like to acknowledge and 

thank the following companies for their support and generosity: 

PLATINUM MAJOR GIFT | $50,000 + 

Exxon Mobil Corporation Microsoft Corporation 

GOLD PRESIDENT’S CIRCLE | $10,000 - $14,999 

Abbott Laboratories, Inc. Dow Chemical Company 

The Boeing Company General Electric Company 

Cisco Systems, Inc. 

SILVER PRESIDENT’S CIRCLE | $5,000 - $9,999 

Apple, Inc. IBM Corporation 

Comcast Corporation Johnson & Johnson 

Corning Incorporated Lockheed Martin Corporation 

Credit Suisse Maple Leaf Foods, Inc. 

Cummins Inc. Medtronic, Inc. 

Dell, Inc. Motorola Solutions, Inc. 

Duke Energy Corporation Pfizer Inc. 

E. I. du Pont de Nemours & Company Procter & Gamble Co. 

Eli Lilly and Company Safeway, Inc. 

GM Foundation Sony Corporation of America 

Halliburton Company Tenneco 

The Hershey Company Tyco International Mgt. Company 

Hewlett-Packard Company Wells Fargo & Company 


PAGE 34

For additional information regarding FERF, contact: 

William M. Sinnett 

Senior Director, Research 

Financial Executives Research Foundation (FERF) 

(973) 765-1004 

bsinnett@financialexecutives.org 

www.ferf.org

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