CEN/WS XBRL Recap
Filing rules
and extensions of EBA/EIOPA taxonomies
5 May, 2013
Katrin Heinze, Bundesbank (currently working for the ECB)
Page 1
CWA1
EU principles of transparency and
non-discrimination
Fundamental principles of the EC Law
Increasing the competitiveness and support the movement of services
Member states must transpose the EU Directives with precision, clarity
and transparency to enable individuals to ascertain their obligations
Providing significant impulses for harmonization in different business
areas
One of them: ICT - information and communication technologies
ICT provides services for the industrial society which are essential to be
competitive against markets in and outside of the EU
ICT contribute to the overall business success
Precondition
ICT applications must be interoperable to provide efficient access to information and their
distribution
In this sense: The harmonization of the supervisory reporting in
Europe by using DPM and XBRL is an important field of activity.
2
Technical background for the definition of
filing rules
XBRL is a framework for the definition of data
formats
provides a high degree of flexibility for the creation
of taxonomies and instance documents
flexibility requires complex IT systems to react
appropriately on all possible variants that the
standard allows,
like definition of units, accuracy of values, usage of
footnotes, periods, identifiers etc.
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Definition and Advantages
Rules to be followed for the preparation and validation of instance
documents in a XBRL filing process which
place additional constraints on XBRL instance documents.
Advantages
Provide harmonization on a technical level
Enhance the interoperability of IT systems
Ease the comparison of reporting data
Ease the validation of instance documents
Give rules to reporting entities as guidance
Decrease the reporting burden for reporting entities
Enable automated tests on the rule set
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XBRL Filing
?
Filing Rules based on Best Practices
Approach
Year
Status
Publisher
Coverage
Rules on
FRIS1
2004
PWD2
XII3
XBRL 2.1 - only
XBRL instances
Global Filing
Manual
2010
Best
Practices
SEC, FSA Japan, IFRS
XBRL Standard
XBRL instances
and taxonomies
EDGAR Filer
Manual
2013
Best
Practices
U.S. Securities and
Exchange
Commission
XBRL Standard
XBRL instances
and taxonomies
Part of the CWA1 deliverables of the standardization process of CEN/WS XBRL
oriented to reporting entities preparing the filings on basis of EIOPA and EBA
taxonomies
Recommendations to be adopted by NCAs
and European Supervisory Authorities
EFL
FRIS
GFM
Page 5
1
2
3
Financial Reporting Instance Standards
Public Working Draft
XBRL International Inc.
Structure of the Deliverable
Currently 34 rules and descriptions separated in two chapters
12 Filing syntax rules
Rules for the complete document to be filed
22 Instance syntax rules
Syntax rules for the instance document and its subordinated objects
Contexts
Facts
Units
Footnotes
Example:
Page 6
Meta model of the CEN Filing Rules
Page 8
Achievements so far
Reporting
entity
Data Point Model
Harmonised
Harmonised
XBRL Data Format &
XBRL Filing
?
Harmonised?
European
Reporting
Frameworks
Page 9
European
Supervisor
Analysis based on the following
publications
CEN: European Filing Rules. December 2013 (after approval by the stakeholders)
EBA: XBRL Filing Rules COREP and FINREP Taxonomy v2. March 2014
https://www.eba.europa.eu/documents/10180/502670/EBA+XBRL+Filing+Rules+for+v2.0.0.pdf
Filing Manuals of the NCAs in Denmark, United Kingdom and Germany
Danmarks Nationalbank: Danish XBRL Filing Rules. February 2014
https://www.finanstilsynet.dk/~/media/Temaer/2014/Fremtidigeindberetninger/Indberetningsregler_fiona.ashx
FCA: COREP/FINREP Reporting Filing Manual. February 2014
http://www.fca.org.uk/static/documents/corep-finrep-filing-manual.pdf
Bundesbank: Regeln der Bundesbank für das bankaufsichtliche XBRL-Meldewesen.
March 2014 (only in German)
http://www.bundesbank.de/Redaktion/DE/Downloads/Service/Meldewesen/Bankenaufsicht/PDF/bundesbank
_filing_rules.pdf?__blob=publicationFile
…
10
Comparison of the Filing Manuals
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Level of harmonisation CEN <-> EBA
CEN rules adopted by EBA
March 2014
7
34
32
8 of 32 define a
different
severity
2
CEN rules
Not adopted
Harmonised
Number of CEN rules: 34
Number of EBA rules: 39
Page
12
New
Issues identified CEN <-> EBA
First set of rules was reduced from 48 to 35 rules
Some previously rejected rules have been added to
the EBA rule set
One rule seems to have a lack of details
The indication of the severity is unclear
is required = MUST
is recommended = SHOULD; sometimes MAY
13
Level of harmonisation EBA <-> NCAs
EBA rules adopted by DE, DK, UK
March 2014
39
23
16
4
EBA rules
Harmonised
Amended
Page
14
New
Decrease in harmonisation
15
Problems identified EBA <-> NCAs
Harmonisation on technical level is not reached
International acting reporting entities have to be
prepared for the different validation requirements
Some based on national language-dependent
description
NCAs might need to amend the file for transmitting
it to ECB or EBA (i.e. duplicate facts are not restricted)
Software prepared for the validation of the EBA
Filing Rules does not cover all rules defined across
Europe
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Possible counter-measures
Amending the CEN Filing Rules according to the
amendments introduced by EBA
Interested parties?
Define a clear severity for each rule
Ease the description of the rule (too technical?)
Raise awareness in the Eurofiling community
Eurofiling workshop (Done!)
Conference call
Publication of the analysis results at eurofiling.info
Raise the issue at EBA level
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Thanks for your attention
Comments or questions?
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CWA1