At the end of April, the International Accounting Standards Committee (IASC) Foundation released the 2010 IFRS Taxonomy. The timing of this release coincides with a continued push to get this taxonomy ready for submissions to the SEC scheduled to start in mid-2011. A quick walk down Final Rule memory lane is that all companies that currently report to the SEC in IFRS, regardless of the size of the company, were pushed to Group 3 of the mandate that has initial XBRL submissions starting on or after June 15, 2011.
So, is the 2010 IFRS Taxonomy ready for SEC "Prime Time"? There are a number of ways to evaluate the state-of-readiness of a taxonomy, and I tend to key on the following three:Marketplace Usage: Although the IFRS Taxonomy has been around since 2006, regulatory programs based on it (SEC, UK iXBRL) are just getting started. As such, it's hard to fully gauge how companies find the current taxonomy in terms of providing adequate tags for regulatory submissions given its recent release and the lack of public-facing tagged data being available. Based upon initial tagging work requested by non-U.S. clients, meeting SEC Year 1 tagging requirements goes fairly well for simple financial statements and block tagging of the Notes. However, when it comes to more complex Year 1 and meeting Year 2 requirements in general, especially for heavier industry-specific reporting requirements found in such industries as Oil & Gas, Utilities, Real Estate and Financial Services, the current version is under-powered and will cause companies to have to create a large number of extension tags in order to complete their submissions.
Tag Robustness: The 2009 US GAAP taxonomy has roughly 13,500 unique tags. How about the 2010 IFRS Taxonomy? Its total unique tag count comes in just over 2,000 which includes 900+ monetary tags and 775+ text tags, with almost 25% of the total tags being Abstract tags (tags for grouping only; not used for tagging). Just for comparison, the 2009 US GAAP taxonomy has 6-7 times the number of monetary tags than the current IFRS Taxonomy does. One might argue that analyzing the number of tags isn't a fair barometer of taxonomy completeness but unfortunately, when it comes to SEC submissions, tags count. At this stage of the game, it seems pretty clear that the 2010 IFRS Taxonomy could use a few more tags, especially at the industry level (see industry comment above).
Also important is the availability and completeness of definitions and authoritative references for each tag in the taxonomy. This good news is that most IFRS taxonomy tags contains references to authoritative literature; the bad news is that none of the tags include a definition...=(. While recognizing that the SEC EDGAR Filer Manual puts higher importance on other tag attributes such as Data Type (numeric vs. text) and Period Type (instant or duration), the reality is that people making tagging correctness decisions need definitions to help get the job done...and those people doing it currently in US GAAP (that has definitions) are quickly noticing them missing in IFRS (right sm?). Without definitions, the 2010 IFRS taxonomy makes it harder to tag and review tagged data.
Domain Experts: As part of finalizing the 2010 IFRS taxonomy release, the IASB solicited comments on the "Exposure Draft" (think beta/preview version) of the taxonomy. The IASB has made the comments they received, of which there are 12, available for review. Review them all when you can, but I found the following interesting when it comes to assessing taxonomy readiness:
Ms. Emily Reid, NAREIT: "As expressed in our previous submission [30 May 2008], we recommend the IASC Foundation should extend the IFRS taxonomy to offer industry specific tags, including tags that relate specifically to the real estate industry."
Lynda Tomkins, Ernst & Young EYGS LLP: "With the XBRL requirements for companies using IFRS in the UK and US both commencing in 2011, we do not believe the current IFRS taxonomy is fit for purpose to meet the needs of regulators and impacted preparers. The current IFRS Taxonomy 2010 is lacking a richness demanded by regulators, preparers, analysts and investors worldwide."
Summary: Based upon these three criteria, I must admit I'm a little more than worried about the 2010 IFRS Taxonomy being ready for SEC Prime Time. The clock is ticking closer and closer to the start of SEC (and iXBRL) submissions based on this taxonomy, which begs the question: Is there enough time left to bring it around? Knowing the XBRL team at the IASB, they have a trick or two up their sleeves and my hope is that one of those includes releasing an updated version of the IFRS taxonomy by late-2010/early-2011 that offers definitions and more tags (especially at the industry level). Good luck guys...we look forward to you pulling this off!