Talk:European Filing Rules

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Contents 1 Comments 1.1 Comment-01 1.2 Comment-02 1.3 Comment-03 1.4 Comment-04 1.5 Comment-05 1.6 Comment-06 1.7 Comment-07 1.8 Comment-08 1.9 Comment-09 1.10 Comment-10 1.11 Comment-11 1.12 Comment-12 1.13 Comment-13 1.14 Comment-14 1.15 Comment-15 1.16 Comment-16 1.17 Suggestions

Comments

Comment-01

RH: Can we use only 'instance' as the term for a report, XBRL document, filing document etc.?
KH: I agree. I'm going to change it to instance document.
The discussion is closed, the following action has been taken: Changed by KH

Comment-02

RH: This 'rule' states that there is no rule for instance naming. I suggest to alter the rule to: Any taxonomy author MUST prescribe instance file naming conventions. We can make a couple of suggestions on how other projects have created such rules.
KH: There need not be any file name conventions. So I would suggest to use CAN instead of MUST.
RH: This touches on a more basic point; if we do not set rules on anything, should we mention it at all? Are examples than still appropriate? IMO it is required to have it explicit (I always favor explicit to implicit). For rules MUST and MAY are the most appropriate terms. So this one should revert to a MAY rule. TD: Is this aspect of file naming not something that should be in the Architecture Document (Roland saying that the author of a taxonomy must provide for a file naming convention. So that instance documents generated on the basis of such a schema will have per definition a file name)
RH: CEN meeting 2012-10-29: Rules should be made explicit, also when the rule is 'to have no rule'.
The discussion is closed, the following action has been taken: Rules have been explicit by RH

Comment-03

Rule: 2.22 xbrli:xbrl/xbrli:unit declarations SHOULD adhere to XBRL international unit registry content
KH: Rule should be reformulated.
RH: Suggestion has been made, SHOULD NOT rule on creating units that are in utr.

Comment-04

KH: Should it be allowed ot define units?
RH: CEN meeting 2012-10-29: No scale on numerics is allowed. Rather: NSA's should conform to the utr of XII and put any new units in there.
The discussion is closed, the following action has been taken: RH: rule is no scale allowed.

Comment-05

KH: Rule to be added that no extension of reporting entities on European taxonomies are allowed.
RH: CEN meeting 2012-10-29, not extensions by reporters allowed
The discussion is closed, the following action has been taken: Rule 1.8 no extensions allowed created.

Comment-06

KH: The schemaRef should contain the full schemalocation because the version is not contained in the namespace.
The discussion is closed, the following action has been taken: RH: comment processed in rule.

Comment-07

TD: In general: the word to be defined should not appear in the definition
The discussion is closed, the following action has been taken: RH: comment processed in rule.

Comment-08

TD: I would add a definition for the "filer" and include there the fact that the filer should own the name of the authority. I would also add a defintion for "to file", in case this is a technical term here.
The discussion is closed, the following action has been taken: RH: comment processed in entry, to file is the general process of filing anything with an authority.

Comment-09

TD: For "entity" I found this deinfition (http://www.aasb.gov.au/admin/file/content102/c3/SAC1_8-90_2001V.pdf)

"entity" means any legal, administrative, or fiduciary arrangement, organisational structure or other party (including a person) having the capacity to deploy scarce resources in order to achieve objectives; and

again, we should avoid to have the (parts of) term we define, inside the definition.

KH: The definition has be reformulated.

Comment-10

TD: The additional sentence "A listing of all taxonomy files respective modules recognised in the filing system should be provided on a web location. " is not necessary
RH: What this text is showing is that DTS authors MUST provide a list of URL's to entrypoints on the internet. Maybe the rule is self explaining?

Comment-11

TD: I think that the concept "Entry Point" should be defined before
The discussion is closed, the following action has been taken: Included by RH

Comment-12

KH: A rule should be added that always the complete package (file) should be sent, not only an update.
DDB: I think this makes it less flexible, partial submission can be very efficient.
RH: CEN meeting 2012-10-29: Allowing partial data brings a lot of technical complexity because validation and presentation of the instance is no longer possible. OTOH the internal processes at reporters may be designed to create only parts of certain reports. Forcing only complete submissions would force internal restructuring with these reporters. Golden rule is that every XBRL instance is XBRL standards valid.
Interesting case: if, because of size restrictions, the instance is being split across multiple instances, a 'total' assertion may not be functioning correctly. In this case the 'golden rule' is being broken because of technical reasons. The DTS owner allowing partial submissions need to guarantee ex-post that all original rules of the DTS are processable.
Sending partial submissions by reporters becomes a choice of the NSA. The header of the message will cater for an element that states if the instance is a 'full' replacement or a 'incremental' submission.
All risks involved with partial submissions are upon the NSA allowing it. The recommendation will be to sent complete packages. (the term Package is not defined!)

Comment-13

RH: Where is the 'default' language declared? Better not have any implicit meaning since every country will allow it's own 'default' which would result in a mess at central European regulators.
Propose to change the rule into: Non numeric facts MUST be clarified to what language is being used.
The purpose of the xml:lang is to enable the receiver to match presentation templates with the facts in the same language as the (non-numeric) facts have been put. ENABLE, not FORCES.

The discussion is closed, the proposed solutions has been adopted: Included by KH

Comment-14

RH/KH: Because of size restrictions, the instance could be split across multiple instances, a 'total' assertion based on XBRL Formula may not be functioning correctly. In this case the instance document wouldn't be valid. The receiver of the data allowing the splitting of submissions need to guarantee ex-post that all original rules of the DTS including Formulas are processable.

Comment-15

TD: The Abbreviation "CWA" occurs here for the first time and has not been introduced. Maybe the whole chapter should start with a sentence like "The present CWA (Full Wording) on European Filing Rules specifies...."

Comment-16

TD: I think that examples should have a different layout. It might be useful to add after the definition a line stating: Example: The xs:element xyz can be viewed as a ..."

Suggestions

RH: As per telecall 20121108 a couple of rules MAY be merged. These are:
There MUST NOT be more than one link:schemaRef in an instance
Reporting entities SHOULD use only one of entrypoint schemas as specified in the applicable taxonomy.
link:schemaRef MUST contain the full URL as published on the internet
Reporting entities SHOULD use one of the taxonomies as specified in the filing system as the applicable taxonomy.

Suggestion:
A single entrypoint using link:schemaRef addressing the official applicable taxonomy through an URL MUST be used.