The U.S. Securities and Exchange Commission (SEC) recently implemented a new requirement related to registrants’ eXtensible Business Reporting Language (XBRL) tagging of their relevant filings. The requirement can be found in an amendment to the Holding Foreign Companies Accountable Act. It is effective for Forms 10-K, 20-F and 40-F for periods ending on or after Dec. 15, 2021 (i.e., effective for registrants with a Dec. 31, 2021, year-end). Among other changes, the SEC’s final rule requires registrants to include XBRL tags for the following three items relating to the registered public accounting firm (or firms) that issues audit reports included in the filing:
The disclosure of each item must be visible and should not be disclosed within Item 9C, Disclosure Regarding Jurisdictions that Prevent Inspection.
The AuditorName and AuditorLocation can be tagged within Baker Tilly’s audit opinion. The rules do not specify where the Firm ID should be disclosed; suggested locations include:
XBRL tagging is a registrant’s responsibility, and independence rules preclude auditors from assisting with the preparation of the financial statements or disclosures. Registrants should consult with their securities counsel with questions about where to disclose this information or other changes required by the SEC’s final rule.