mhoullier/esef-block-tagging-hierarchy

esef-block-tagging-hierarchy's Issues

InformationAboutEmployees and EmployeeBenefits

What is the definition for the former? Do we agree on the principle that employee benefits are not a part of it?

ExceptionalItems (accounting policy) expected contents

When is this tag expected to be used? There is no definition in the standards.

JointVentures and InvestmentsAccountedForUsingEquityMethod

Is it all right to multi-tag a whole disclosure of joint ventures with the tag for investments accounted for using the equity method, even when it may also include joint ventures other than ones accounted for using the equity method?

DisclosureOfFinancialRiskManagementExplanatory definition and relation to other tags

Should we consider that DisclosureOfFinancialRiskManagementExplanatory as a part of DisclosureOfFinancialInstrumentsExplanatory?

Should we consider that DisclosureOfLiquidityRiskExplanatory, DisclosureOfMarketRiskExplanatory, DisclosureOfCreditRiskExplanatory are part of DisclosureOfFinancialRiskManagementExplanatory?

Agreed upon hierarchical relations

We distinguish:

1. Strict inclusions A < B, that denote that all sections tagged with A should also be tagged with B
2. Frequent inclusions A ≲ B, that denotes that tag B should strongly be considered as well when using tag A

• DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory < DisclosureOfInterestInOtherEntities

• DisclosureOfInvestmentsOtherThanInvestmentsAccountedForUsingEquityMethodExplanatory < DisclosureOfInterestsInOtherEntitiesExplanatory

• DisclosureOfNoncontrollingInterestsExplanatory < DisclosureOfSignificantInvestmentsInSubsidiariesExplanatory

• DisclosureOfFairValueOfFinancialInstrumentsExplanatory < DisclosureOfFairValueMeasurementExplanatory

• DisclosureOfFairValueOfFinancialInstrumentsExplanatory < DisclosureOfFinancialInstrumentsExplanatory

• DisclosureOfSignificantInvestmentsInAssociatesExplanatory ≲ DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory

Expenses, expected content

Are all kinds of expenses supposed to be part of this tag? It seems difficult to cover all section where an expense is disclosed.

For instance, if among other information is my section relative to employee benefits there is an expense, am I expected to tag using the disclosure of expenses tag?

BorrowingCosts, expected content and placement

What is the definition for this? Is there any tag with a wider meaning that we could identify?

EBPTF - Questionnable mandatory bocktags

This is the place to add what you consider are questionnable tags in the list of mandatory blocktags.
The relevance of these tags will be discussed in the workgroup and our conclusions will be included in our final document.

I propose the following list that you can amend or expand:

• DisclosureOfConsolidatedAndSeparateFinancialStatementsExplanatory
• DisclosureOfInterimFinancialReportingExplanatory
• DescriptionOfAccountingPolicyForExceptionalItemsExplanatory
• DisclosureOfExpensesExplanatory
• DescriptionOfAccountingPolicyForExpensesExplanatory
• DisclosureOfExpensesByNatureExplanatory
• DisclosureOfInformationAboutEmployeesExplanatory
• DisclosureOfInformationAboutKeyManagementPersonnelExplanatory
• Basis of consolidation
• DisclosureOfInterestsInOtherEntitiesExplanatory

--

simplification of the hierarchy of disclosures

I had a new (disrupting) idea about the hierarchy of disclosures:
In the IFRS taxonomy there is a sort of hierarchy:

• level 1: disclosures that are defined as "entire disclosure" of a topic (57 elements)
• level 2: disclosures that are referenced to specific IFRS (11 aditionnal elements)
• level 3: disclosures defined as "common practices" (155 elements)

Any disclosure or accounting policy relating to level 1 and 2 must be tagged specifically and with tag of the parent in level 1 or level 2
Any disclosure relating to level 3 must be tagged if present, tagged with the parent in level 1 or 2 (if any) without any hierarchy or to the root if it is not related to a parent in the list (67 elements)

This would simplify the imbrications (3 levels maximum) an ease the selection of tags

I can share the excel file that illustrates this.

Tags that refer to concepts that are never defined in the standards

The list of mandatory tags includes a number of tags centered around concepts that are never defined in the IFRS.

For instance, DisclosureOfProfitLossFromOperatingActivitiesExplanatory, DescriptionOfAccountingPolicyForExceptionalItemsExplanatory, ...

How can we approach tagging or review the conformance of a tagging without an agreement on the definition of these items?

ProfitLossFromOperatingActivities, expected content

What should be the definition for this tag? Are all disclosures relative to components of the profit (loss) from operating activities expected to be covered by this tag as well?

For instance, should all sections tagged with the disclosure of other operating income (expenses) be tagged with this as well?

NonControllingInterests and SignificantInvestmentsInSubsidiaries

RepurchaseAndReverseRepurchaseAgreements expected content

What is the expected content for this disclosure?

Proposed hierarchy of textblocks

Here is a draft of the proposed hierarchy of textblocks to help issuers tag their notes and accounting policies.

• accounting policies are classified with the disclosures and independently if reported in a specific section

How to reade the file:
• level 1: disclosures that are defined as "entire disclosure" of a topic (57 elements)
• level 2: disclosures that are referenced to specific IFRS (11 additional elements)
• level 3: disclosures defined as "common practices" (153 elements)
Any disclosure or accounting policy relating to level 1 and 2 must be tagged specifically and with tag of the parent in level 1 or level 2
Any disclosure relating to level 3 must be tagged if present, tagged with the parent in level 1 or 2 (if any) (77) without any hierarchy or to the root if it is not related to a parent in the list (76 elements)
This would simplify the imbrications (3 levels maximum) an ease the selection of tags.

https://app.box.com/file/1028245660813

Expense by nature definition

The definition of expense by nature is given by the calculation linkbase:

Disclosure of notes and other explanatory information covered by RTS 2018 but not by RTS 2021

Is there an explanation why the position DisclosureOfNotesAndOtherExplanatoryInformationExplanatory is not covered by "Final Report On the draft RTS amending Delegated Regulation (EU) 2019/815 as regards the 2022 update of the taxonomy laid down in the RTS on ESEF"?

In my understanding when using ESEF 2021 taxonomy it is required to tag this very large block tag, but for usage of ESEF 2022 taxonomy it won't be required.

DisclosureOfRepurchaseAndReverseRepurchaseAgreementsExplanatory definition and relation to other tags?

Should DisclosureOfRepurchaseAndReverseRepurchaseAgreementsExplanatory be considered a part of DisclosureOfFinancialInstrumentsExplanatory?

DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory expected narrower tags

Do we expect the DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory element to ever be used by itself, or do we expect to almost always have contents relative to associates and/or joint ventures that could be tagged using a narrower disclosure as well?

What is a disclosure that must be tagged?

RTS:
Issuers shall mark up all disclosures made in IFRS consolidated financial statements or made by cross-reference therein to other parts of the annual financial reports for financial years beginning on or after 1 January 2022 that correspond to the elements in Table 2 of this Annex.

Reporting manual:
Therefore, preparers have to consider the accounting meaning of a taxonomy element when selecting the appropriate block tag for marking up such disclosure. This is particularly important for cases where there are multiple block tags that can match a given disclosure.
ESMA is of the opinion that issuers shall, as a minimum, mark up information contained in the IFRS consolidated financial statements (including headers/titles) with the elements of Annex II.
In case of a disclosure corresponding to more than one element of different granularity (with narrower and wider elements), preparers should use each of them and multi tag the information to the extent that corresponds with the underlying accounting meaning of the information.

What is a disclosure? How is it represented in the financial statements?

• Refers to headers/titles or more granular information: paragragh/words?
  What is the meaning of “corresponding”?
• The “accounting meaning” of disclosure is not defined in the taxonomy.
• In many cases, it is possible to relate with primary financial line items. In other cases?
• The relation to a wider element is undestandable in case there is a hierarchy
• When are there narrower elements? Should not these be tagged at level 1?

InvestmentsOtherThanInvestmentsAccountedForUsingEquityMethod part of FinancialInstruments?

Should we tag disclosures relative to investments other than investments accounted for using equity method with the financial instruments disclosure tag?

Systematic use of DisclosureOfNotesAndOtherExplanatoryInformationExplanatory for all notes

Should the DisclosureOfNotesAndOtherExplanatoryInformationExplanatory tag be used for all notes or only for parts of the notes that are covered by no other tag from the list of mandatory taggings?

SignificantInvestmentsInAssociates and InvestmentsAccountedForUsingEquityMethod

Is it all right to multi-tag a whole disclosure of significant investments in associates with the tag for investment accounted for using the equity method, even when it may also include investments in associates other than ones accounted for using the equity method?

Inclusion of accounting policies in the corresponding "disclosure" tag

Should an accounting policy always be tagged with the corresponding "disclosure" tag (if it exists), even when the accounting policy is disclosed in a well-separated location of the notes?

DisclosureOfInformationAboutEmployeesExplanatory and DisclosureOfEmployeeBenefitsExplanatory

Should DisclosureOfEmployeeBenefitsExplanatory be considered a part of DisclosureOfInformationAboutEmployeesExplanatory?

InterestsInOtherEntities and BasisOfConsolidation

What is the definition of the basis of consolidation tag?

Is there any expected hierarchical relationship between these two concepts?

ResearchAndDevelopmentExpense and capitalised costs

What is the definition for this tag? Is this information about the expense as a component of P&L, or should information relative to the capitalisation of R&D costs also be covered (in which case tags relative to intangible assets would have to be considered)?

InterestIncomeExpense and FinanceIncomeExpense

Although interest income and expense are often included in finance income and cost, there are exceptions (e.g interest income part of revenue).

Should disclosures related to interest income and expenses always be multi-tagged with the disclosure of finance income and cost?
If not, should they be multi-tagged explicitly when it is included?