What are the ground rules for the SEC's voluntary filing program?

The US Securities and Exchange Commission (SEC) has invested heavily in XBRL. In 2005, the SEC introduced the Voluntary Filing Program (VFP) to test the merits of what they term “Interactive Data”. Under this program, SEC registrants can voluntarily file their periodic financial statements in XBRL format as supplemental exhibits to their official EDGAR filings. Some key features of the program:

  • Companies that participate in the VFP must continue to submit their official EDGAR filings.
  • If a company elects to submit XBRL data, only the complete set of financials (Balance Sheet, Income Statement, Statement of Cash Flows and Statement of Owner’s Equity) must be submitted. Companies may also elect to furnish the notes to the financial statements, management’s discussion and analysis and other elements of the official filing.
  • The XBRL filings must be filed either contemporaneously with or subsequent to, but not before the official EDGAR filing.
  • The XBRL documents must be filed as a supplemental exhibit to the official financial report, or as an exhibit to a filing on Form 8-K or Form 6-K. The XBRL documents should be identified as "Exhibit 100" to the corresponding filing.
  • Registrants are not required to continue filing in XBRL once the first filing is submitted.
  • Registrants may choose to participate in the Interactive Data Test Group, which was established in 2006. Under this program, the company must complete an application, submit XBRL filings for one year and provide feedback on their experience in the program. In exchange for their participation in the test group, the SEC has promised expedited processing of participants registration statements or annual reports.

What are the benefits to companies?