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IBM Canada Ltd/

Please provide your views on the proposed XBRL taxonomy (intended to form the basis for supervisory data transmission between competent authorities and the EBA) and supporting documentation, and in particular on the technical expression of the ITS data point model in XBRL.
Filing Indicators.

The use of the non-standard find:fixed attribute on filing indicators to indicate omitted templates is an unfortunate departure from using standardised XBRL. While not illegal, since XBRL allows for application specific attributes in non-XBRL-standard namespaces such as this, it presents unnecessary complexities for software developers. It requires them to make specific modifications to their software that are relevant for this filing regime only, thereby moving away from the philosophy of adopting a global standard.

It is doubly unfortunate since a standard approach is perfectly possible. allowing find:filingOmittedIndicator elements in the find:fIndicators tuple to indicate the same thing would be one such approach.

We encourage the EBA to consider making this modification to the taxonomy in order to achieve better adherence to standardised approaches.
Contact name
Hugh Wallis