Experiences implementing XBRL

Eurofiling 15th workshop Madrid – 2011-06-01

Eric JARRY

Experiences implementing XBRL

Classification: PUBLIC

Prudential Supervisory Authority

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Banque de France – Secrétariat général de la Commission bancaire SENSITIVITY LEVEL : PUBLIC

Banque de France – ACP (Prudential Supervisory Authority)

Eurofiling workshop2011-06-01

• ACP / Banque de France and XBRL• ACP / Banque de France involvement in CEIOPS / EIOPA• Making XBRL mandatory• Web forms• Excel to XBRL conversion tools• Short introduction to ACP / Banque de France SURFI system

Agenda

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• Before 2007: the French banking regulator, Commission bancaire, bound to Banque de France, uses a proprietary format for the French banking reporting since 1993, BAFI

• 2005-2006: CEBS (now EBA) chooses XBRL for the Basel II / CRD and Financial reporting, COREP and FINREP taxonomies

• 2006: Banque de France decides that XBRL will be the only format accepted for COREP and FINREP data, a new application is developed

• 2008: New French regulations, complete change of the reporting system : SURFI (Unified FInancial Reporting System), all banking reporting for prudential and statistical needs of Banque de France, will be done in XBRL, except two reporting consisting in potentially long list of details, the SURFI taxonomy and SURFI application are developed

• 2010: The French authorities for Banking and Insurance supervision are merged, giving ACP (Prudential Supervisory Authority), bound to Banque de France

• EBA uses another implementation of the SURFI sytem, IPEBA – IT Platform for EBA. EBA accepts XBRL, XML and CSV reports for KRI (Key Risk Indicators) data

Banque de France and XBRL

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• 2010: In CEIOPS (now EIOPA), ACP promotes the use of XBRL and develop the Solvency II taxonomy, using an evolution of the tools used to generate the SURFI taxonomy

• 2011: Decision of EIOPA to use XBRL for the reporting, from undertakings to NSAs and from NSAs to EIOPA

• Legal difficulties, it may be not possible to impose a format to undertakings… EIOPA may only impose the format for the reporting (from NSAs) to EIOPA…

• Decision in EIOPA to use Data Point Modelling methodology to define all characteristics of each data point, but to define two layers of the taxonomy– Moderately dimensional: to keep the primary items defined by

business experts – Highly dimensional: to express all characteristics as dimensions

to be used in instances

Banque de France involvement in CEIOPS / EIOPA

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What?

– New reporting (e.g. COREP / FINREP or Solvency II)• new IT system (or important refactoring)

• budget may be used to modernize the system and use the format dedicated to financial reporting: XBRL

– Software providers may provide common solutions across Europe

– Using XBRL may simplify the life of cross-border (multi-country) or cross-sector (banking and insurance) institutions

– XBRL taxonomies are used to describe the reporting (dictionary)• not using XBRL would lead to conversion costs for every version of

the reporting

Making XBRL mandatory

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How?– Implication of XBRL France

• Creation of a new group (Banking in 2006, Insurance in 2011)

• First meetings open to everybody (not members)

• Organization of trainings

• Existence of a Technology group to discuss issues

– Use of a IT stakeholders group in ACP• Meetings to presentation of the taxonomies and discussions

• Technical meetings organized

– No tools provided by ACP• Web Forms introduced in 2010 by OneGate, the portal, rarely used

• No Web Forms anticipated for Insurance reporting, but EIOPA intends to provide a tool for small undertakings


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So?– No major difficulties encountered

• All taxonomies: SURFI, COREP and FINREP taxonomies include assertions (XBRL formula) since 2010

• Some software provider use available XBRL processing engines

• A software provider has developed its own XBRL processing engine, including formula processing

• Some software providers developed ad hoc solutions (not generic) to validate XBRL and assertions

• Few institutions developed ad hoc converters to XBRL=> few errors are still strange (meaning that instances are not validated at reporting side)


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What is missing?

– Commonalities between taxonomies– Defining the reporting format is not enough for a common

solution, differences will be in:• Communication protocols

• Security options (e.g.: digital signature and relevant options)

• Format and contents of the errors notifications (XBRL and other errors, like “Deadline not met”)

– ACP uses Excel to report assertions errors (Excel spreadsheets are always returned to filers, containing the data sent)

– In ACP taxonomies, each assertion has an identification, a label and is associated to satisfied and not satisfied messages


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• Give to each assertion:• A clear label expressing the check: xxxx shall be xxxx• A code

Appreciated practice

Solvency II assertions

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Generic messages / labels

Escaped XML element

UBmatrix XPE

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• Applicable only to small set of data– Will certainly not be implemented for Solvency II reporting in

ACP• May be a way to view the data sent to the regulator

– But ACP sends back Excel sheets containing the data and showing the errors

• May be a way to correct (slightly) invalid reports

• Imply a cost to create forms from taxonomy / regulatory templates– The Table linkbase will help

• May be used for the signature of reports for small filers (view the reported data, then sign)

Web forms

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• Some small filers use solutions based on Excel (specially in the insurance sector)

• An Excel to XBRL conversion tool may be an alternative to Web forms (some offers provide both solutions)– Possibility to fill the forms with Excel API (e.g.: ActiveX)

Excel to XBRL conversion tools

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A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

SMTPSMTP

HTTPHTTP

TransferTransferprotocolprotocolss

Web dataWeb dataentryentry

Taxonomies

XBRLXBRLvalidatiovalidatio

nn(not (not

formula)formula)

FileFiletransfertransfer

Webforms

FormsFormshandlinghandling

SignatureSignature

EncryptionEncryption

AuthenticationAuthenticationAuthorizationAuthorization

Certificats mgtCertificats mgt

SecuritySecurity

TimestampingTimestampingConversionsConversions

(IPEBA)(IPEBA)

OneGateOneGate

Other flowsOther flows

MessagesMessages

ExcelExcel

XBRLXBRL

XMLXMLCSVCSV

SURFISURFI

XBRLXBRLvalidatiovalidatio

nn(with (with

formula)formula)

Due timeDue timemanagementmanagement

OutputOutputprocessingprocessing

Registry

RegistryRegistryApplicationApplication

Taxonomies

Reportingdatabase(XBRL)

ViewsViewsgenerationgeneration

ExcelExcel

XBRLXBRL

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

ExcelExcel

MessagesMessages

Instances Instances and errors and errors processingprocessing

XMLXML

ExcelExcel

PDFPDF

OtherOtherapplicationsapplications

Common portal of Banque de FranceCommon portal of Banque de France(from National Bank of Belgium)(from National Bank of Belgium)

Synoptic view of the SURFI system

XBRLXBRL

XMLXML

CSVCSV

EDIEDI

FormsFormsgenerationgeneration

SASSASApplicationApplicationXBRLXBRL

XMLXML

KRI instances (to EBA)KRI instances (to EBA)

XBRLXBRL

XBRLXBRL

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Thank you

Any questions?

Documents

Experiences implementing XBRL