SEC Exempts Intermediary Forms and Reports From Inline XBRL Tagging

The U.S. Securities and Exchange Commission announced on Sept. 14, 2026, that it issued an order granting exemptive relief from certain Inline XBRL requirements the Commission adopted on Dec. 16, 2024. The order, Release No. 34-106339, is dated Sept. 11, 2026. It relieves covered registrants from filing or submitting the following in Inline XBRL: Form CA-1, except Exhibit H; Form 1, except Exhibit I; Form X-17A-5 Part III; Form 17-H; and the annual compliance report of a security-based swap dealer or major security-based swap participant.

The Commission issued the order under Section 36(a)(1) of the Securities Exchange Act of 1934, which authorizes it to conditionally or unconditionally exempt any person, security, or transaction from provisions of the Exchange Act or its rules to the extent the exemption is necessary or appropriate in the public interest and consistent with the protection of investors. The order states that the Commission found the relief satisfies that standard. Sherry R. Haywood, Assistant Secretary, signed the order.

Forms and Reports Covered by the Relief

Form CA-1 is the application for registration, for amendment to registration, or for exemption from registration filed by clearing agencies, and it is used to assess those applications and amendments. The relief extends to clearing agencies with respect to that form. Form 1 is the corresponding application filed by national securities exchanges, used to assess applications for, and amendments to applications for, registration as a national securities exchange or exemption from registration; the relief extends to self-regulatory organizations with respect to Form 1.

Form X-17A-5 Part III contains annual reports filed by broker-dealers, including over-the-counter derivatives dealers, and by security-based swap dealers and major security-based swap participants, collectively SBS Entities, for which there is no prudential regulator. The form is used to assess the financial and operational condition of broker-dealers. Form 17-H is the risk assessment report filed by certain larger broker-dealers subject to Exchange Act Rule 17h-2T.

The annual compliance report, referred to in the order as the CCO report, must be prepared and signed by an SBS Entity’s chief compliance officer under Exchange Act Rule 15fk-1(c). Under that rule, the report must contain, at a minimum, an assessment of the effectiveness of the firm’s security-based swap policies and procedures, material changes to those policies and procedures, areas for improvement and recommended potential changes to the compliance program and its resources, material non-compliance matters identified, and the compliance resources dedicated to the firm’s security-based swap business.

The relief carves out Exhibit H to Form CA-1 and Exhibit I to Form 1. Exhibit H contains a balance sheet and a statement of income and expenses, with all notes and schedules, as of the registrant’s most recent fiscal year for which the information is available, certified by an independent accountant; it must still be filed in Inline XBRL. Exhibit I contains the applicant’s audited financial statements and likewise remains subject to the Inline XBRL requirement.

The order also extends the relief to SBS Entities relying on a Commission order granting substituted compliance, with respect to Form X-17A-5 Part III and the CCO report. It does not exempt any filer from the requirement to file or submit these forms and reports electronically on EDGAR.

Rationale Stated in the Order

Inline XBRL is a structured data language in which data in documents can be tagged so machines can read the tags, a function intended to enable more efficient retrieval, aggregation, and comparison across different filers and time periods than an unstructured document allows, the order explains. While useful to many parties, Inline XBRL primarily helps financial institutions and regulators analyze data, and the order states it is less useful for the specified forms. Those forms are specific to market intermediaries and are primarily used by the Commission to assess whether a registered entity meets the legal, financial, and operational standards necessary to comply with the Exchange Act.

Many of these filings contain individually tailored information, so standardized tags can be relatively less useful and, in the case of Form X-17A-5 Part III, duplicate existing processes, the order states. It adds that since the amendments were adopted, the Commission has received information from industry participants indicating that the cost of complying with the Inline XBRL requirement is higher than the Commission previously estimated. The order cites a March 13, 2026, letter from Kyle L. Brandon, managing director and head of derivative policy at the Securities Industry and Financial Markets Association.

The order further states that reducing compliance costs for Form X-17A-5 Part III, Form 17-H, and the CCO report would not impact investors, because those forms are not primarily used by investors and several are generally non-public. As a general matter, the entirety of Form 17-H and the CCO report, and the vast majority of Form X-17A-5 Part III, are non-public. A reduction in compliance costs would instead enable affected firms to allocate resources more efficiently, including to support or enhance their operations and existing compliance obligations, the order states.

The Commission said the exemptive relief is expected to reduce potentially significant unnecessary compliance costs, which firms may ultimately pass on to investors through higher fees, without meaningful gains in transparency or data accessibility to investors. “This exemptive order – which provides commonsense relief without sacrificing investor protection – will reduce compliance costs and enable market participants to more efficiently allocate resources, including to support or enhance their operations and existing compliance obligations,” SEC Chairman Paul S. Atkins said. “This action furthers the Commission’s efforts to transform our rulebook by trimming immaterial requirements that burden the market without materially benefitting investors.”

The underlying requirements trace to rule amendments the Commission adopted on Dec. 16, 2024, in Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report, Exchange Act Release No. 101925, published at 90 FR 7250 on Jan. 21, 2025. Those amendments required certain forms and submissions to be filed electronically and designated several for Inline XBRL: Schedule A and Exhibits C, F, H, J, K, L, M, O, R, and S to Form CA-1; Exhibits D, E in part, and I to Form 1; Form X-17A-5 Part III; Item 4 of Form 17-H; and the CCO report.