The SEC has adopted a pay ratio disclosure rule – Item 402 of Reg S-K – requiring public companies to disclose:
- The annual total compensation of the CEO
- The median of the annual total compensation of all employees other than the CEO
- The ratio of these amounts
The SEC has provided a transition period: generally most issuers will first be required to include their pay ratio disclosure in 2018, or later in the case of companies that are new SEC registrants. The initial pay ratio disclosure will be required with respect to compensation for a company’s first full fiscal year that begins on or after January 1, 2017. And XBRL will have a role.
Say-on-Pay data tagging using XBRL
The SEC has also stated that the disclosure provided, including footnotes, be XBRL tagged. This is the first instance that XBRL tagging would be required for data outside the financial statements.
For a direct dialog with the SEC on this, you are invited – FREE – to join an open webinar with Mike Willis, the SEC’s Assistant Director, Office of Structured Disclosure, Division of Economics and Risk Analysis (& XBRL guru) in his discussion with XBRL US member Gordon Ruckdeschel, VP, Operations at Vintage.
- Wednesday, January 27 ~ 3:00 PM ET
- LOG IN HERE
- This event is free to participants but CPE credit can be obtained for $49
The conversation will include the status of the current program for XBRL reporting by public companies and other initiatives in the works:
- Is the SEC using XBRL data?
- How is XBRL data quality?
- What enhancements to the existing program are under consideration, including inline XBRL?
- And how does structured data factor into upcoming SEC rule proposals like executive compensation and investment company disclosures?
Find out about the SEC’s Disclosure Effectiveness initiative which is considering way to improve disclosure requirements in Regulation S-K and Regulation S-X, to benefit both companies and investors.