Deciding document linking policy

This article outlines general guidelines for regulators to decide whether to enable linking between the primary sustainability report and other supplied documents.

Regulators prepare the filing manuals to set up how data preparers use links between documents. When preparing a filing manual, regulators should consider if they want to allow linking to the following:

• Documents supplied with the primary document
• Documents previously supplied
• Any site on the Internet

Before you start

Before deciding to enable linking between the primary document and other documents, regulators should consider:

• Are people from your market legally allowed to link to other documents?
• How much cross-referencing is your market expected to do?
• What documents from your market must the data preparers link to?

Guidelines for enabling linking

Regulators should take the following into consideration when enabling linking:

• Define the documents that data preparers can link to and how they should be validated during the submission of the disclosure.
  Data preparers need to know which documents can be linked and how to validate the links. A working validation process is an essential element of the XBRL standard.
• Define how to ensure that the data linked from the primary document cannot change.
  Ensure the linked data does not move or change. This allows data preparers to link to existing documents and be confident that the links will continue to work.
• Define how to manage governance issues.
  For example, how to manage different teams preparing different data or documents, or different data and documents having different disclosure timelines. Explain how different teams should work together to link documents that are still being worked on and how to link to data that is not yet made public.
• When linking to non-XBRL documents, the links should be as fine-grained as possible:
  • For data in an HTML document, link directly to the data item.
    When linking to an HTML document, ensure the link points directly to the data item to avoid any doubt where multiple data items are presented on the web page.
  • For data in a PDF document, add the page number of where the data can be found.
    Provide a more detailed description of the data location to help the human reader.

Guidelines for excluding linking

Regulators should take the following into consideration when excluding linking:

• Define taxonomies that can be used to add data reported in other documents.
  If regulators decide to exclude linking, data preparers will have to duplicate the data that is used in another report.
  For example, to use data from a financial report, a taxonomy author needs to create concepts to report the financial data in the sustainability report. Rather than creating duplicate concepts, regulators can allow data preparers to report the duplicate data against the concept in the taxonomy of the source document. This means the sustainability report will use any taxonomies required to support the reporting of duplicate data. It avoids doubt as to the meaning of the duplicated data.
• When referencing data in non-XBRL documents, the reference should be as fine-grained as possible:
  • For data in an HTML document, provide a link that points directly to the data item.
    When linking to an HTML document, ensure the link points directly to the data item to avoid any doubt where multiple data items are presented on the web page.
  • For data in a PDF document, add the page number of where the data can be found.
    Provide a more detailed description of the data location to help the human reader.