A sustainability report is usually one of many documents an entity will produce disclosing various related information. Here we outline a decision process around allowing / facilitating / discouraging linking between documents and the benefits of different approaches from the point of view of the regulator or other body collecting documents.
Do you want to allow cross-referencing (linking) from the submitted primary document to other documents?
If no:
- Filers will need to duplicate data from their other primary sources such as financial statements.
- Rather than creating duplicate concepts to collect the data, consider allowing filers to report the duplicate data against the same concept as in the primary source. This means the sustainability report will have more than one supporting taxonomy, the sustainability taxonomy and any taxonomies required to support reporting of duplicate data.
- There is still a question of whether the duplicate data has been correctly duplicated from the primary source
- However, there will be no ambiguity as to the meaning of the duplicated data
If yes, will the linking be allowed to other documents supplied with the primary document, other documents previously supplied, anything on the entities official website or to any site on the Internet?
Consider:
- Which documents to allow and how to validate that during submission / acceptance of the disclosure
- What will ensure that the data linked to cannot change?
- What governance issues are there to consider?
- E.g. Different teams preparing different data, different data having different disclosure timelines
- Any particular metadata or styling requirements for external links
- For XBRL target documents, linking to a fact is preferred
What will you do about non-XBRL target documents?
Consider asking for links to be as fine-grained as possible:
- In an HTML document, link to the data item itself
- In a PDF document, note the page number and a further description to help the human reader