Should you ask your audit committee to evaluate your XBRL files for completeness, mapping, accuracy and structure under an agreed-upon procedures (AUP) engagement in accordance with the principles and criteria set by the AICPA? I get asked this question all the time, especially by companies whose limited liability is expiring. But everybody should consider AUP for their XBRL.
Why? In the absence of a mandatory audit assurance, an AUP engagement helps ensure that XBRL data brings meaningful value and transparency to the investment community.
Even if your audit committee has adopted a wait-and-see attitude, analysts and investors may be making investment decisions about your company that may be based on substandard and inconsistent data quality. For example, the SEC found several significant and recurring errors by large accelerated filers during the first two months of 2011. The most prevalent data-quality issues revolved around negative values, extended elements and tagging completeness.
Says XBRL US: “In the over 14,900 XBRL submissions to date, over 145,000 data issues have been identified related to the use of the XBRL US GAAP Taxonomy. These inconsistencies include incorrect signs, missing concepts and concepts used incorrectly.“
While a formal AUP is not required, it is best to have a mock AUP environment that ensures compliance of your XBRL-formatted information. A recent trend is for companies to leverage their internal audit function or professional service firm to implement a mock AUP environment to be better prepared for the formal AUP engagement.
What exactly is AUP?
First, an AUP engagement doesn’t deliver an audit opinion. The practitioner performs agreed-upon procedures and assessments, and then reports findings, alternatives and recommendations in a letter to management and the audit committee.
An AUP ensures the completeness, accuracy, proper mapping and structure of your XBRL files. These are the four important aspects of XBRL, according to the AICPA’s latest exposure draft for the XBRL process. Here is what an AUP engagement covers.
Completeness Do you have a procedure to ensure that all required source information is tagged in XBRL? For example, a few commonly missed tags are significant accounting policies embedded throughout footnotes, spelled out amounts and superscript footnotes.
Mapping Even though finding data-quality issues on proper mapping can be aided by software-assisted search and benchmarking analytical tools, at the end of the day, this core process can be subjective: choosing the narrowest tag and assessing materiality can be an art rather than a science. Likewise, the SEC considers mapping to be the most critical part of the XBRL quality control process, but there are no software tools that can detect this type of error prior to filing.
Accuracy Even if common data-quality issues, such as negative values, are flagged by software tools, you still need to assess their validity based on financial facts and the specific circumstances for comparative quarters and year-to-date periods.
Structure Technical validation errors of this type tend to be black-and-white and can be detected by third-party SEC and EDGAR validation tools prior to submission to the SEC.
AUP = quality assurance = market value
Whether you have a built-in versus a bolt-on XBRL solution, you need quality assurance over your XBRL data. Some AUP steps can be accomplished with software tools, while other procedures require professional judgment. Automated tools can only help you so much in highlighting inconsistencies and the usual suspects. Ultimately, you need to tell your company’s story by choosing the tag that best maps to the underlying transaction and translates that fact into meaningful information.
Because investors rely on your XBRL data to make investment decisions, it is ultimately your responsibility to avoid errors before they are disseminated to the public. Aside from compliance, the real benefit of XBRL is increased transparency and comparability, which can in turn increase the value of your stock when the analyst community gains more confidence in your XBRL data.
Learn more about RoseRyan’s XBRL expertise.
