The SEC has removed Inline XBRL tagging requirements from several market-intermediary forms and submissions. The underlying reports still matter, and the relief is narrower than a general rollback of structured-data filing.
Updated September 26, 2026: This article retains its complete original text, with researched updates integrated into the relevant sections.
The Securities and Exchange Commission’s September 11, 2026 exemptive order removes Inline XBRL requirements from specified market-intermediary forms and reports. The Commission announced the action on September 14 in Release 2026-88.
The order is narrow. It changes a structured-data format requirement. It does not excuse the underlying filing or submission, and it does not exempt covered materials from electronic submission on EDGAR. It also preserves Inline XBRL for two financial-statement exhibits. Teams should update the formatting layer of their workflow without weakening content, approval, timing, or retention controls.
The covered forms are specific
The relief applies to 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 under Exchange Act Rule 15Fk-1(c).
The 2024 amendments had required Inline XBRL for specified portions of Form CA-1, specified portions of Form 1, Form X-17A-5 Part III, Item 4 of Form 17-H, and the annual compliance report of a security-based swap entity. The new order removes that requirement for the covered Form CA-1 materials other than Exhibit H, for the covered Form 1 materials other than Exhibit I, and for the other covered submissions. National securities exchanges use Form 1. Broker-dealers and specified security-based swap entities use Form X-17A-5 Part III. Certain larger broker-dealers file Form 17-H. Security-based swap entities submit the chief compliance officer report. The order also extends relevant relief to security-based swap entities relying on substituted-compliance orders for Form X-17A-5 Part III and the CCO report.
Two exceptions deserve prominent workflow rules. Exhibit H to Form CA-1 contains certified financial information and remains subject to Inline XBRL. Exhibit I to Form 1 contains audited financial statements and also remains subject to Inline XBRL. A filing team that removes tagging from an entire package could therefore create a defect even while attempting to implement the relief.
The SEC has granted targeted relief from several Inline XBRL requirements that were adopted as part of its 2024 electronic-submission reforms.
For compliance teams, the key question is not whether Inline XBRL is "gone." It is which workflows no longer require Inline XBRL and which obligations remain.
What the SEC exempted
The September 11, 2026 order grants relief from Inline XBRL filing or submission requirements for:
- Form CA-1, other than Exhibit H;
- Form 1, other than 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 explained that these submissions are primarily used to assess whether registered market intermediaries meet legal, financial, operational, and other regulatory standards.
Why the Commission changed course
The Inline XBRL requirements came from amendments adopted in December 2024 that required electronic submission and, for some materials, structured data. Inline XBRL attaches machine-readable metadata to information so it can be retrieved, aggregated, and compared.
The Commission concluded that the benefits were limited for the specified forms. Much of the information is individually tailored, several materials are generally nonpublic, and Form X-17A-5 Part III already involves existing data processes. The Commission also cited industry information indicating that implementation costs were higher than previously estimated. Under Exchange Act Section 36(a)(1), it found the relief necessary or appropriate in the public interest and consistent with investor protection.
Those findings explain the scope. They do not establish that Inline XBRL is generally unnecessary or relieve public companies, funds, or other filers from unrelated structured-data rules.
Why the SEC changed course
The Commission said the relief is expected to reduce compliance costs without meaningful loss of transparency or data accessibility for investors.
That rationale is particularly relevant because the affected submissions are directed principally to regulatory oversight of intermediaries rather than ordinary investor-facing company disclosure.
Convert the order into a form-by-form control matrix
The first implementation step is an inventory of every filing affected by the December 2024 amendments. For each form, the owner should record the filer type, rule citation, filing event, due date, EDGAR submission type, document components, Inline XBRL status after the order, and any preserved exception.
That matrix should drive filing-provider instructions. A general email saying “XBRL is no longer required” is too broad. Written change tickets should identify Form CA-1 and Form 1 exceptions, confirm that electronic EDGAR submission continues, and state the effective configuration date. If a vendor supports multiple clients or forms, the institution should ask how it prevents relief for one submission from changing another.
Templates and validation scripts should be versioned. Removing Inline XBRL may affect preparation software, package assembly, preflight checks, naming conventions, and internal evidence. Teams should retire only tests that enforce the relieved requirement. Checks for complete exhibits, signatures, dates, financial statements, EDGAR acceptance, and content consistency still matter.
The exceptions matter
The relief for Form CA-1 does not extend to Exhibit H.
The relief for Form 1 does not extend to Exhibit I.
Those carve-outs should be reflected in filing checklists and vendor specifications so a broad "XBRL relief" label does not cause overcorrection.
Preserve legal and financial ownership
Structured-data production often sits between legal, finance, compliance, and an external filing agent. The relief may reduce tagging work, but it should not move substantive accountability to the vendor. Form X-17A-5 Part III still reports financial and operational condition. Form 17-H still supports risk assessment. A security-based swap entity’s CCO report still addresses the effectiveness of policies and procedures, material changes, improvement areas, material noncompliance, and resources.
Approval records should show that the filing owner confirmed both applicability and continuing obligations. For Form CA-1 and Form 1, the approver should verify that the preserved financial exhibit received the required tagging. For recurring reports, the first filing under the revised process should receive an enhanced quality-control review.
The institution should also retain the order, applicability analysis, vendor communication, configuration evidence, test results, final submitted package, and EDGAR acceptance. That record explains why a previously tagged submission is now untagged and shows that the change was deliberate.
What firms should do now
Covered firms should:
- update filing calendars and procedure manuals;
- identify exactly which forms and exhibits are covered;
- confirm vendor configurations;
- remove unnecessary Inline XBRL production steps only where the order applies;
- preserve controls for any remaining structured-data requirements;
- document the effective workflow change and the authority supporting it.
The safest implementation is form-by-form, not a blanket instruction to stop using Inline XBRL.
Test the transition at package level
A controlled test should assemble a representative package for each affected form. Reviewers should confirm that relieved components contain no unintended tagging dependency, preserved exhibits remain tagged, readable documents render correctly, and EDGAR validation succeeds. The comparison should focus on both machine and human use.
After the first production filing, teams should reconcile the accepted package against the authorized version and monitor SEC or vendor feedback. They should also update procedure manuals, calendars, responsibility charts, and training. Historical filings should not be altered merely to create visual consistency.
Internal audit or compliance testing can sample later submissions to confirm that the narrow exception has not spread into unrelated filing types or preserved exhibits.
The order offers targeted operational relief, not a holiday from regulatory reporting. The safest implementation removes an unnecessary format step while preserving every substantive owner, deadline, exception, and filing receipt.
Determining whether the relief changes your firm’s filing process? Contact Braeden Anderson to discuss applicability, continuing obligations, and coordination among legal, finance, and filing providers. Review your regulatory filing workflow.
September 2026 researched developments
September 26, 2026 researched update: The following developments supplement the original article where the current research did not map cleanly to an existing section.
What the order does not do
The order does not erase the forms themselves.
It grants relief from specified Inline XBRL requirements.
Firms should therefore distinguish among three separate questions:
- Is the report still required?
- Must it still be filed or submitted electronically?
- Must it be tagged in Inline XBRL?
The September order principally changes the third question for the covered items.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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