Inline XBRL requires filers to embed XBRL data directly into an HTML document. As noted in our August 15, 2018 Advisory, operating companies and funds, on a phased-in basis, will be required to use Inline XBRL for the submission of financial statement and fund risk/return summary information, embedding a part of their interactive data file within an HTML document, and including the rest in a related exhibit.

For operating companies, the first phase-in period applies to large accelerated filers that prepare their financial statements in accordance with US GAAP, and commences with the first Form 10-Q for a fiscal period ending on or after June 15, 2019 (thus including 2019 second-quarter filings for large accelerated filers with a calendar year-end). The exhibit index of the filing must include the word "Inline" in the title description for any XBRL-related exhibit. In addition, and as noted in our April 4, 2019 Advisory, all of the information on the cover page of the Form 10-Q must be tagged using Inline XBRL, and the filing must include a "Cover Page Interactive Data File" containing cover page data. Note that the Form 10-Q cover page has recently been revised to include the title of each class of registered securities, each exchange on which such securities are registered, and the applicable trading symbol.

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