NL.NL-KVK.4.4.2.5.extensionTaxonomyLineItemNotLinkedToDesignatedPlaceholder

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Dmitry Mikhed

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Jul 2, 2026, 8:48:24 AM (3 days ago) Jul 2
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Hi all,

I'm getting validation errors from the "Validate NL" plugin for a filing that I believe is actually valid, and I'd like to understand whether the rule's behavior is intentional.

The error:
NL.NL-KVK.4.4.2.5.extensionTaxonomyLineItemNotLinkedToDesignatedPlaceholder — "Line item is not present in the correct definition linkbase placeholder. Ensure line items with only Financial Statements type is in the appropriate placeholder."

The scenario:
The legal entity reports both consolidated and separate financial statements (as required under BW2 Titel 9), with genuinely different values for the same concepts (e.g. bw2-titel9:CashAndCashEquivalents, Assets, Equity, etc.). Because these concepts are tagged with facts using both the Consolidated and Separate members of bw2-titel9:FinancialStatementsTypeAxis, the extension's definition linkbase links them as domain-members under both KVK-designated placeholders: [990010] (consolidated NL-GAAP) and [990020] (separate NL-GAAP).

I looked at the source of rule_nl_kvk_4_4_2_5 (arelle/plugin/validate/NL/rules/nl_kvk.py), and the check requires the concept's set of primary-item ELRs to be an exact match (conceptRoleUris == {requiredRole}) to a single designated role, unless the concept also appears in an extension-defined role. Since [990010]/[990020] are both standard (non-extension) KVK roles, a concept linked to both fails this check.

This seems stricter than what the KVK Reporting Manual (Guidance 4.4.2) actually states — it only says line items must "appear in at least one hypercube" / "participate in at least one hypercube," with no wording requiring exactly one. I also checked the official 2025 conformance suite (conformance-suite-2025-sbr-domein-handelsregister) and found test cases for sibling rules G4-4-2_1 through G4-4-2_4, but there is no G4-4-2_5 test folder and no reference to DesignatedPlaceholder anywhere in the suite.

Arelle's core XBRL 2.1 / XBRL Dimensions 1.0 validation shows no errors for this structure, and using the same primary item under multiple all-hypercube relationships in different extended link roles is a standard, well-established XBRL Dimensions pattern.

My question: is the "exactly one placeholder" requirement in rule_nl_kvk_4_4_2_5 intentional and based on guidance from KVK/SBR-NL beyond what's in the published Reporting Manual, or could this be an overly strict implementation that doesn't account for concepts legitimately reported under both Consolidated and Separate members? If it's intentional, what's the recommended way to structure the definition linkbase for concepts that are genuinely valid — and reported with different values — under both statement types?

Jacques Urlus

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Jul 2, 2026, 10:06:14 AM (3 days ago) Jul 2
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Hi Dmitry,

If this is an SBR Report Package, you should only tag the consolidated financial statements. The separate financial statements should not be tagged. If there is only a separate financial statement present, then this one should be tagged

With an SBR Instance, it is possible to tag both the consolidated and the separate financial statements. However, in this taxonomy there are no designated placeholders ([990010]  and  [990020]) available.

I think there may have been some confusion between the different filing rules and starting points. You're certainly not the first person to run into this.

Regards,

Jacques Urlus
(j.u...@nba.nl)


Op do 2 jul 2026 om 14:48 schreef Dmitry Mikhed <axl...@gmail.com>:
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Dmitry Mikhed

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Jul 2, 2026, 11:00:00 AM (3 days ago) Jul 2
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Thanks for your response, Jacques.

What you’re saying is consistent with my understanding. However, in this particular case, the filing was a consolidated set of financial statements that did not include a consolidated statement of changes in equity. Instead, it contained only a separate statement of changes in equity, and the auditors insisted that this statement should be tagged using the Separate members. We pushed back on this, as it didn’t seem to align with our understanding of the filing rules, but they were quite insistent.

What would your recommendation be in this situation? Would you leave the statement of changes in equity untagged in the SBR Report Package, even though it is included in the published annual report, or would you tag it using the Separate members despite the apparent conflict with the filing rules?

четверг, 2 июля 2026 г. в 17:06:14 UTC+3, jacque...@gmail.com:
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Jacques Urlus

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Jul 2, 2026, 11:17:14 AM (3 days ago) Jul 2
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Hi Dmitry,

I now understand what the situation is. The auditor is correct. But in this case you don’t tag the entire separate statement, but only the part with the changes in equity (with a separate member).

And of course you tag the consolidated statement.

Regards,

Jacques


Op do 2 jul 2026 om 17:00 schreef Dmitry Mikhed <axl...@gmail.com>:
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