Form SD Files Dataset

The Form SD Files Dataset is a complete EDGAR archive of every Form SD and Form SD/A specialized disclosure report filed under the Securities Exchange Act of 1934 since the form went into effect. Each record represents one EDGAR accession — a single Form SD or Form SD/A submission filed by one issuer on one date — bundled with a metadata.json manifest and the textual filing documents from the original submission. Form SD itself is the cover form for two distinct Dodd-Frank disclosure regimes administered by the SEC: Rule 13p-1 conflict-minerals disclosures (Section 1502 of Dodd-Frank) and Rule 13q-1 resource-extraction payment disclosures (Section 1504). The dataset's earliest sample date is April 1, 2014, corresponding to the first Form SD filings made for calendar-year 2013 conflict-minerals reporting, and it covers every issuer subject to either rule from that point forward. Containers are distributed as monthly ZIP archives holding HTML, JSON, TXT, and PDF payloads.

Dataset APIs

Dataset Files

What This Dataset Contains

The dataset captures every Form SD and Form SD/A filing submitted to EDGAR from April 2014 to the present. Form SD is a specialized disclosure report filed pursuant to Rule 13p-1 and Rule 13q-1 under the Securities Exchange Act of 1934, both promulgated under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Rule 13p-1, mandated by Section 1502 of Dodd-Frank, requires issuers whose products contain tin, tantalum, tungsten, or gold ("3TG" conflict minerals) necessary to functionality or production to disclose whether those minerals originated in the Democratic Republic of the Congo or an adjoining country, and to attach a Conflict Minerals Report when triggered. Rule 13q-1, mandated by Section 1504 of Dodd-Frank, requires resource extraction issuers engaged in the commercial development of oil, natural gas, or minerals to disclose payments made to the U.S. federal government and to foreign governments. Form SD/A filings are amendment counterparts used to correct, restate, or supplement a previously submitted Form SD.

For each accession number the dataset includes a metadata file and all documents in the original EDGAR submission except image files. Each filing typically contains the issuer's conflict-minerals disclosure, an attached Conflict Minerals Report describing due diligence measures and the source and chain of custody of applicable minerals, or — for resource extraction issuers — payment information organized by project, type, and government recipient. Records are organized as accession-numbered folders inside year/month ZIP containers and are distributed in HTML, JSON, TXT, and PDF formats; in practice modern Form SD filings consist almost exclusively of HTM/HTML documents plus the JSON manifest, with PDF and TXT payloads appearing rarely in older or unusually formatted submissions.

Content Structure of a Single Record

What one record represents

One record in the Form SD Files dataset is a single EDGAR accession — that is, one Form SD or Form SD/A submission filed by a single issuer on a specific date — packaged as an accession-numbered folder inside a year/month ZIP container. The folder is named with the 18-digit, dash-stripped accession number (for example 000143774925038455) and bundles the textual filing documents that comprise the submission together with a metadata.json describing the accession and the filer. The unit is therefore the filing as a whole, not a single exhibit, a single payment row, or a single conflict-mineral disclosure paragraph; an issuer that files an annual Form SD and later submits an amending SD/A contributes two independent records.

What the underlying filing is

Form SD is the cover form that introduces these disclosures; the substantive content lives partly on the cover form and partly in attached exhibits. The form is structured around three operative items:

• Item 1.01 — Conflict Minerals Disclosure. The issuer states, after a reasonable country-of-origin inquiry, whether any conflict minerals in its products originated in covered countries, and provides the address of an internet site where the disclosure is publicly available.
• Item 1.02 — Exhibit. Directs the issuer to file a Conflict Minerals Report as Exhibit 1.02 when one is required.
• Item 2.01 — Resource Extraction Issuer Disclosure. Under Rule 13q-1, the payment data must be filed as Exhibit 2.01 in inline XBRL format.

Item 3 lists the exhibits accompanying the form. The form closes with a signature block executed under Section 13 of the Exchange Act by an authorized officer.

Content layers of a single record

A single accession folder contains three concentric layers of content: an outer manifest layer (metadata.json), an EDGAR SGML document-wrapper layer surrounding each filed document, and the inner HTML and inline-XBRL bodies that carry the actual disclosure text and structured data.

The metadata.json manifest

Every accession folder carries one metadata.json, a single JSON object that catalogs the submission and the filer. Its top-level fields are:

• formType — "SD" or "SD/A".
• accessionNo — the dashed EDGAR accession (for example "0001437749-25-038455"); the folder name is the same identifier with the dashes removed.
• description — human-readable form name, typically "Form SD - Specialized disclosure report".
• filedAt — ISO-8601 timestamp with timezone offset capturing the EDGAR acceptance moment.
• linkToFilingDetails, linkToTxt, linkToHtml, linkToXbrl — EDGAR URLs to the primary document, the consolidated SGML submission text file, the filing index page, and (when applicable) the inline-XBRL viewer. linkToXbrl is generally empty for Form SD because the inline-XBRL payload, when present, is embedded inside Exhibit 2.01 rather than published as a standalone XBRL document.
• id — a 32-character hex hash that uniquely identifies the record internally.
• seriesAndClassesContractsInformation — array, generally empty for Form SD because the form does not pertain to investment-company series and classes.
• documentFormatFiles — an ordered array, one element per document in the original EDGAR submission, including the form body, every exhibit, every graphic, and the trailing complete-submission text file. Each element carries sequence (the SGML sequence number, or " " for the wrapping .txt), size (byte size as a string), documentUrl (EDGAR URL — for inline-XBRL exhibits the URL points at the ix?doc= viewer), description (for example "FORM SD", "EX-2.01", "EXHIBIT 99.1", "GRAPHIC", "Complete submission text file"), and type (the <TYPE> token from the SGML header — "SD", "EX-2.01", "EX-99", "GRAPHIC", or " ").
• dataFiles — a parallel array for XBRL artifacts. For Form SD this is populated only when an Exhibit 2.01 payments exhibit is filed, and typically contains the inline-XBRL instance (type: "EX-2.01.INS"), the taxonomy schema (type: "EX-2.01.SCH"), and the extracted XBRL instance (type: "XML").
• entities — an array of filer entity objects, almost always of length one. Each entity carries companyName (usually suffixed with (Filer)), cik, irsNo, fileNo, filmNo, act (typically "34"), type (the form type as recorded in the EDGAR header), stateOfIncorporation (two-letter state or country code), fiscalYearEnd as MMDD, sic (the four-digit SIC code with its industry description), and tickers (an array of trading symbols associated with the issuer).

The SGML document wrapper

Each document in the folder is preserved with its EDGAR SGML envelope intact — the same wrapper that appears inside the consolidated complete-submission .txt on EDGAR. The envelope opens with <DOCUMENT> and contains <TYPE>, <SEQUENCE>, <FILENAME>, <DESCRIPTION>, and <TEXT> lines before the inner HTML body. The <TYPE> token is the authoritative role indicator:

• SD — the Form SD body itself.
• EX-1.02 — the Conflict Minerals Report.
• EX-2.01 — the resource-extraction payments exhibit (inline XBRL).
• EX-99 (often EX-99.1) — supplemental conflict-minerals attachments such as supplier lists, smelter rosters, or supporting graphics.
• GRAPHIC — image documents catalogued in the manifest but not redistributed.

The <SEQUENCE> value matches the sequence field in metadata.json, so the manifest and the on-disk wrappers can be cross-referenced one-to-one.

The HTML and inline-XBRL bodies

Inside the SGML wrapper, each document is a self-contained HTML file. The Form SD body is a narrative HTML document with a cover page identifying the registrant, the reporting period, and the address of the principal executive offices, followed by the checked items (1.01, 1.02, 2.01 as applicable), the disclosure text, an "Item 3 - Exhibits" listing, and a signature block. Conflict-minerals exhibits are typically narrative HTML documents that read as legal-style reports. The Exhibit 2.01 resource-extraction payments exhibit is an inline-XBRL document — an XHTML root that opens with an XML declaration, declares the rxp (resource-extraction payments) namespace, and uses <ix:header>, <ix:nonNumeric>, and <ix:nonFraction> tags to mark up project names, government recipients, country, payment categories (taxes, royalties, fees, production entitlements, bonuses, dividends, infrastructure improvement payments), payment amounts, currencies, and resource types.

Component-by-component breakdown

The Form SD body (<TYPE>SD)

The SD body is always present, always sequence 1, and always identifies the registrant, the reporting period, and the items being addressed. Its substantive content is conditional on which rule the filer is reporting under:

• A Rule 13p-1 filer (conflict minerals) checks Item 1.01 and supplies the country-of-origin determination — typically a brief statement that conflict minerals were or were not necessary to the functionality or production of products manufactured or contracted to be manufactured during the calendar year, the conclusion of the reasonable country-of-origin inquiry, and the URL of the issuer's public website where the conflict-minerals disclosure is hosted. When a Conflict Minerals Report is required, Item 1.02 references it as Exhibit 1.02.
• A Rule 13q-1 filer (resource extraction) checks Item 2.01 and references Exhibit 2.01, which carries the structured payment table. The body itself contains comparatively little narrative for these filers; the substance lives in the inline-XBRL exhibit.
• Item 3 lists the exhibits filed with the form. The signature page closes the document, dated and signed by an authorized officer.

Exhibit 1.02 — Conflict Minerals Report

When required, Exhibit 1.02 is the Conflict Minerals Report itself: a narrative legal/operational report describing the design and execution of due diligence on the source and chain of custody of conflict minerals, conformed to a nationally or internationally recognized framework — in practice the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Typical sections include:

• Description of the issuer's products containing 3TG and the role of those minerals.
• Reasonable country-of-origin inquiry summary.
• Supply-chain due diligence steps taken under the OECD framework's five-step structure (management systems, risk identification and assessment, risk-management strategy, third-party audits where applicable, and reporting).
• Identified smelters and refiners, often with country of location and conformance status under industry programs such as the Responsible Minerals Assurance Process (RMAP).
• Mitigation efforts, supplier engagement, and risk-management actions taken or planned for subsequent reporting periods.

For periods up to and including the 2013 reporting year, the report had to be accompanied by an Independent Private Sector Audit (IPSA) of the due diligence framework when the issuer described products as "DRC conflict free." In practice the audit obligation effectively fell away after the 2014 District of Columbia Circuit decisions on the rule, and IPSA reports are now uncommon.

Exhibit 2.01 — Resource Extraction Payments

Exhibit 2.01, where present, is an inline-XBRL document containing the structured payment disclosure required by Rule 13q-1. The payments are organized at the project level and disaggregated by category, government recipient (with country), and resource. Each tagged data point indicates:

• The payment amount, in the issuer's reporting currency, often with USD equivalents.
• The payment type: taxes, royalties, fees (including license, rental, and concession fees), production entitlements, bonuses, dividends, payments for infrastructure improvements, and community and social responsibility payments where required.
• The project name and project-level identifiers.
• The resource extracted (oil, natural gas, or specific minerals).
• The recipient government, including subnational and federal levels where applicable.

The XBRL markup enables extraction of every payment row as structured data without parsing the rendered narrative tables.

Exhibit 99 attachments

EX-99 files (commonly EX-99.1) appear when issuers attach supplemental materials such as supplier or smelter lists, mineral-flow diagrams, due-diligence framework citations, or related graphics. These are HTML wrappers that may reference image files (logos, signature scans, flow charts) which themselves are not included in the dataset.

The complete-submission text file

Every record's manifest also lists a trailing complete-submission .txt file (sequence " ", type " "), which on EDGAR is the concatenated SGML container holding all submission documents in one stream. The manifest records its size and URL but the file itself is not redistributed because its content is the union of the wrapped HTM documents that are already included.

What is included in a record

Each record bundles metadata.json and the textual documents from the original EDGAR submission — at minimum the Form SD body, plus any HTM-format exhibits (EX-1.02, EX-2.01, EX-99.x). The SGML headers around each document are retained, so document role, sequence, and description can be read directly from the file. The HTML payloads preserve original formatting, tables, footnotes, and inline-XBRL markup (in the case of Exhibit 2.01).

What is excluded or kept separate

• Image files. GRAPHIC documents (such as .jpg logos, signature scans, and embedded chart images) referenced by the SGML wrapper are catalogued in documentFormatFiles but are not redistributed inside the ZIP. Their original EDGAR URLs remain available via documentUrl.
• Ancillary XBRL artifacts. The .xsd taxonomy schema and the extracted _htm.xml or .xml XBRL instance documents that EDGAR publishes alongside Exhibit 2.01 are catalogued under dataFiles but are not redistributed; the inline-XBRL payload remains accessible because it is embedded inside the EX-2.01 HTM file that is included.
• Complete-submission .txt. Referenced in the manifest but not redistributed for the reason given above.
• Off-EDGAR website material. The conflict-minerals disclosure URL cited in Item 1.01 points to material hosted on the issuer's own website; that off-EDGAR copy is not part of the record and is not guaranteed to remain accessible over time.

Changes in required content over time

The Form SD record structure has shifted materially in response to litigation and rulemaking since the form went into effect in 2014:

• April 2014 to mid-2014. The first Form SD filings were due 2 June 2014 for calendar year 2013 conflict-minerals disclosures. As originally adopted in 2012 (Release 34-67716), Rule 13p-1 required issuers describing products as "DRC conflict free" to obtain an IPSA of the Conflict Minerals Report. The 2014 D.C. Circuit decision in National Association of Manufacturers v. SEC held that the compelled "not been found to be DRC conflict free" labeling violated the First Amendment. The SEC's April 29, 2014 statement and subsequent guidance suspended portions of the rule: issuers no longer needed to make conflict-status descriptions and, correspondingly, the IPSA requirement effectively fell away. Records from 2014 onward therefore tend to omit the IPSA attachment and use neutralized language in Item 1.01 and the Conflict Minerals Report.
• 2012 / 2013 / 2016 — Resource extraction rule iterations. The original Rule 13q-1 was adopted in 2012, vacated by the District of Columbia federal court in 2013, re-adopted in 2016 (Release 34-78167), and that re-adopted rule was disapproved by Congress under the Congressional Review Act in February 2017. As a consequence, no Exhibit 2.01 payments exhibits exist in the dataset for periods between 2014 and the 2020 re-adoption. Form SD records during that window are conflict-minerals-only.
• December 2020 onward — Final Rule 13q-1 (Release 34-90679). The SEC adopted a third version of the resource-extraction rule, with reporting beginning for fiscal years ending on or after 30 September 2024 in most cases (with extended transition periods for certain issuers). Records from 2024 onward begin to include Exhibit 2.01 inline-XBRL payments tables built around the project-level, government-recipient, payment-category schema described above. Exhibit 2.01 exhibits are filed under the Commission-prescribed XBRL taxonomy for resource-extraction payments (rxp).

The Item structure of the form itself (1.01 / 1.02 / 2.01 / 3) has remained stable across these regulatory shifts; what has changed is which items carry substantive content and which exhibits accompany the body.

Changes in data format over time

Form SD entered effect in 2014, well after EDGAR's transition away from ASCII-only filing, so every record in the dataset is filed in HTML wrapped in the EDGAR SGML envelope. There is no ASCII or paper era to account for. The principal format evolution within the dataset concerns the resource-extraction exhibit:

• 2014 through 2023. Records consist of the Form SD body in HTML, optionally accompanied by HTML conflict-minerals reports and HTML EX-99 attachments. No XBRL is present, since Item 2.01 had no operative reporting requirement during this window.
• 2024 onward. Resource-extraction filers begin attaching Exhibit 2.01 as an inline-XBRL document using the SEC's Resource Extraction Payments (rxp) taxonomy. From this point forward, records that include EX-2.01 also carry dataFiles entries describing the inline-XBRL instance and schema, and the EX-2.01 HTM file itself contains the structured <ix:*> markup that allows machine extraction of every payment row.

Interpretation notes

• Amendments. A formType of "SD/A" indicates a Form SD amendment. SD/A records are full filings in their own right (with their own accession number, manifest, and document set) rather than diffs against the prior filing; reconstructing the amendment trail requires linking SD and SD/A records by issuer, period, and filedAt chronology.
• Item conditionality. Because Items 1.01/1.02 (conflict minerals) and Item 2.01 (resource extraction) address two independent regulatory regimes, a single Form SD typically activates only one of them. Issuers subject to both regimes file a single Form SD that addresses each item in turn, but most records are single-regime.
• Incorporation by reference and off-EDGAR content. Form SD makes substantial use of issuer websites for the public posting of the Conflict Minerals Disclosure and the Conflict Minerals Report. The body typically cites a URL where the disclosure is hosted in addition to filing it as an exhibit; long-running access to the off-EDGAR copy is not guaranteed.
• Exhibit identification. Reliable role classification of a document inside an accession folder should use the SGML <TYPE> token (and the matching type field in documentFormatFiles) rather than filename heuristics, because issuers' filename conventions vary widely.
• Inline XBRL extraction. For Exhibit 2.01, structured payment data should be parsed from the inline-XBRL tags inside the HTM file rather than from rendered table HTML, since the visible table is generated from the same tags and may include presentational rows (subtotals, totals, currency-conversion lines) that are not separate facts.
• Missing graphics. When the metadata lists GRAPHIC files that are not present on disk, narrative references inside HTML exhibits (for example image-based supplier diagrams or signature blocks) will resolve to broken image links if rendered locally. The textual content of the exhibit remains intact.
• Filer identification. The entities array reflects the EDGAR header at the moment of filing, including SIC code, state of incorporation, fiscal year end, and tickers. Industry concentration in the dataset skews toward extractive SIC codes (10xx metal mining, 13xx oil and gas extraction, 1040 gold and silver ores, 1090 miscellaneous metal ores) for resource-extraction filers and toward manufacturing SIC codes (3xxx) for conflict-minerals filers.

Who Files or Publishes This Dataset, and When

Who files

Form SD is an issuer-level filing. The filer is always an Exchange Act reporting issuer subject to Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934. It is not filed by individuals, beneficial owners, institutional investment managers, broker-dealers, transfer agents, or registered investment companies in their capacity as such. Suppliers, smelters, refiners, mine operators, and government recipients named inside the disclosure are subjects of the report, not filers.

The form carries two structurally distinct disclosure regimes that share one cover form. A given issuer may be in scope for one, the other, or in rare cases both.

Rule 13p-1 conflict minerals filers

Rule 13p-1 applies to any reporting issuer (domestic registrant, foreign private issuer, or smaller reporting company) for which "conflict minerals" are necessary to the functionality or production of a product the issuer manufactures or contracts to be manufactured. "Conflict minerals" means the 3TG minerals: cassiterite, columbite-tantalite, wolframite, and gold, and their derivatives (tin, tantalum, tungsten, gold).

The obligation is product-driven, not industry-driven. There is no SIC or sector limitation. Consumer electronics, industrial machinery, automotive, aerospace, medical device, and branded jewelry issuers are commonly in scope. Pure distributors, resellers, or service providers that do not contract or influence manufacturing are generally outside the rule, even when the goods they handle contain 3TG.

Rule 13q-1 resource extraction issuers

Rule 13q-1 applies only to "resource extraction issuers": reporting issuers engaged in the commercial development of oil, natural gas, or minerals. "Commercial development" covers exploration, extraction, processing, export, and the acquisition of a license for any such activity. The population is concentrated among integrated oil and gas majors, independent E&P companies, and mining companies, including foreign private issuers in those industries. Refiners, marketers, transporters, retailers, and oilfield service contractors that do not themselves hold development rights are typically outside the rule.

When the record is created

Form SD is annual. There is no event-driven trigger; the obligation arises from the issuer's status combined with the passage of a reporting period.

• Rule 13p-1 (conflict minerals): Reporting period is the calendar year, regardless of the issuer's fiscal year-end. Filing is due by May 31 of the following year. The same May 31 deadline applies to domestic issuers, foreign private issuers, and smaller reporting companies; there is no tiered acceleration by filer status.
• Rule 13q-1 (resource extraction): Reporting period follows the issuer's fiscal year. Filing is due no later than 270 days after fiscal year-end.

The first Rule 13p-1 cycle covered calendar year 2013, with filings appearing on EDGAR in spring 2014. This explains the dataset's earliest sample date of April 1, 2014. Form SD has been an electronic EDGAR filing since inception; there is no pre-EDGAR analog.

Conflict Minerals Report attachment

If the issuer's reasonable country of origin inquiry indicates that 3TG originated in the Democratic Republic of the Congo or an adjoining "Covered Country," or origin is undeterminable, the issuer must attach a separate Conflict Minerals Report (CMR) as an exhibit to Form SD, describing due diligence on source and chain of custody under a recognized framework (in practice, the OECD Due Diligence Guidance). The CMR is part of the same Form SD submission, not a separate filing. Following 2017 SEC staff guidance, many issuers now file only the cover disclosure without the full step-two CMR.

Form SD/A amendments

Form SD/A is filed to correct, supplement, or restate a previously submitted Form SD. Typical reasons include factual corrections to country-of-origin or due diligence descriptions, addition of an omitted CMR exhibit, restatement of project-level payment data, or response to staff comments. SD/A has no independent triggering event; it relates back to the original filing's reporting period.

Important distinctions

• Not a substitute for periodic reports. Form SD sits alongside, not in place of, Form 10-K, 20-F, Form 40-F, 10-Q, and 8-K. In-scope issuers continue their normal reporting.
• "Contract to manufacture" turns on influence. Affixing a logo to an off-the-shelf product, without influence over manufacturing specifications, generally does not trigger Rule 13p-1.
• Foreign private issuers are not exempt from Rule 13p-1. The May 31 calendar-year deadline applies to them on the same basis as domestic issuers.
• Alternative reporting under Rule 13q-1. Resource extraction issuers may use reports prepared under regimes recognized as substantially similar (EU Accounting and Transparency Directives, Canada's ESTMA, USEITI). The alternative report is still attached to a Form SD and filed on EDGAR.
• Voluntary supply-chain disclosures (RMI Conflict Minerals Reporting Template, etc.) inform due diligence but do not satisfy the Form SD filing obligation.
• Non-operating registrants such as investment companies, broker-dealers, and asset managers acting in their fund-management capacity do not file Form SD because they neither manufacture 3TG-containing products nor commercially develop oil, gas, or minerals.
• Filed, not furnished. Form SD is subject to Exchange Act liability, though the 2014 D.C. Circuit ruling in National Association of Manufacturers v. SEC struck down the compelled "not been found to be DRC conflict free" product-status statement on First Amendment grounds, narrowing how liability attaches to specific labels in the CMR.

How This Dataset Differs From Similar Datasets or Filings

Form SD is a narrow Dodd-Frank specialty disclosure covering Rule 13p-1 (conflict minerals) and Rule 13q-1 (resource extraction payments). It is annual but not a periodic report, rule-specific rather than principles-based, and produces structured payment data that exists nowhere else in EDGAR. The most useful comparisons are the annual reports it sits beside, the current reports it is sometimes confused with, the XBRL payment exhibit it carries, and the non-SEC transparency regimes that cover overlapping payment data.

Form 10-K and Form 20-F annual reports

The 10-K (domestic) and 20-F (foreign private issuer) are comprehensive annual reports covering business, risk factors, MD&A, and audited financials. Form SD is filed on a separate annual cycle (due May 31 for the prior calendar year) and is not an exhibit to either form. Critically, conflict-minerals and resource-extraction-payment disclosures are carved out of the annual report entirely — even FPIs subject to Rule 13p-1 or 13q-1 must file Form SD alongside their 20-F. A 10-K or 20-F will not contain country-of-origin, smelter-level, or project-level payment data at the granularity Form SD requires. Amendments use SD/A, independent of 10-K/A or 20-F/A.

Form 8-K and Form 6-K current reports

8-K (domestic) and 6-K (FPI) are event-driven disclosures triggered by enumerated material events on short deadlines. Form SD is the opposite: a fixed-cadence annual compliance report tied to specific Dodd-Frank rules, not to any corporate event. There is essentially no content overlap; conflict-minerals and government-payment disclosures will not appear in 8-K or 6-K datasets, and an issuer's SD obligation is unaffected by any 8-K it does or does not file.

Form SD body versus the Conflict Minerals Report exhibit

Within an SD filing, the cover form contains issuer identification, the relevant rule citation, and a high-level disclosure statement. The Conflict Minerals Report (CMR), required as an attached exhibit when due diligence is triggered under Rule 13p-1, contains the substantive material: reasonable country-of-origin inquiry, OECD-aligned due diligence framework, facility and smelter lists, products containing conflict minerals, and independent private sector audit results. Users analyzing supply-chain due diligence need the CMR exhibit; the cover form alone is metadata. The dataset packages both at the accession level so the right granularity is preserved.

Resource extraction XBRL versus general financial XBRL datasets

Rule 13q-1 filers attach payment data as inline XBRL in an EX-2.01 exhibit to Form SD, tagged by project, payment type (taxes, royalties, fees, production entitlements, bonuses, dividends, infrastructure improvements), government recipient, country, and currency. This is structurally similar to the SEC's Financial Statement Data Sets (FSDS) — both are tag-driven structured extracts — but the content domains do not overlap. FSDS contains GAAP line items from 10-K, 10-Q, and 20-F filings; the EX-2.01 extract contains payment-level disclosures that never appear at this granularity in the financial statements. Conflict-minerals-only SD filings do not produce this XBRL extract.

Non-SEC extractive transparency regimes

For resource extraction issuers, Canada's ESTMA, the EU Accounting and Transparency Directives, and the UK's Reports on Payments to Governments Regulations are the closest analogues to Rule 13q-1, requiring issuer-level disclosure at comparable project-and-recipient granularity. Some SEC filers cross-reference an ESTMA or Home Country Report to satisfy Rule 13q-1's alternative reporting provision, so the underlying payment events overlap substantially for dual-listed issuers. EITI is a country-level voluntary reconciliation framework rather than an issuer disclosure and is a weaker analogue. The Form SD dataset captures only the SEC-filed instance; parallel filings live in separate national registries. Conflict-minerals disclosures under Rule 13p-1 have no direct foreign mandatory analogue at the same granularity, although the EU Conflict Minerals Regulation and OECD Due Diligence Guidance shape similar narratives.

Boundary summary

Form SD is the only SEC filing dedicated to conflict-minerals due diligence and resource-extraction payments. It is annual but separate from the 10-K and 20-F, structurally unrelated to event-driven 8-K and 6-K reports, and produces structured XBRL payment data (under 13q-1) that exists nowhere else in EDGAR. Its closest substitute for extractive payments is the ESTMA/EU/UK regimes outside SEC EDGAR; for conflict-minerals due diligence there is no SEC substitute at all, making this dataset the authoritative source for both disclosures from April 2014 to present.

Who Uses This Dataset

The dual mandate of Form SD — conflict minerals under Rule 13p-1 and resource extraction payments under Rule 13q-1 — gives the dataset an unusually broad professional user base, with each role drawing on different parts of the package: the SD cover body, the attached Conflict Minerals Report (CMR), the EX-2.01 payments exhibit (typically inline-XBRL), EX-99 narrative exhibits, and the per-accession metadata.json.

Conflict Minerals Compliance Officers and Disclosure Counsel

In-house program leads, trade compliance officers, and securities counsel use the dataset to draft and revise their own SD and CMR filings. They read peer SD bodies for "necessary to functionality or production" determinations, contract-manufacturer carve-outs, and product-scope language, and study CMRs for OECD-aligned due-diligence framework descriptions, smelter inventories, and risk-mitigation plans. SD/A amendment histories in metadata.json show what peers revised and when, informing internal redline cycles and board-level compliance memos.

Supply-Chain Due Diligence and Responsible-Sourcing Teams

Procurement, supplier-risk, and responsible-sourcing teams at downstream manufacturers mine CMR exhibits for named smelters and refiners, country-of-origin lists, and supplier survey methodologies disclosed by peers. They benchmark escalation, remediation, and off-boarding language to refine internal policy. Outputs include supplier scorecards, due-diligence playbooks, and Tier-N mapping projects.

ESG and Sustainability Research Analysts

Analysts at investment managers, ratings providers, and ESG data vendors construct firm-level conflict-minerals exposure scores and track year-over-year changes in due-diligence maturity. They parse CMR HTML for RCOI results, smelter identification, and OECD alignment language, and pull SD-body determinations and metadata.json filer attributes to align disclosures with sector and fiscal period. Output feeds ESG scoring models, thematic fund screens, and engagement priority lists.

IPSA Auditors

Audit firms engaged for Independent Private-Sector Audits study the population of issuers commissioning IPSAs, the scope statements used, and the design-and-performance criteria referenced. They focus on attached audit reports inside the CMR exhibit and on qualifications or scope limitations, and they use metadata to identify recurring engagements across filing years. The dataset supports audit-methodology calibration and peer benchmarking of opinion language.

Extractive-Industry Equity Research Analysts

Sell-side and buy-side analysts covering oil, gas, and mining issuers parse the EX-2.01 inline-XBRL payments exhibit for project-level payments to governments, disaggregated by payment type (taxes, royalties, fees, production entitlements, bonuses, dividends, infrastructure improvements) and recipient. This drives effective government-take estimates, fiscal-regime sensitivity models, and project-NPV adjustments.

Transparency-Focused NGOs and Civil-Society Analysts

Researchers at extractive-industry watchdogs and corporate-accountability organizations use both halves of the dataset. On conflict minerals, they rank issuers on smelter naming, country-of-origin disclosure, and due-diligence credibility. On resource extraction, they reconcile EX-2.01 payment tables against host-country budget data to flag potential revenue leakage. Outputs include public scorecards, regulatory comment letters, and shareholder engagement campaigns.

Investment Screening and Proxy Advisory Teams

Negative-screening analysts at asset owners and fund managers use the dataset to identify issuers with unresolved conflict-minerals exposure for exclusion-list maintenance. Proxy advisors assess management responses to related shareholder proposals, focusing on CMR remediation timelines, supplier-engagement results, and named high-risk sourcing locations to inform vote recommendations.

Government and Multilateral Transparency Analysts

Analysts at host-government revenue authorities, international transparency initiatives, and multilateral institutions use EX-2.01 to triangulate corporate-side disclosures with government-side receipts. They focus on structured payment fields (project, government recipient, currency, category, totals) for reconciliation reports and country-level transparency assessments.

3TG Smelter and Refinery Mapping Researchers

Specialists tracking the tin, tantalum, tungsten, and gold midstream extract every named smelter or refiner and reported operating country across CMR exhibits to build cross-issuer sourcing maps. Output supports industry validation programs, midstream concentration analysis, and high-risk facility flagging.

Academic Researchers

Researchers in law, accounting, economics, and supply-chain management treat the corpus from April 2014 onward as a longitudinal panel. CMR text supports studies of boilerplate convergence, the impact of the 2014 D.C. Circuit ruling, and changes in due-diligence specificity. EX-2.01 supports empirical work on host-government revenue and fiscal regimes. Metadata enables panel construction by CIK, period, and accession; SD/A amendments enable revision-behavior studies.

NLP and Retrieval Engineering Teams

Engineering teams building ESG and compliance retrieval systems ingest the full package (HTML, TXT, PDF, JSON) to train and evaluate extractors for smelter names, country-of-origin lists, payment tables, and due-diligence narratives. Heterogeneous exhibit formats stress-test parsers handling inline-XBRL, HTML, and PDF in one pipeline; metadata.json provides clean filer-level grounding for training data and evaluation sets.

Specific Use Cases

The dataset supports concrete workflows across both Form SD disclosure regimes, drawing on the SD body, the Conflict Minerals Report (Exhibit 1.02), the inline-XBRL payments exhibit (Exhibit 2.01), and the per-accession metadata.json.

Building a cross-issuer 3TG smelter and refiner registry

Parse Exhibit 1.02 narratives to extract every named smelter or refiner together with reported country of operation and Responsible Minerals Assurance Process (RMAP) conformance status. Aggregating across CIKs and reporting years yields a midstream facility roster, supports concentration analysis, and flags facilities that newly appear or drop off issuer lists year over year.

Extracting project-level government payments from inline XBRL

Pull <ix:nonFraction> and <ix:nonNumeric> tags from EX-2.01 documents (rxp taxonomy) to materialize a structured table of payments by project, recipient government, country, payment category (taxes, royalties, fees, production entitlements, bonuses, dividends, infrastructure improvements), and currency. The resulting table feeds effective government-take models, fiscal-regime sensitivity analyses, and reconciliation against ESTMA and EU/UK Reports on Payments to Governments for dual-listed issuers.

Benchmarking peer disclosure language for SD and CMR drafting

Filter metadata.json by SIC code and fiscal year end to assemble a peer set, then compare Item 1.01 country-of-origin determinations and Exhibit 1.02 sections on OECD five-step due diligence, contract-manufacturer scope, and supplier escalation. Output supports redline cycles for in-house counsel preparing the issuer's own Form SD and structuring board-level compliance memos.

Tracking amendment behavior via SD/A chronology

Link SD and SD/A records by issuer CIK, reporting period, and filedAt timestamp to reconstruct each amendment trail. Diffing the original Form SD body and Conflict Minerals Report against the SD/A surfaces what issuers correct (smelter list revisions, RCOI restatements, scope clarifications), supporting restatement-behavior studies and disclosure-quality scoring.

Constructing ESG conflict-minerals exposure panels

Combine entities metadata (CIK, SIC, state of incorporation, tickers, fiscal year end) with parsed Item 1.01 determinations and CMR maturity indicators (named smelters, audit references, remediation plans) to build a longitudinal firm-level panel from 2014 forward. The panel feeds ESG scoring models, exclusion-list maintenance for negative screens, and academic studies of boilerplate convergence following the 2014 D.C. Circuit decision.

Reconciling corporate payments against host-country revenue data

For transparency-focused analysts, sum EX-2.01 payment facts by recipient government and resource type, then compare against host-government budget receipts and EITI country reports. Discrepancies between corporate-side disclosures and government-side receipts drive country transparency assessments, regulatory comment letters, and shareholder engagement on revenue governance.

Training extractors for heterogeneous ESG document layouts

Use the bundled HTML, inline-XBRL, and JSON manifest as a multi-format training corpus for compliance and ESG retrieval systems. The mix of narrative CMR prose, structured rxp-tagged payment tables, and EX-99 supplementary attachments stress-tests parsers for smelter-name extraction, country-of-origin list parsing, and payment-row reconciliation, with metadata.json providing CIK- and period-level ground truth for evaluation sets.

Dataset Access

Dataset Index JSON API: https://api.sec-api.io/datasets/form-sd-files.json

This endpoint returns dataset metadata including the name, description, last updated timestamp, earliest sample date (2014-04-01), total record count, total size, covered form types (SD, SD/A), container format (ZIP), and the file types included in each container (HTML, JSON, TXT, PDF). It also returns the full dataset download URL and the list of all individual container files, each with its size, record count, last updated timestamp, and download URL. The endpoint does not require an API key.

Poll this endpoint daily to detect which containers were modified in the most recent refresh run, then decide which containers to re-download based on their updatedAt timestamps.

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          {
        

          2
            "datasetId": "1f13365b-9ae0-6923-8ed4-6e2115d6cf27",
        

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            "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-sd-files.zip",
        

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            "name": "Form SD Files Dataset",
        

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            "updatedAt": "2026-05-07T02:51:40.258Z",
        

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            "earliestSampleDate": "2014-04-01",
        

          7
            "totalRecords": 24611,
        

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            "totalSize": 192016410,
        

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            "formTypes": ["SD", "SD/A"],
        

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            "containerFormat": "ZIP",
        

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            "fileTypes": ["HTML", "JSON", "TXT", "PDF"],
        

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            "containers": [
        

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              {
        

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                "downloadUrl": "https://api.sec-api.io/datasets/form-sd-files/2026/2026-03.zip",
        

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                "key": "2026/2026-03.zip",
        

          16
                "size": 13818783,
        

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                "records": 154,
        

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                "updatedAt": "2026-05-07T02:51:40.258Z"
        

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              }
        

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            ]
        

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          }
        

Download Entire Dataset: https://api.sec-api.io/datasets/form-sd-files.zip?token=YOUR_API_KEY

Downloads the complete Form SD Files dataset as a single ZIP archive containing every monthly container from April 2014 to present. This endpoint requires an API key.

Download Single Container: https://api.sec-api.io/datasets/form-sd-files/2026/2026-03.zip?token=YOUR_API_KEY

Downloads one monthly container ZIP file instead of the full archive, which is useful for incremental updates or when only a specific time period is needed. This endpoint requires an API key.

Frequently Asked Questions

What forms does this dataset cover?

The dataset covers Form SD and Form SD/A filings submitted to EDGAR. Form SD is the specialized disclosure report filed under Rule 13p-1 (conflict minerals) and Rule 13q-1 (resource extraction payments) of the Securities Exchange Act of 1934, and Form SD/A is the amendment counterpart used to correct, restate, or supplement a previously submitted Form SD.

What does one record in the Form SD Files Dataset represent?

One record is a single EDGAR accession — one Form SD or Form SD/A submission filed by a single issuer on a specific date — packaged as an accession-numbered folder containing a metadata.json manifest and the textual filing documents from the original submission. An issuer that files an annual Form SD and later submits an amending SD/A contributes two independent records.

Who is required to file Form SD?

Two issuer populations file. Under Rule 13p-1, any Exchange Act reporting issuer for which conflict minerals (tin, tantalum, tungsten, gold) are necessary to the functionality or production of a product they manufacture or contract to manufacture must file. Under Rule 13q-1, "resource extraction issuers" engaged in the commercial development of oil, natural gas, or minerals must file. Foreign private issuers are not exempt from either rule.

When are Form SD filings due?

Rule 13p-1 conflict-minerals filings are due by May 31 of the year following the calendar-year reporting period, regardless of the issuer's fiscal year-end. Rule 13q-1 resource-extraction filings are due no later than 270 days after the issuer's fiscal year-end. There is no event-driven trigger; the obligation arises annually from the issuer's status.

What time period does the dataset cover?

The dataset's earliest sample date is April 1, 2014, corresponding to the first Form SD filings made for calendar-year 2013 conflict-minerals disclosures, and it covers every Form SD and Form SD/A filing through the present. Form SD has been an electronic EDGAR filing since inception, so there is no pre-EDGAR analog.

What file formats are included, and what is excluded?

Records are distributed inside monthly ZIP containers and contain HTML, JSON, TXT, and PDF payloads — at minimum the Form SD body, plus any HTM-format exhibits (EX-1.02, EX-2.01, EX-99.x) and a metadata.json. Image files (GRAPHIC documents such as logos, signature scans, and chart images), the standalone .xsd taxonomy schema, the extracted _htm.xml XBRL instance, and the consolidated complete-submission .txt are catalogued in the manifest but not redistributed inside the ZIP.

How is this dataset different from the 10-K or 20-F annual report datasets?

Conflict-minerals and resource-extraction-payment disclosures are carved out of the periodic annual report entirely. A 10-K or 20-F will not contain country-of-origin, smelter-level, or project-level payment data at the granularity Form SD requires. Even foreign private issuers subject to Rule 13p-1 or 13q-1 must file Form SD alongside their 20-F, on a separate annual cycle, and amendments use SD/A independently of 10-K/A or 20-F/A.