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Explore EU public country-by-country reporting (pCbCR) developments across the 27 individual member states

EU Public Country-by-Country Reporting Tracker Tax and sustainability Tax is no longer simply about compliance. For many stakeholders, including investors, tax and tax transparency are an important component of a broader sustainability conversation which often goes to the heart of a business’s purpose and role in society. The tax contributions made by companies can have a significant positive impact on local communities and environmental initiatives in countries where they have operations, yet this story is often not told or well understood.

The disclosure of pCbCR will be uncharted waters for most multinational enterprises (MNEs) and is likely to represent the first time potentially sensitive country-level data on tax and profits will be made publicly available. While the focus of pCbCR is on corporate income taxes, this new regulation gives businesses an opportunity and a foundation from which to tell their holistic tax story and help build trust with stakeholders.

What is country-by-country reporting? Introduced by the OECD as one of the organisation’s BEPS Actions, country-by-country reporting (CbCR) information has for the majority of businesses been privately submitted to tax authorities and used as a high-level transfer pricing risk assessment tool. The Global Reporting Initiative (GRI) built on this, and in 2019 introduced a requirement to publicly disclose CbCR information as part of its 207 Tax Standard, which companies can elect to report under voluntarily. The objective of the EU Directive is to further this tax transparency initiative through mandated disclosure of CbCR for MNEs with operations in the EU.
 

What is EU pCbCR and what are the implications for businesses? EU pCbCR is a tax transparency initiative which aims to give stakeholders a clearer view of MNEs’ EU tax contributions and economic activities and is designed to foster corporate responsibility in the EU. It requires large MNEs to publicly disclose key financial data for each tax jurisdiction in which they operate, enhancing the public’s ability to scrutinise corporate tax metrics. 

The Australian Parliament has introduced public country by country (CBC) reporting obligations with effect from 1 July 2024 for large multinational groups with an Australian presence. The data is to be submitted to the Australian Taxation Office (ATO), and will be made available publicly. The Australian regime differs from the EU in some of the data to be provided and the tax jurisdictions for which data must be disaggregated. The Australian government has also released information on how businesses can register for the CBC regime and draft guidance on applying for exemptions from CBCR.

Public country by country (CBC) reporting obligations Information on how businesses can register for the CBC regime Draft guidance on applying for exemptions Companies in scope — who is affected? A reporting obligation arises for multinational groups with a consolidated net turnover of at least EUR750 million in each of the last two consecutive financial years if the group’s ultimate parent is either:

headquartered in the EU, or

headquartered in a third country and operates in the EU through a qualifying subsidiary or branch1.

For EU-headquartered groups the disclosure obligation lies with the EU parent which is responsible for filing the report with a publicly accessible commercial registry and publishing it on its website (unless the website publication exemption applies, please refer to optional clauses below). 

For non-EU headquartered groups, the Directive provides a reporting exemption for EU subsidiaries and branches where the ultimate parent has published a report on its website and assigned one of the EU-based subsidiaries or branches to file the report with their national commercial registry. Not all countries have included this exemption (please refer to the below tracker for country-level specifics).

Financial institutions established in the EU within the scope of pCbCR and which already report country-by-country information under Capital Requirements Directive (CRD) IV are exempt.

1. A qualifying subsidiary must meet two of the following three requirements: 1) have an average number of employees exceeding 50, 2) have a balance sheet greater than EUR 5 million, or 3) have net revenue greater than EUR 10 million. A branch simply needs to meet the revenue threshold. These thresholds may be different in some member states according to the local legislation, please refer to the tracker for additional information.

First year of reporting and publication date Information required to be disclosed Optional clauses and penalties Using the tracker Our tracker offers a comprehensive overview of the Regulation across the 27 individual EU member states, including where the local reporting and filing requirements as well as available exemptions and deferrals, often diverge from the EU Directive. The tracker is designed to help tax teams navigate through this complexity in order to make informed decisions and deliver the best outcomes for their business and stakeholders.

Select a territory Select a territory Tracker up to date as at 13 February 2026.
This content is for general information purposes only and should not be used as a substitute for consultation with professional advisors.

Need to look at the data offline or print it? Download the data as a PDF document Download all data (PDF of 379.86KB) Additional information First year of reporting and publication date First year of reporting and publication date For most member states the first reporting year will commence 12 months on or after the transposition deadline (i.e. on or after 22 June 2024). Publication of the report is expected 12 months after the first reporting year. For businesses operating on a calendar year basis, the first reporting year will be 2025 with publication of the report due by the end of 2026.

Some member states have set earlier reporting and/or publication periods. For multinationals with operations in Romania, the local pCbCR regulation is applicable for financial years beginning on/after 1 January 2023. This is two years earlier than the EU Directive meaning the regulation is already in force in Romania, and reports are expected to be published by 31 December 2024 for MNEs operating on a calendar year basis. Please refer to the tracker for further country-level specifics.

Information required to be disclosed Information required to be disclosed The report is required to disclose data on the following basis for the whole group:

For each EU member state separately

For each jurisdiction included on the EU list of non-cooperative jurisdictions for one year (the ‘black’ list) or for two consecutive years on the list of jurisdictions that do not yet comply with all international tax standards but have committed to implementing reforms (the ‘grey’ list)

Aggregated for the rest of the world

The report should contain the following information:

Brief description of the nature of activities

Number of full-time equivalent employees

Total revenue including from related parties

Profit/loss before tax

Income tax accrued in the current year

Income tax paid

Accumulated earnings

The above may be subject to change/revision as the European Commission has yet to release the template report.

Optional clauses and penalties Optional clauses and penalties The EU Directive is a minimum standard allowing member states to expand its scope as well as leaving a number of optional elements with respect to domestic implementation. The two main optional elements are:

An optional reporting deferral of up to a maximum of 5 years where disclosure would be deemed commercially sensitive to the business (a so-called ‘safeguard clause’), with an exception for data related to jurisdictions on the EU’s list of non-cooperative jurisdictions (the ‘black’ and ‘grey’ lists); 

Exemption from publication on the company’s website if the report is made publicly available to any third party located in the EU, free of charge, on the website of the official commercial registry.

Please refer to the tracker for further information on the optional elements alongside noteworthy divergences from the Directive specific to individual member states. In addition, the EU Directive does not provide details on the topic of penalties instead requiring member states to impose them. The tracker includes a high-level overview of the penalty regimes and responsible personnel where applicable.

Go back to the tracker ↑

Tax and Sustainability Tax is a value driver in delivering on the business’s environmental, social and governance (ESG) goals.

Find out more OECD Pillar Two readiness The Organisation for Economic Cooperation and Development (OECD) has placed significant importance on country-by-country reporting data within the context of the Pillar Two CbCR-Transitional Safe Harbour rules.

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