Directive (EU) 2021/2101 — Public Country-by-Country Report

Does my multinational group have to publicly disclose how much tax it pays in every country — and what happens if the first report is late?

Groups with consolidated revenue above EUR 750 million must publish a country-by-country income tax report for financial years starting on or after 22 June 2024; penalties are set by each Member State under the Directive 2013/34/EU enforcement framework, and the statutory auditor must flag non-compliance in the audit report [Art. 48f].

Short Answer

Directive (EU) 2021/2101 inserts Articles 48a to 48h into the Accounting Directive (2013/34/EU), creating a public country-by-country reporting (CbCR) obligation for multinational groups and standalone undertakings whose consolidated revenue exceeds EUR 750 million for two consecutive financial years [Art. 48b(1)]. The report must disclose revenue, pre-tax profit, income tax accrued and paid, accumulated earnings, and employee headcount, broken down by EU Member State and by each jurisdiction on the EU list of non-cooperative tax jurisdictions [Art. 48c(2), (5)]. It must be published on the company website, free of charge, in a machine-readable format, within 12 months of the balance sheet date [Art. 48d(2)]. EU subsidiaries and branches of non-EU parent companies that meet the thresholds must publish the report themselves — or issue a statement that the parent did not provide the necessary data [Art. 48b(4), (5)].

Who is affected

Ultimate parent undertakings and standalone undertakings with consolidated (or individual) revenue exceeding EUR 750 million for each of the last two consecutive financial years [Art. 48b(1)]. Medium-sized and large EU subsidiary undertakings of non-EU parents above the same threshold [Art. 48b(4)]. Branches opened in a Member State by non-EU undertakings, where the branch net turnover exceeds the medium-sized threshold for two consecutive years and no EU subsidiary already reports [Art. 48b(5)]. Exempted: groups operating exclusively within a single Member State [Art. 48b(2)] and entities already reporting under CRD IV Article 89 [Art. 48b(3)].

Deadline

The obligation applies from the first financial year starting on or after 22 June 2024 [Art. 48g]. For a calendar-year group, the first report covers FY 2025 and must be published by 31 December 2026 at the latest (12 months after balance sheet date) [Art. 48d(1)]. The Commission must submit a review report by 22 June 2027 [Art. 48h].

Risk

Penalties are determined by each Member State under the existing Directive 2013/34/EU sanctions framework [Recital 21]. In addition, statutory auditors must state in the audit report whether the undertaking was obliged to publish a CbCR and whether it did so [Art. 48f] — creating a public compliance flag visible to investors, creditors, and the media. Commercially sensitive information may be deferred for up to five years, but data relating to non-cooperative tax jurisdictions may never be omitted [Art. 48c(6)].

Proof

Legal status

• In force
• as of 2026-04-17
• Original version (OJ L 429, 1.12.2021, p. 1)

Primary sources

• EUR-Lex — Full text
• European Commission — Collective redress — EU redress policy

What to do now

Legal / DPO

•Verify whether the group's consolidated revenue exceeded EUR 750 million for FY 2023 and FY 2024 to confirm reporting obligation from FY 2025 onward [Art. 48b(1)].
•Review whether any EU subsidiary or branch of a non-EU parent must independently publish the report or issue a non-availability statement, and assign board-level responsibility for compliance [Art. 48b(4), (5), Art. 48e].
•Assess the scope of the temporary deferral option under national transposition law: commercially sensitive data may be omitted for up to five years, but non-cooperative jurisdiction data may never be withheld [Art. 48c(6)].

Compliance

•Establish a data collection process covering all eight mandatory fields per tax jurisdiction: entity list, activities, FTE headcount, revenue, pre-tax profit, tax accrued, tax paid, and accumulated earnings [Art. 48c(2)].
•Map every tax jurisdiction in which the group operates and identify those on the EU Annex I and Annex II non-cooperative lists, since these require individual disclosure with no deferral right [Art. 48c(5), (6)].
•Confirm publication within 12 months of the balance sheet date on the corporate website, free of charge, in a machine-readable electronic format once the Commission template is adopted [Art. 48d(2), Art. 48c(4)].

IT / Security

•Implement a machine-readable electronic reporting format (XHTML or future Commission template) and ensure the corporate website can host the report in a publicly accessible, structured format [Art. 48c(4), Art. 48d(2)].
•Build an automated data pipeline that aggregates income tax data from ERP and consolidation systems, broken down by tax jurisdiction, to produce the CbCR report with minimal manual intervention [Art. 48c(2), (5)].
•Ensure the published report and all predecessor versions remain accessible on the website for at least five consecutive years, with appropriate archiving and availability controls [Art. 48d(4)].

Product / Engineering

•Coordinate with Group Tax and Finance to ensure that internal transfer pricing documentation is consistent with the publicly reported revenue and profit figures per jurisdiction, since any discrepancy will be publicly visible [Art. 48c(2)(d), (e)].
•Factor the CbCR timeline into the annual reporting calendar: the report is separate from the annual financial statements and has its own 12-month publication deadline [Art. 48d(1), Recital 13].
•Prepare an optional narrative explanation for material discrepancies between tax accrued and tax paid, as permitted under the Directive, to pre-empt reputational risk from public misinterpretation [Art. 48c(7)].

Key Terms

Country-by-country reporting (CbCR): Public disclosure of income tax information broken down by each tax jurisdiction in which a multinational group operates, covering revenue, profits, taxes, and headcount.
Ultimate parent undertaking: The undertaking that draws up the consolidated financial statements of the largest body of undertakings in a group [Art. 48a(1)(1)].
Standalone undertaking: An undertaking that is not part of a group as defined in Article 2(11) of Directive 2013/34/EU [Art. 48a(1)(4)].
Tax jurisdiction: A State or non-State jurisdiction which has fiscal autonomy in respect of corporate income tax [Art. 48a(1)(3)].
Non-cooperative jurisdiction: A tax jurisdiction listed in Annex I or Annex II to the Council conclusions on the revised EU list of non-cooperative jurisdictions for tax purposes; data from these jurisdictions must always be reported individually and cannot be deferred [Art. 48c(5), (6)].
Revenue (for scope purposes): Net turnover for undertakings governed by Member State law not using IFRS; revenue as defined by the applicable financial reporting framework for other undertakings [Art. 48a(2)].
Accumulated earnings: The sum of profits from past and current financial years whose distribution has not yet been decided upon; for branches, it refers to the undertaking that opened the branch [Art. 48c(2)(h)].

Frequently Asked Questions

Which groups must publish a country-by-country tax report?

Any multinational group whose ultimate parent undertaking has consolidated revenue exceeding EUR 750 million for each of the last two consecutive financial years must report. Standalone undertakings above the same threshold are also covered [Art. 48b(1)].

Are groups operating only within a single Member State exempt?

Yes. Where all undertakings in the group, including branches, are established or have their permanent business activity within the territory of a single Member State and no other tax jurisdiction, the reporting obligation does not apply [Art. 48b(2)].

What must the report contain?

The report must include, per tax jurisdiction: a list of entities, nature of activities, number of employees (FTE), revenue, pre-tax profit or loss, income tax accrued, income tax paid (cash basis), and accumulated earnings [Art. 48c(2)].

When is the first report due?

The reporting obligation applies from the first financial year starting on or after 22 June 2024 [Art. 48g]. For calendar-year groups, this means FY 2025 is the first reporting year, and the report must be published within 12 months of the balance sheet date — i.e. by 31 December 2026 [Art. 48d(1)].

Can commercially sensitive information be withheld?

Member States may allow undertakings to temporarily omit specific items of information for up to five years, provided the omission is disclosed with a reasoned explanation. However, information about tax jurisdictions on the EU non-cooperative list (Annex I and Annex II) may never be omitted [Art. 48c(6)].

What happens if the non-EU parent company refuses to provide data?

EU subsidiaries and branches must publish all information in their possession, obtained or acquired, together with a statement indicating that the ultimate parent undertaking did not make the necessary information available [Art. 48b(4), (5)].

Are banks exempt from public CbCR under this Directive?

Yes. Ultimate parent undertakings and standalone undertakings that already report under Article 89 of CRD IV (Directive 2013/36/EU), covering all their activities including non-prudential ones, are exempt from this Directive's reporting requirements [Art. 48b(3)].

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