EU Public Country-by-Country Reporting obligations for EU and non-EU-headquartered multinationals from 22 June 2024

Overview of the Directive on EU Public Country-by-Country Reporting

In December 2021, the EU adopted an amendment to Directive 2013/34/EU to introduce new rules regarding the disclosure of income tax information by certain undertakings and branches (Directive (EU) 2021/2101). EU Public CbCR aims to increase transparency and to provide more scrutiny of MNEs' EU income tax positions and strategies.

EU Public CbCR requires all MNEs with consolidated revenues exceeding EUR 750 million for two consecutive financial years and with qualifying operations in at least one EU member state to annually disclose certain income tax information to the general public on a country-by-country basis. In-scope MNEs are both large EU-parented groups and large non-EU-parented groups. In both cases, data and information needs to be disclosed for all subsidiaries and branches in the EU and the EEA and also for defined countries outside of the EU (see below). The Directive only requires a disclosure for medium-sized and large subsidiaries (i.e., subsidiaries that, at the balance sheet date, exceed two of the following three criteria) and comparable branches:

1. Total assets: EUR 5 million;
2. Net turnover: EUR 10 million;
3. Average number of employees: 50.

A branch only needs to meet the revenue threshold. The EU member states were allowed to apply different thresholds to determine whether a subsidiary or branch qualifies as medium or large (see below). An overview of the implementation legislation in the EU member states can be found in the Deloitte Global Tax Library (scroll to “Quick Reference” and then to “EU public country-by-country reporting“; latest update: April 2026).

On 2 December 2024, the Commission published the final version of its EU Template. All EU-based MNE groups must create their EU Template, which they must disclose in their own member state in its official EU register, as an XHTML dataset with iXBRL markup. Non-EU-based groups may also use an XHTML dataset and disclose it in at least one official EU public register (see below). To generate a machine-readable EU Template, which can be published in an official EU register, the Commission published a first Reporting Package on 22 December 2025, which was last updated on 25 September 2026 (Reporting Package). This includes, inter alia, the EU Taxonomy and a Report Generator (Excel; Version 2.0 dated 25 September 2026).

In Germany, the EU Taxonomy has already been implemented in the German company register, which can receive machine-readable EU Templates in all official EU languages. In Germany, all large Germany-parented groups who must e-disclose an EU Template and all large non-EU-parented groups who want to e-disclosure an EU Template must prepare a machine-readable EU Template in German (i.e. no PDF upload is possible). A second (optional) EU Template in English can also be uploaded. The Report Generator (Version 2.0 dated 25 September 2026) does not generate error-free EU Templates that can be e-uploaded to the German company register. Deloitte’s Public CbCR platform (CbCR Agent) generates validated and error-free XHTLM datasets in German and in English that can be uploaded to the German company register.

According to the Directive, the following information must be disclosed - for all in-scope jurisdictions - for all financial years beginning on or after 22 June 2024 at the very latest within 12 months after year-end in one official EU register and on one internet website:

1. Name of the ultimate parent undertaking or stand-alone undertaking;
2. Nature of activities;
3. Number of full-time equivalents;
4. Revenues;
5. Profit or loss before income tax;
6. Current income tax accrued;
7. Current income tax paid;
8. Accumulated earnings at year-end.

This information must be provided - on a jurisdictional basis - for all in-scope subsidiaries and branches for each EU member state, for each member state of the European Economic Area (EEA; i.e., Iceland, Liechtenstein, and Norway), and for each state that is (or that has been) included on the EU list of non-cooperative jurisdictions (i.e. annex I and annex II). All other jurisdictions may be aggregated into “All other tax jurisdictions (aggregated basis).” More details are included and explained in the common template and data schema.

The Directive entered into force on 21 December 2021. All EU member states were given 18 months (i.e. until 22 June 2023) to transpose the Directive into local law. EU Public CbCR applies - at the very latest - for all new financial years beginning on or after 22 June 2024 (with an earlier effective date being possible). An overview of the implementation in the EU member states can be found in the Deloitte Global Tax Library (scroll to “Quick Reference” and then to “EU public country-by-country reporting“; latest update: April 2026).

Overview of the German implementation of EU Public CbCR

On 19 June 2023, Germany published its final implementation legislation in the Federal Gazette. The legislation requires all in-scope MNEs to disclose defined income tax information on a country-by-country basis to the general public for all financial years beginning on or after 22 June 2024. The German legislation is very business-friendly (including the so-called “website exemption”) and is in line with the requirements as set forth in the Directive (Tax@Hand). The implementation legislation was included in the German Commercial Code (HGB) in Sections 342-342p, which are applicable to all large MNEs. Germany did not nationally extend the EU list of non-cooperative jurisdictions.

Compared to the EU Directive, Germany applies more generous criteria for testing whether MNE groups are in scope of EU Public CbCR. The German domestic criteria are: a) EUR 7,5m balance sheet total; b) EUR 15m net revenue; and/or c) 50 average number of employees during the financial year. EU Public CbCR only applies to German branches with more than EUR 12m of net sales.

In the legislative process, Germany tightened the standard rules from the Directive in two areas: The period during which confidential information can be excluded from disclosure (“safeguard clause”) was reduced from five to four years. Furthermore, the maximum fine for non-compliance was increased fivefold to EUR 250,000, which indicates that strict enforcement should be expected. In Germany, this fine is not automatic, but fully discretionary, and both a fine and its maximum amount will therefore only be assessed in extreme cases of non-compliance.

Advantages of Germany as a central EU disclosure hub for non-EU-parented MNEs

EU Public CbCR differs from the existing non-public OECD CbCR in terms of content and scope. It only includes EU-, EEA-, and non-EU subsidiaries and branches in non-cooperative jurisdictions (see above). Furthermore, while regular CbCR is filed by most MNE only in their own headquarter jurisdiction, EU Public CbCR must – by default – always be locally disclosed in the local EU register and on a website in each EU member state in which an in-scope non-EU-parented MNE group maintains a qualifying local presence, which may multiply the number of local EU filings required under EU Public CbCR.

The main rule assumes that the non-EU-parented MNE group makes a qualifying EU Template available to all its EU subsidiaries and EU branches in all EU member states with a qualifying presence. If this is not the case, a fallback rule may apply that requires all EU subsidiary or EU branch in EU members with a qualifying presence to draw up the EU Template from locally available information in Euros and to publish it in their local EU register and on their website.

For a non-EU-headquartered MNE group, there is an exception to the standard that all qualifying EU subsidiaries or EU branches are always required to comply with the EU Public CbCR disclosure requirements and obligations locally in each EU member state in which the MNE group has a qualifying presence. To benefit from the multiple reporting exemption (often also called “nomination rule”) in Germany, the non-EU-headquartered MNE group must (1) prepare a qualifying EU Template, (2) publish this qualifying EU Template no later than one year following the end of the reporting period in at least one of the official EU languages (e.g. English) on its own website, (3) have the qualifying EU Template disclosed by its qualifying German subsidiary or branch in German in the German company register, and (4) must state of the name and the registered office of its qualifying German subsidiary or branch in the EU Template.

Not all EU member states have locally implemented the nomination rule for non-EU-parented MNE groups in line with the spirit of administrative simplification (i.e. allowing for a one EU register disclosure). The majority of EU member states respect that the nomination rule is exercised in another EU member state and require no local e-disclosure or notification. In some EU member states, non-EU-parented MNE groups with a qualifying local presence must make a full local e-disclosure if they elect the nomination rule in another EU member state. Some EU member states respect the nomination rule if exercised in another EU member state, but require a local e-disclosure related to the nomination rule. An overview of the implementation legislation in the EU member states can be found in the Deloitte Global Tax Library (scroll to “Quick Reference” and then to “EU public country-by-country reporting“; latest update: April 2026).

For non-EU-parented MNEs, Germany is an attractive hub for one central EU Public CbCR disclosure under the multiple reporting exemption (nomination rule). Most non-EU-parented MNE groups have a qualifying presence in Germany as the largest EU market. Germany allows for an election to bridge the (existing) OECD CbCR XML dataset into the (new) EU Public CbCR XHTML dataset. In Germany, the German company register already accepts machine-readable EU Templates (see above) drawn up in XHTML in German and in English for a fixed fee, so that the disclosure requirements for financial year 2025 could be fulfilled in Germany for EU member states with a shorter deadline (e.g. Spain; 30 June 2026). Furthermore, nomination rule requirements in other EU member states can be met via an upload of the machine-readable EU Template in the German company register on 31 December 2026 or on 31 March 2027.

Since 2016, Deloitte Germany has offered an OECD CbCR outsourcing service and already supports many non-EU-parented MNE groups with conversions of their foreign OECD CbCR XML into a German OECD CbCR XML dataset (including local e-filing in Germany). Starting from 2025, Deloitte Germany has extended its service to EU Public CbCR and can support all non-EU-parented groups with a qualified presence in Germany with a digital bridge of their (existing) foreign OECD CbCR XML dataset into their EU Public CbCR XHTML dataset (including e-disclosure in the German commercial register), which fully exempts most of their other EU subsidiaries and EU branches from local disclosures or local filings (see above).

Action steps for non-EU-parented MNEs preparing for their first EU Public Country-by-Country Reporting disclosure

For many in-scope MNEs who prepare their consolidated financial statements on a calendar-year basis, EU Public CbCR first applies for the entire EU from 1 January 2025 for their financial year 2025. The first EU public register filing (and potentially also website disclosure) is then due by 31 December 2026. For certain in-scope MNEs with deviating year-ends (e.g., 30 June 2024 or 30 September 2024), EU Public CbCR already applies since 1 July 2024 or 1 October 2024. Many Japanese groups with a 31 March year-end have time for their first external reporting until 31 March 2027 for their financial year 25/26 (31 March 2026).

EU Public CbCR will increase the administrative burden for all in-scope MNE groups as they will need to disclose, for the first time, jurisdictional current income tax information to the general public. This new disclosure only relates to EU, EEA and certain non-cooperative jurisdictions, but is currently not legally required and is currently also not yet prepared on a voluntary basis by most MNE groups. MNE groups that are subject to both EU Public CbCR and Australian Public CbCR should note that the list of disclosure jurisdictions under both rulesets is likely to differ.

Many MNE groups want to supplement their EU Public CbCR dataset with additional explanations and want to contextualize the information from the dataset to mitigate potential misinterpretation by the general public, which is now possible in an EU Template prepared according to the EU Taxonomy. Further context or explanations can be provided either directly in the EU Template, as part of an extended website disclosure or via an integration of the EU Public CbCR dataset into an existing or new external reporting framework.

Integrating EU Public CbCR into an existing external or into a new external reporting framework (e.g. ESG, sustainability, total tax contribution, or investor reporting (including Corporate Sustainability Reporting Directive (CSRD)) allows in-scope MNE groups to better explain and to better contextualize the content of their public CbCR dataset. An integrated public CbCR is not only important in the context of EU Public CbCR, but might also simplify reporting requirements and minimize tax exposure under OECD Pillar 2 (e.g. CbCR-Safe-Harbour).

Support from Deloitte on the Public CbCR

Deloitte can provide support and guidance on the new EU Public CbCR disclosure requirements for non-EU-parented groups in all EU member states. More details on EU Public CbCR for non-EU headquartered MNEs can be found in EMEA Dbriefs from 17 March 2026 (note: registration for accessing the recording). If, in addition to new EU Public CbCR, you are also subject to the new Australian Public CbCR, Deloitte can also support you with this new external disclosure (Deloitte).

Deloitte Germany can also help you evaluate whether Germany is a suitable central EU disclosure hub for your EU Public CbCR and can also provide an outsourcing service for the conversion of your existing OECD CbCR XML dataset or file into an EU Public CbCR XHTML dataset if you choose Germany as your central EU disclosure hub. Furthermore, Deloitte can also assist with your external communication strategy and your website disclosure.

Please reach out to Deloitte for further assistance and queries related to EU Public CbCR or Australian Public CbCR.