Public CbCR: EU Directive 2021/2101 Compliance Guide, Scope, and iXBRL Format (2025)

Quick Answer: Public CbCR (EU Public Country-by-Country Reporting)

Public CbCR in the EU is a requirement for large groups to publish a “report on income tax information” with selected tax and business KPIs by jurisdiction under Directive (EU) 2021/2101 (Accounting Directive Articles 48a–48h). If consolidated revenue exceeds €750m in each of the last two consecutive financial years, EU-headed groups (and certain non‑EU groups with qualifying EU subsidiaries/branches) may be in scope (Accounting Directive Art. 48b). The report must be published within 12 months after the balance sheet date (Accounting Directive Art. 48d(1)). The EU-level “latest” commencement date is financial years starting on/after 22 June 2024 (Accounting Directive Art. 48g), which means FY 2025 is the first in-scope year for many calendar‑year groups. From FYs starting on/after 1 Jan 2025, Implementing Regulation (EU) 2024/2952 applies and sets the common template plus XHTML + iXBRL mark-up requirements.

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What EU Public CbCR is (and how it differs from “tax authority CbCR”)

EU Public CbCR is not a transfer pricing filing in the classic sense—it is public corporate disclosure designed to put selected income-tax information into the public domain.

Legal basis and terminology

The core requirement is introduced by Directive (EU) 2021/2101, which amends the Accounting Directive (Directive 2013/34/EU) by adding Chapter 10a (Articles 48a–48h). The deliverable is formally a “report on income tax information” (Accounting Directive Art. 48c).

Public CbCR vs OECD/DAC4 CbCR (practitioner differences that matter)

Stakeholders (investors, media, works councils, NGOs) often compare Public CbCR outputs to a group’s tax narrative, financial statements, and—where leaked—confidential CbCR. You should assume comparability questions will arise even when the rules differ.

Why Public CbCR is a transfer pricing and tax controversy issue

Public CbCR data is frequently interpreted as a proxy for “where profit is booked vs where tax is paid,” even though the required fields reflect accounting and cash tax mechanics, not transfer pricing policy per se.

Common “optics triggers” include:

• Low current tax accrued in a profitable jurisdiction (incentives, tax holidays, prior-year true-ups, permanent differences)
• Cash tax paid ≠ current tax accrued (audit settlements, withholding taxes, timing differences)
• Loss-making jurisdictions with headcount and revenues (business cycle, impairment, restructuring)
• High accumulated earnings in specific jurisdictions (historic profitability, dividend policy, local statutory accounts)

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Who must comply with EU Public CbCR (scope and thresholds)

The scope rules are in Accounting Directive Art. 48b and hinge on (i) size, and (ii) whether the group is EU-headed or non‑EU-headed with qualifying EU presence.

The €750m revenue test (two consecutive years)

As a general rule, an undertaking is in scope when consolidated revenue (or revenue for a standalone undertaking) exceeds €750,000,000 for each of the last two consecutive financial years, and the report is prepared for the latter of those two years (Accounting Directive Art. 48b(1)).

EU-headed groups and EU standalone undertakings

An EU ultimate parent undertaking (UPE) (or an EU standalone undertaking) meeting the threshold must publish the report (Accounting Directive Art. 48b).

Key exemption: where the group operates only within one Member State and no other tax jurisdiction, Member States must provide that the obligation does not apply (Accounting Directive Art. 48b(2)).

Banking/CRD “already reporting” exclusion: Member States must also provide that the rule in Art. 48b(1) does not apply where the undertaking (or its affiliated undertakings) already discloses a report under CRD (Directive 2013/36/EU) Article 89 that covers all activities (and, for an EU UPE, all group activities included in consolidated financial statements) (Accounting Directive Art. 48b(3)). This is a meaningful carve-out for many credit institutions.

Non‑EU-headed groups: “pull‑in” via EU subsidiaries and branches

A non‑EU group that meets the €750m threshold can still be pulled into EU Public CbCR through:

• Medium-sized or large EU subsidiaries (as defined under the Accounting Directive size regime as transposed), and/or
• Certain EU branches meeting Member State turnover thresholds (Directive 2021/2101 amending framework; implemented through national law)

Accounting Directive Art. 48b provides the architecture, but the practical trigger points (especially for branches and “medium/large” status) can vary because they rely on national transposition and the Accounting Directive’s size definitions (including updates under Delegated Directive (EU) 2023/2775).

Proxy publication relief (non‑EU parent publishes once)

To avoid multiple EU subsidiaries/branches publishing overlapping reports, a non‑EU parent can prepare a compliant report and have one designated EU entity publish it—subject to conditions (Accounting Directive Art. 48b and Art. 48d mechanics). The report must be publicly accessible free of charge, in a machine-readable format, and in at least one EU official language within 12 months.

If the non‑EU parent refuses to provide information

If an in-scope EU subsidiary/branch cannot obtain all required information from the non‑EU parent, it may need to publish:

• the information it has/obtains, and
• a statement that the UPE did not make the necessary information available (Accounting Directive Art. 48b(4)–(5)).

This is a compliance outcome you want to avoid because it creates inconsistent, partial, and potentially misleading public disclosures.

Scope decision table (practical triage)

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What must be disclosed in a Public CbCR report (data fields and jurisdiction split)

The content requirements sit in Accounting Directive Art. 48c(2). They are narrower than OECD CbCR, but still enough to generate reputational narratives if not curated and explained.

Required data fields (what the public will see)

For each in-scope jurisdiction line, the report includes:

• Nature of activities
• Number of employees (FTE)
• Revenues (including related-party transactions; computed per Accounting Directive Art. 48c(2)(d))
• Profit or loss before income tax
• Income tax accrued (the current tax expense recognised on taxable profits or losses; it must not include deferred taxes or provisions for uncertain tax liabilities — Accounting Directive Art. 48c(2)(f))
• Income tax paid (cash tax; can include certain withholding taxes paid by others on behalf of group members — Accounting Directive Art. 48c(2)(g))
• Accumulated earnings (as defined in Accounting Directive Art. 48c(2)(h))

It also includes identifying information such as the name of the reporting undertaking, financial year, currency, and (for certain jurisdictions) lists of subsidiaries (Accounting Directive Art. 48c(2)).

Jurisdictional breakdown: EU vs lists vs “rest of world”

Public CbCR requires different granularity than OECD CbCR:

• Always separate: each EU Member State
• Separate: jurisdictions on the EU list of non‑cooperative jurisdictions (Annex I) as of 1 March of the financial year
• Separate: jurisdictions on Annex II (“grey list”) that appear on 1 March of the financial year and on 1 March of the preceding financial year (i.e., two consecutive years)
• Aggregate: all other non‑EU jurisdictions into a single “rest of world” line

(See Accounting Directive Art. 48c(5).)

Where the numbers usually come from (and where they commonly break)

A robust operating model maps each disclosure field to a data owner and source system:

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When and how to publish (deadlines, registers, websites, and iXBRL)

Effective dates: why FY 2025 is the “first real year” for many groups

At EU level, Member States must apply Public CbCR rules at the latest for financial years starting on or after 22 June 2024 (Accounting Directive Art. 48g). For most calendar-year groups, that points to:

• First in-scope year (typical): FY 2025 (1 Jan 2025 – 31 Dec 2025)
• Publication deadline: within 12 months of year end → 31 Dec 2026

The 12‑month rule is in Accounting Directive Art. 48d(1).

Publication channels and retention

The report must generally be:

• filed in the relevant national register (company law filing), and
• made accessible on the undertaking’s website,

free of charge, in at least one EU official language, and kept available for at least five years (Accounting Directive Art. 48d).

A Member State may allow a register-only approach if the register provides free, machine-readable access and the company website provides a link/notice (Accounting Directive Art. 48d(3)).

Digital format: XHTML + Inline XBRL (iXBRL) for reports for FYs starting 1 Jan 2025

For reports on income tax information for financial years starting on or after 1 January 2025, the EU standardized template and electronic reporting format are set by Commission Implementing Regulation (EU) 2024/2952. In short: XHTML with embedded Inline XBRL (iXBRL) tags using the Commission’s Public CbCR taxonomy.

Operationally, this changes project planning:

• You are not just compiling a table—you are producing a digitally tagged disclosure
• Data, narrative, and sign-offs must be ready early enough to support tagging, validation, and register filing

What is actually tagged (and what is optional) under Implementing Regulation 2024/2952

If you are building an iXBRL workplan, the key practical point is that the regulation distinguishes between:

• Mandatory mark-ups: disclosures must be tagged using the core taxonomy elements listed in Table 2 of Annex IV, in line with Annex III marking-up and filing requirements; and
• Optional additional mark-ups: undertakings may additionally tag using Table 3 of Annex IV.

This leads to a practical readiness checklist:

• Map each required Public CbCR data field to a taxonomy element (start with the Table 2 set).
• Decide whether any Table 3 (optional) tags add value (or create more review overhead).
• Build validations into the timeline (XHTML well‑formedness, iXBRL embedding, required tags present, consistent units/currency).
• Do an “acceptance test” with your target register filing workflow before the statutory deadline.

Governance, responsibility, and the auditor “presence check”

Member States must impose responsibility on the administrative/management/supervisory bodies, and (where a statutory audit is required) the auditor must state whether the report was required and whether it has been provided/published as required (Accounting Directive Arts. 48e–48f).

That means EU Public CbCR becomes part of the annual reporting perimeter—even if tax teams own the content.

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The safeguard clause: can you delay sensitive disclosures?

Accounting Directive Art. 48c(6) includes an option for Member States to permit temporary omission of certain information where disclosure would be seriously prejudicial to the commercial position of the undertaking.

Key features practitioners should operationalize:

• Omitted information must be disclosed in a later report, and the deferral cannot exceed five years (Accounting Directive Art. 48c(6)).
• No omission is allowed for information pertaining to tax jurisdictions included in Annex I and Annex II (Accounting Directive Art. 48c(6)).
• Member States may implement stricter rules (shorter deferral periods or narrower eligibility).
• In practice, you should assume regulators and stakeholders will expect a clear justification and a re-publication calendar.

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How to prepare for Public CbCR (a practical implementation playbook)

Public CbCR is easiest when treated as an annual reporting product with a repeatable process, not a one-off compilation exercise.

Step 1: Confirm scope early (and centralize the decision)

Recommended timing: before year end for the first in-scope year.

• Confirm the two-year €750m revenue test and the “report for the latter year” mechanic (Accounting Directive Art. 48b(1))
• For non‑EU parents, assess EU subsidiaries’ “medium/large” status by Member State (national transposition can affect sizing)
• Decide whether to use a proxy approach (single parent-prepared report) to avoid multiple EU filings (Accounting Directive Art. 48b(6) mechanics)

Step 2: Decide your “definition set” (Public CbCR-native vs DAC-aligned)

Accounting Directive Art. 48c(3) allows Member States to permit use of DAC Annex III instructions for certain items. The most important operational decision is whether your Public CbCR will:

• follow Public CbCR-native definitions (as drafted in Chapter 10a), or
• be DAC-aligned for consistency with confidential CbCR and internal tax risk processes

Step 3: Build a reconciliation and “story” layer (before you publish)

The Directive does not require a reconciliation to consolidated financial statements, but in practice you need a defensible bridge for internal sign-off and external questions.

Minimum controls most groups implement:

• Revenue and PBT tie-outs to consolidation (at least at a high level)
• Current tax accrued tie-out to the current tax provision
• Cash tax paid tie-out to treasury/cash tax tracker, with a withholding tax protocol
• A variance analysis for “optics outliers” (e.g., low accrued tax in profitable jurisdictions)

Step 4: Prepare narrative disclosures proactively

The Directive explicitly allows an overall narrative to explain material discrepancies between accrued tax and cash tax paid (Accounting Directive Art. 48c(7)). Use this to pre-empt predictable misinterpretations:

• timing differences (accrued vs paid)
• loss utilization, audits, prior-year settlements
• one-off items (restructuring, impairments)
• changes in footprint (acquisitions/disposals)

Step 5: Treat iXBRL as a workstream, not a formatting step

For reports for FYs starting on/after 1 Jan 2025 (Implementing Regulation (EU) 2024/2952), plan:

• taxonomy mapping and tagging rules (at minimum, the mandatory element set)
• validation checks and sign-offs
• register filing mechanics per Member State
• website publication workflow and 5-year retention controls (Accounting Directive Art. 48d)

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Practical Examples (with numbers)

Example 1: EU-headed calendar-year group—first report for FY 2025, publish by 31 Dec 2026

Facts

• UPE is established in an EU Member State.
• Consolidated revenue:
  • FY 2024: €820m
  • FY 2025: €860m
• Threshold met in both FY2024 and FY2025 → in scope to draw up a report for FY2025 (the latter of the last two consecutive financial years) (Accounting Directive Art. 48b(1)).
• EU-level “latest” commencement: FYs starting on/after 22 Jun 2024 → first calendar-year in-scope FY is typically 2025 (Accounting Directive Art. 48g).
• Publication deadline: 12 months after 31 Dec 2025 → 31 Dec 2026 (Accounting Directive Art. 48d(1)).

Illustrative Public CbCR extract (€, millions; employees = FTE)

What the tax team should flag before publication

• France shows cash tax paid > accrued. Without context, readers may assume an error.
• Add a narrative note (permitted under Accounting Directive Art. 48c(7)) such as: “Cash tax includes €5m settlement of prior-year audit assessments.”

Example 2: US-headed group with a large EU subsidiary—why proxy publication matters

Facts

• UPE is in the United States (non‑EU).
• Consolidated revenue:
  • FY 2024: €5.2bn
  • FY 2025: €5.4bn
• EU footprint: a large subsidiary in Ireland and another EU branch that meets the local turnover trigger.
• Parent is reluctant to publish globally.

Option A (recommended where feasible): proxy publication

Parent prepares a single compliant Public CbCR report and designates the Irish subsidiary to publish it, meeting the conditions in Accounting Directive Art. 48b/48d (free public access, machine readable, EU language, within 12 months). Outcome: one consistent EU report.

Option B (high-risk): parent refuses to provide information

Irish subsidiary must publish what it can and include a statement that the UPE did not provide required information (Accounting Directive Art. 48b(4)). This can produce an incomplete “rest of world” line and inconsistent disclosures across Member States.

Illustrative “partial” outcome (what investors will see)

Accompanied by a statement: “The ultimate parent undertaking did not make the necessary information available.”

Example 3: Accrued vs paid tax optics—how timing differences create “false low tax” narratives

Assume a jurisdiction shows:

• P/L before tax: €100m
• Current tax accrued (current tax expense): €20m
• Cash tax paid: €5m

A simplistic reader may compute a “cash ETR” of 5% and claim low taxation. But if the €15m difference reflects:

• €12m paid next year due to instalment mechanics, and
• €3m of tax credits utilized against current tax,

then the disclosure is economically consistent—just poorly explained.

A concise narrative note could say:

“Cash tax paid reflects instalment timing and utilization of €3m of credits; the current tax accrued is aligned to taxable income for the year.”

This type of narrative reduces controversy risk without changing any numbers.

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Related Topics (recommended next reading)

• Hub (Pillar Two + CbCR): /blog/pillar-two-cbcr-guide
• CbCR processes and controls (confidential CbCR): /blog/cbcr-preparation-guide
• Pillar Two documentation context: /blog/transfer-pricing-documentation-guide
• Benchmarking fundamentals (Pillar One / TP): /blog/benchmarking-study-guide

Glossary:

• Public CbCR: /glossary/public-cbcr
• Country-by-country report (CbCR): /glossary/country-by-country-report

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FAQ: EU Public CbCR (Directive 2021/2101)

1) What is EU Public CbCR?

EU Public CbCR is a requirement for certain large undertakings to publicly disclose a “report on income tax information” by jurisdiction under Directive (EU) 2021/2101 and the Accounting Directive Articles 48a–48h.

2) How is Public CbCR different from OECD (tax authority) CbCR?

OECD/DAC4 CbCR is confidential and exchanged between tax authorities; EU Public CbCR is public, has a different data set (Accounting Directive Art. 48c), and allows aggregation of most non‑EU jurisdictions into “rest of world.”

3) Who is in scope for EU Public CbCR?

Generally, EU UPEs/standalone undertakings and certain non‑EU groups with qualifying EU subsidiaries/branches are in scope when revenue exceeds €750m in each of the last two consecutive financial years and the report is prepared for the latter year (Accounting Directive Art. 48b). Credit institutions already reporting under CRD Article 89 may be excluded, depending on how the rule applies to the group (Accounting Directive Art. 48b(3)).

4) What information must be disclosed in a Public CbCR report?

Per Accounting Directive Art. 48c(2), disclosures include activities, employees, revenues, profit/loss before tax, current tax accrued (excluding deferred tax and provisions for uncertain tax liabilities), cash tax paid, accumulated earnings, and certain identifying information.

5) When is the first reporting year for calendar-year groups?

At EU level, Member States must apply the rules at the latest for financial years starting on/after 22 June 2024 (Accounting Directive Art. 48g), so many calendar-year groups start with FY 2025. However, some Member States chose earlier local effective dates, so your first reporting year can be earlier depending on where you operate.

6) When is EU Public CbCR publication due?

The report must be published within 12 months after the balance sheet date (Accounting Directive Art. 48d(1)). For FY 2025 calendar-year filers, this is typically 31 Dec 2026.

7) Where must the report be published?

It must generally be filed in the national register and made available on the undertaking’s website, free of charge, in at least one EU official language, and kept accessible for five years (Accounting Directive Art. 48d), subject to Member State options for register-only publication.

8) Do we need iXBRL/XHTML tagging for Public CbCR?

For reports for financial years starting on/after 1 Jan 2025, Implementing Regulation (EU) 2024/2952 applies and sets the common template and XHTML with Inline XBRL (iXBRL) mark-up requirements.

9) Can companies omit commercially sensitive information (safeguard clause)?

Member States may permit temporary omission where disclosure would be seriously prejudicial, with later re-disclosure and a maximum deferral period under the Directive’s framework (Accounting Directive Art. 48c(6)). Information for Annex I/II listed jurisdictions cannot be omitted, and national rules can be stricter—so local legal review is essential.

10) What’s the biggest practical risk for multinational groups?

The biggest risk is publishing technically correct numbers that are easily misinterpreted (especially current tax accrued vs cash tax paid) without a narrative and without robust controls—creating avoidable reputational and controversy exposure in the first publication cycle.