Public CbC Reporting in Spain: Review & 2027 Reporting Deadlines

Spain reached the first publication deadline for public Country-by-Country (CbC) reporting on Corporate Income Tax in June 2026. This obligation applies to large multinational groups and standalone undertakings with consolidated annual revenue exceeding €750 million. It became effective for financial years beginning on or after 22 June 2024 and, for companies operating on a calendar-year basis, the first report covered the 2025 financial year. Now that this initial reporting cycle has been completed, it is worth reviewing which entities were required to comply, what information had to be disclosed, and the timetable applicable to the 2026 financial year, whose report must be published before June 2027.

The Origin of the Obligation: From the EU Directive to Spanish Law

The obligation stems from Directive (EU) 2021/2101 of 24 November 2021, which introduced the requirement across the European Union for certain groups and undertakings to publicly disclose tax-related information on a country-by-country basis. Spain transposed this Directive through Law 28/2022 of 21 December, commonly known as the Startup Law, by introducing a new Eleventh Additional Provision into Law 22/2015 of 20 July on Statutory Audit.

Subsequently, Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024, published in the Official Journal of the European Union on 2 December 2024, established the common template and machine-readable electronic formats in which this information must be presented. These requirements apply to financial years beginning on or after 1 January 2025.

Which Entities Were Required to Comply in Spain

The obligation applies to four categories of entities.

First, the ultimate parent undertaking of a group governed by Spanish law that prepares consolidated financial statements and whose consolidated net turnover exceeds €750 million in each of the two preceding financial years.

Second, standalone undertakings—that is, companies that do not form part of a group—where their individual net turnover exceeds the same €750 million threshold in each of the two preceding financial years.

Third, Spanish subsidiaries controlled by an ultimate parent undertaking not governed by the law of a European Union Member State, where the group exceeds the €750 million threshold and the subsidiary does not qualify as a small undertaking under Article 3 of the Spanish Audit Law.

Fourth, branches established in Spain by companies not governed by the law of a Member State, provided equivalent conditions regarding group size are met and no subsidiary is already subject to the reporting obligation.

The legislation also includes an anti-abuse provision under which any subsidiary or branch established solely for the purpose of avoiding this obligation remains subject to it.

Spain’s Six-Month Deadline: The Distinctive Feature of the First Reporting Cycle

The European Directive allows Member States up to twelve months after the end of the financial year for publication of the report. Spain, however, opted for a six-month deadline, aligning the reporting obligation with the timetable established by the Spanish Commercial Code for the approval of annual financial statements.

As a result, for companies operating on a calendar-year basis, the first report covering the 2025 financial year had to be approved, published and filed with the Commercial Registry together with the annual accounts before the end of June 2026. By contrast, in other Member States that adopted more flexible transposition rules, the deadline extends until December 2026.

For multinational groups headquartered outside Spain, this six-month difference effectively reduced the time available to compile the required Country-by-Country information, particularly because much of its content mirrors the information already required since 2016 under Spanish Form 231. Companies that prepared in advance were able to organise data collection well before year-end, whereas those that delayed faced a considerably narrower reporting window than originally envisaged under the Directive.

What Information the Report Had to Include and How It Had to Be Published

The legislation prescribes the report’s content in detail. It must include the undertaking’s revenues, calculated in accordance with the specific rules laid down in the Implementing Regulation, profit or loss before Corporate Income Tax, income tax accrued for the current year’s activities, income tax actually paid on a cash basis, accumulated earnings at year-end, the number of full-time employees, and a description of the activities carried out.

This information must be disclosed separately for each Member State of the European Union, separately for each jurisdiction included on the European Union Council’s lists of non-cooperative tax jurisdictions, and on an aggregated basis for all other tax jurisdictions.

The report had to be approved and published within six months of the financial year-end, remain freely accessible on the company’s website for at least five consecutive years, be available in at least one official language of the European Union, and be filed with the Commercial Registry together with the annual financial statements.

The legislation also allows the temporary omission of specific information where its disclosure would seriously prejudice the company’s commercial position, provided that the omission is duly justified, clearly identified and subsequently remedied in a later report within a maximum period of five years. However, information relating to non-cooperative tax jurisdictions may never be omitted.

Exemptions That Allowed Certain Groups to Avoid Preparing a Separate Spanish Report

Not every entity exceeding the €750 million threshold was required to prepare a separate Spanish report.

Spanish subsidiaries and branches of ultimate parent undertakings not governed by the law of a Member State are exempt where the parent undertaking—or a standalone undertaking not governed by EU law—has already prepared a report containing equivalent information, made it available free of charge in a machine-readable electronic format, published it on the parent’s website in an official language of the European Union within the six-month deadline, and identified the name and registered office of a single subsidiary or branch governed by EU law responsible for making the report publicly available.

Groups and undertakings operating exclusively within the territory of a single Member State are also exempt, as are credit institutions that publish the report required under Article 87 of Law 10/2014, provided that the report covers all of their activities and, where applicable, those of all subsidiaries included within their consolidated financial statements.

The first exemption proved particularly relevant for groups headquartered outside the European Union. However, Spain’s shorter six-month deadline, compared with the twelve-month period permitted under the Directive, raised practical questions regarding the coordination of publication between the foreign parent undertaking and the Spanish timetable—an issue on which the Spanish authorities have not yet issued express guidance.

Public CbC Reporting and Form 231: Two Obligations with Different Degrees of Transparency

Since 2016, Spain has required the filing of Country-by-Country reports through Form 231, governed by Order HFP/1978/2016 of 28 December. This obligation applies to multinational groups whose ultimate parent undertaking is resident in Spain and whose annual consolidated turnover exceeds €750 million, as well as to certain subsidiaries of foreign parent companies.

The Spanish Tax Agency uses this information to prepare aggregated statistical analyses, but Form 231 itself is not publicly available.

The public CbC report introduced by Law 28/2022 shares much of its content with Form 231 but differs in one fundamental respect: the information must be made publicly accessible to anyone through the company’s website.

Companies that had already been filing Form 231 therefore began the transition with much of the required data already available. Nevertheless, they were required to adapt the reporting format and address the reputational implications arising from making this information available to investors, competitors, creditors and the general public.

Looking Ahead: Preparing the 2026 Financial Year Report

With the first reporting cycle now complete, the obligation enters its recurring phase.

Companies with calendar-year financial statements that were subject to the obligation in 2026 must once again approve, publish and file their report for the 2026 financial year before June 2027, and continue doing so annually for as long as they remain above the €750 million threshold for two consecutive financial years.

Companies that exceeded this threshold for the first time during 2026, or that commenced operations in Spain as a subsidiary or branch of a group not governed by EU law, should already assess their reporting position ahead of the next year-end, as the six-month publication window leaves little room for preparation once the financial year has closed.

At ILIA ETL GLOBAL, we recommend that the tax and finance departments of these companies review well in advance the availability of the required country-by-country data, assess whether any of the statutory exemptions apply, and coordinate the preparation of the report with the approval of the annual financial statements so that both processes progress simultaneously and the statutory deadline is met comfortably.

Article prepared by our colleague Xavier Vilalta.

To receive specialized advice on this matter, you may contact through our contact form.