Dutch public country-by-country reporting: is your group ready for the first reports due in 2026?

The Netherlands has introduced public country-by-country reporting (CbCR) requirements for large multinational groups. If your group has consolidated revenue above EUR 750 million, you may be required to publicly disclose key information about where you generate profits and pay taxes.

For groups with a calendar financial year, the first report relates to 2025 and must generally be published by the end of 2026 (within 12 months after the end of the relevant financial year). Groups with a non-calendar financial year should check whether an earlier or later deadline applies. The rules primarily affect multinational groups with consolidated revenue above EUR 750 million, including certain Dutch subsidiaries and branches of non-EU groups.

The information in the CbC reports will no longer be available only to tax authorities. It will be publicly accessible through the Dutch trade register and must be published on the company’s website. This means that journalists, NGOs, investors and competitors will be able to review tax data by jurisdiction and calculate effective tax rates per country.

Who is in scope?
The rules generally apply to large multinational groups with consolidated revenue of more than EUR 750 million. They can apply both to groups headquartered in the EU/EEA and to certain Dutch or other EU/EEA entities of groups headquartered outside the EU/EEA. In practice, the main categories are:

• EU/EEA-headquartered groups: the ultimate parent is generally required to publish a report if consolidated revenue exceeds EUR 750 million in at least two consecutive financial years, including the reporting year.
• Large standalone companies: an EU/EEA company that is not part of a group can also be required to report if its revenue exceeds that same threshold.
• EU/EEA subsidiaries of non-EU/EEA groups: certain medium-sized and large subsidiaries may have a reporting obligation where the non-EU/EEA parent group exceeds the threshold.
• EU/EEA branches of non-EU/EEA companies: a branch can be in scope where its net turnover exceeds EUR 12 million and the relevant company or group exceeds the threshold, subject to specific conditions.

There are exceptions: banks and investment firms that already disclose equivalent information under the EU capital requirements framework are excluded, as are groups operating entirely within a single EU/EEA jurisdiction. For non-EU/EEA groups, the rules are particularly relevant where there is no qualifying EU/EEA subsidiary already publishing the report.

If a Dutch subsidiary or branch is required to report but cannot obtain the necessary information from its non-EU/EEA parent, it must publish the information available to it and explain that the parent did not provide the required information.

What will be made public?
The report provides a snapshot of the group’s tax and business activities across different jurisdictions. 

It will include, among other things:

• the name of the ultimate parent or standalone company;
• the relevant financial year and reporting currency;
• the jurisdictions in which the group operates;
• a description of the activities carried out;
• the average number of employees;
• revenue;
• profit or loss before income tax;
• income tax accrued for the year;
• income tax actually paid; and
• accumulated earnings.

Information must be reported separately for each EU/EEA member state, as well as for jurisdictions on the EU’s non-cooperative or grey lists. Information for other jurisdictions outside the EU/EEA can generally be combined into a single “rest of the world” category rather than being disclosed by country.

Can information be withheld?
In limited cases, companies may temporarily withhold specific information if disclosure could seriously harm their commercial position. The threshold for “serious harm” is high: a general concern about competitive sensitivity is unlikely to suffice. The company must explain in the report that information has been withheld and provide reasons. The withheld information must then be disclosed within five years. This exception does not apply to information relating to EU non-cooperative or grey-listed jurisdictions. Given the narrow scope of this safeguard, we recommend assessing early whether any data qualifies and documenting the justification carefully.

Publication and filing
The report must be published on the company’s website, in at least one official EU language, and remain available for five years. It must also be filed with the Dutch trade register within 12 months after the end of the financial year. No separate notification to the Dutch tax authorities is required.

The report must follow the European Commission’s prescribed format. The Dutch trade register currently accepts filings by email; a structured filing option is expected to follow.

What happens if a company does not comply?
Failure to comply is an economic offence under Dutch law. In addition, interested parties can ask the Enterprise Chamber of the Amsterdam Court of Appeal to order compliance. If the company’s annual accounts are subject to a statutory audit, the auditor is required to verify and report on compliance with the public CbCR obligation, meaning that non-compliance is likely to surface during the audit process.

Questions?
Given the end-of-2026 deadline for calendar-year groups, we recommend starting preparations now. We are happy to assist with scoping assessments, data readiness reviews and the preparation of your first public CbCR report. Please feel free to get in touch!