Spain's accounting regulator has confirmed that EU-headquartered multinational groups should follow the parent company's national public country-by-country reporting (public CbCR) framework, while Spain's six-month publication deadline continues to apply under its implementation of Directive (EU) 2021/2101.
Spain’s Institute of Accounting and Audit (ICAC) has clarified the application of Spain’s public country-by-country reporting (public CbCR) rules through ICAC Query 5 (BOICAC 144). The guidance confirms that when the ultimate parent company is established in another EU Member State, the applicable reporting framework is determined by the parent company’s national legislation.
The public CbCR requirement, introduced under Directive (EU) 2021/2101 and implemented in Spain through the Audit Law, applies to Spanish-resident ultimate parent entities with consolidated revenue of at least EUR 750 million, as well as Spanish subsidiaries and branches of multinational groups with non-EU parent companies.
Entities within the scope of the rules must publicly disclose jurisdiction-by-jurisdiction information, including revenues, profits, accrued and paid taxes, and the number of employees. The report must also be published on the company’s website and filed with the Commercial Registry together with the annual accounts.
Spain requires public CbCR reports to be published within six months after the financial year-end, making it one of the shortest reporting deadlines in the EU. For calendar-year groups, the first reports may therefore be due by 30 June 2026.
Although the ICAC guidance provides greater certainty for multinational groups operating across the EU, differences in reporting deadlines among Member States remain. Spain implemented the EU Public CbCR Directive in December 2022, including an option for eligible groups to defer disclosure of commercially sensitive information for up to five years under specified conditions.
