28 january 2026
The French authorities have released new reporting obligation modalities regarding public CbyC reports. The multiple reporting exemption has now been transposed into French law. Additionally, the public CbyC report may be prepared in any official language of the EU (there is no longer an obligation to prepare the report in French).
TRANSPOSITION OF THE MULTIPLE REPORTING EXEMPTION
The public CbCR Directive provides that Member States shall not apply the reporting obligation to EU subsidiaries or branches, where a report on income tax information is drawn up by an ultimate parent undertaking or standalone undertaking that is not governed by the law of a Member State (Article 48c), provided the following criteria are met:
- The report is made accessible to the public, free of charge, and in an electronic, machine-readable format:
- on the website of the parent or standalone company;
- in at least one official language of the EU;
- within 12 months following the end of the relevant financial year, it identifies the name and the registered office of a single subsidiary undertaking, or the name and the address of a single branch governed by the law of a Member State, which is designated to submit the report to the relevant national commercial register (art. 48b, 1).
In other words, the EU subsidiaries and branches are exempt from their obligations if the non-EU parent has published the report on its website and has assigned one of the EU subsidiaries or branches to file the report with their national commercial register.
This multiple reporting exemption had not been transposed into French law until now, even though Member States do not have the possibility to opt out of this exception.
A decree has finally been released and transposes this exception into French law as from 28 December 2025.
THE PUBLIC CBYC REPORT MAY BE PREPARED IN ANY OF THE OFFICIAL LANGUAGES OF THE EU
Until now, the French rules required the public CbyC reports to be prepared in French.
As of 28 December 2025, this obligation no longer applies. The public CbyC report may be prepared in any official language of the EU.
