Public CbCR, or public Country-by-Country Reporting, is an obligation based on EU Directive 2021/2101, applicable for financial years starting after 22 June 2024 — for most companies, from the 2025 financial year.
The regulation applies to multinational enterprise groups whose consolidated revenue exceeds EUR 750 million — or HUF 275 billion in the case of Hungarian groups — in two consecutive financial years. The affected groups, and where applicable their Hungarian subsidiaries or branches, must publish their tax and financial data in a structured, machine-readable XHTML/XML-based format simultaneously with their annual or consolidated annual financial statements.
When does a Public CbCR obligation arise in Hungary?
The regulation applies to groups whose consolidated revenue exceeds EUR 750 million — HUF 275 billion — in two consecutive financial years. Under Section 134/E of the Hungarian Accounting Act, the report must be published in Hungary in the following cases:
- The ultimate parent undertaking of the group is a company registered in Hungary.
- Subsidiary of a non-EU parent undertaking:
- The Hungarian entity is required to prepare annual financial statements, and its ultimate parent undertaking is not governed by the law of an EU Member State, provided that there is no
- Hungarian branch of a non-EU group: Provided that the group does not have a subsidiary registered in another EU Member State that already fulfils the obligation.
In the case of a non-EU parent undertaking, the subsidiary may be exempt if the parent undertaking itself publishes the report in a machine-readable format within 12 months of the balance sheet date of the financial year, in accordance with Section 134/E(17) of the Hungarian Accounting Act. In the case of an EU parent undertaking, the publication obligation is generally fulfilled by the parent undertaking; therefore, the Hungarian subsidiary does not have a separate publication obligation.
Public CbCR obligation – what must be published and when?
Publication must be aligned with the filing deadline for the annual or consolidated annual financial statements. The report must be filed with the Court of Registration and, at the same time, published on the company’s website, where it must remain available for at least five years.
| Type of obligated entity | End of relevant financial year | Deadline for calendar-year |
|---|---|---|
| Ultimate parent undertaking — consolidated | 31 December 2025 | 30 June 2026 |
| Standalone undertaking / subsidiary — annual financial statements | 31 December 2025 | 31 May 2026 |
Why is XML format critical when preparing the Public CbCR report?
The Public CbCR report must be prepared in a machine-readable electronic XHTML/XML-based format, in line with the uniform data structure and publication requirements defined by the European Commission, in accordance with Section 134/F(4) of the Hungarian Accounting Act. In practice, this does not mean completing a traditional form, but rather creating a structured, tagged dataset that requires accurate preparation from both a technical and content perspective.
As a result of machine readability, the published data can be easily compared with the data of other groups. Differences can quickly become visible, and the figures — without the underlying business context — may also be interpreted by external stakeholders, such as investors, competitors or the media.
RSM’s services related to the preparation of the Public CbCR report
Assessment of the Public CbCR obligation position
We examine whether the Hungarian entity has a separate Public CbCR publication obligation or whether an exemption may be available, for example based on publication by the parent undertaking. This analysis depends on the group structure, the registered seat of the parent undertaking and the group’s other EU members.
Data content preparation and XML compilation
We assist with collecting the mandatory data elements, coordinating with the group headquarters, and technically compiling the machine-readable XML file in line with the European Commission’s template, while ensuring compliance with the formal requirements applicable to filing with the Court of Registration and publication on the company’s website.
Management of Public CbCR deadlines and process
The Hungarian publication deadline is aligned with the domestic filing deadline for annual financial statements, which is typically earlier than the deadline applicable in other Member States where the group operates. We help establish the internal workflow required to ensure that group-level data is available on time.
Preparation of a non-cooperation statement
If the parent undertaking does not provide the required data in time, the law allows for the publication of a so-called non-cooperation statement. This is not an exemption — the publication obligation remains in place — but rather a documented record of responsibility. We assist in preparing this statement in a professionally appropriate manner.
Are you interested in our Public CbCR report preparation service?
