Public CbCR: first obligations as early as 2026

When does the obligation arise?

Under Directive (EU) 2021/2101 and Sections 32m to 32r of the Accounting Act, Public CbCR applies to accounting periods beginning after 22 June 2024. The obligation to prepare and publish an income tax information report arises where the following statutory thresholds have been met in two consecutive accounting periods:

• for a multinational group, consolidated revenue reaches EUR 750 million;
   
• for a standalone undertaking with a cross-border dimension, net turnover exceeds CZK 19 billion.
   

A standalone undertaking with a cross-border dimension is a Czech company with a branch outside the Czech Republic or a foreign company with a branch or permanent establishment in the Czech Republic. However, such cases will be rare in the Czech Republic: in most cases, the obligation will concern multinational groups, which are discussed below.

The situation is the simplest for groups operating solely within the EU. In such cases, the ultimate consolidating undertaking will fulfil the obligation to prepare and publish the report, and the other EU entities in the group will generally have no further obligations.

Greater attention is required where a Czech entity’s ultimate consolidating undertaking is based outside the EU. If the obligation is not addressed at group level, the Czech entity must fulfil it separately, provided that it meets the statutory conditions (i.e., it is a medium-sized or large undertaking).
 

First reports as early as 2026

For entities whose accounting period began after 22 June 2024, the first reporting period may already have ended in 2025. The report must be published within 12 months of the balance sheet date. For example, for an accounting period ending on 30 June 2025, the report had to be prepared and published by 30 June 2026.

For companies that use the calendar year as their accounting period and meet the relevant conditions, 2025 will be the first reporting period. They will therefore be required to prepare and publish the report by the end of 2026.
 

What must the report contain?

The report includes basic identification, descriptive and financial information, such as the name of the undertaking, the reporting period, the reporting currency, a brief description of activities in each tax jurisdiction, and the number of employees on a full-time equivalent basis.

The financial section includes, in particular, total revenue, profit or loss before income tax, current income tax, income tax paid on a cash basis, and accumulated profits and losses at the end of the period.

The information is also broken down by tax jurisdiction. EU member states and jurisdictions included on the EU lists of non-cooperative jurisdictions / jurisdictions with pending commitments —the ‘blacklist’ and ‘greylist’—must be disclosed separately, while all other jurisdictions may be reported on an aggregated basis.
 

Who will see the report and where

In the Czech Republic, the income tax information report under the Public CbCR obligation is published by filing it in the Collection of Deeds of the Commercial Register no later than 12 months after the balance sheet date.

The undertaking must also publish information about the report on its website. In practice, it may choose one of two options:

• to publish the full text of the report directly on the company’s website; or
   
• to publish a link to the Collection of Deeds together with a brief notice stating that the report is not published in full directly on the company’s website.
   

Whichever option is chosen, this information (i.e., the income tax information report or the link with the notice) must remain available on the website for at least five years.
 

Multiple reporting exemption: when a group report may be used

Groups with a parent undertaking outside the EU may benefit from the multiple reporting exemption (MRE) introduced by the EU directive. The MRE allows a single equivalent group report to be used instead of separate local reports, provided that the statutory conditions are met.

In practice, this means that the non-EU parent undertaking must publish the report on its website in a machine-readable format and in one of the EU’s official languages within 12 months after the end of the accounting period. The report must also identify a specific subsidiary or branch in the EU—the representative entity—which will file it in its national register. It is important that this filing in the national register actually takes place.

If these conditions are met, the Czech entity should generally not be required to prepare its own report, as the obligation is covered by the group report. However, the Czech Accounting Act uses the term ‘equivalent reports’ and does not transpose the MRE mechanism verbatim. From the perspective of Czech companies, we therefore recommend determining whether and how the report was published in national registers and on websites, and verifying whether the MRE conditions were met in the Czech Republic. According to an informal opinion of the General Financial Directorate, the obligation to prepare a separate report should not arise if these conditions are met. We believe that any risk of a strict interpretation can be reduced by voluntarily filing the group report in the Czech Commercial Register.
 

Penalties: why it pays to start early

Failure to prepare or publish the report, or to ensure its publication, may result in a fine of up to 3% of the undertaking’s total assets, or 3% of consolidated assets in the case of a parent undertaking preparing consolidated financial statements.

Public CbCR is not merely an administrative obligation. As the reported information will be publicly accessible, companies should focus not only on ensuring its accuracy and timely publication but also on how it is presented to the public. Early preparation will help groups establish a consistent approach and reduce both penalty and reputational risks.