On 24 December 2025, the National Bank of Belgium (NBB) announced that the new definitive taxonomy including the Public Country-by-Country Reporting (pCbCR) model is accessible on the Central Balance Sheet Office’s website. This update follows the transposition of EU Directive 2021/2101 regarding pCbCR into Belgian law on 8 January 2024 and the Royal Decree on 18 June 2024.
As a reminder, pCbCR obligations generally apply to Ultimate Parent Entities or Standalone undertakings with consolidated revenues exceeding EUR 750 million in each of the last two consecutive financial years. This also includes certain EU subsidiaries or branches of non-EU groups that meet these thresholds.
The ultimate parent company is responsible for filing the report, which must be published on its website and submitted to the NBB within 12 months after the end of the relevant financial year. These rules kick in for financial years starting on or after 22 June 2024. For groups with a calendar-year financial year, this means the first public CbCR will cover the 2025 financial year and should be made publicly available by 31 December 2026.
New Model and Key Changes
In December 2025, the European Commission (EC) launched the pCBCR taxonomy project to help companies prepare the pCBCR using a unified template and the iXBRL format. The EC released the core pCBCR taxonomy file on 22 December 2025. Starting January 2026, a new review cycle will gather feedback from the public to enhance the taxonomy and report generator. The EC announced that updated versions and documentation will be available in July 2026.
The NBB now implemented the EC’s pCbCR taxonomy and form. In accordance with the Belgian implementation, European entities must file the pCbCR in iXBRL (Inline XBRL). Temporary XBRL is permitted only if the EC’s final iXBRL taxonomy is not ready by late 2025 or early 2026. It is currently unclear if the EC’s publication on 22 December 2025 is final, given the ongoing review cycle. Non-European entities can continue using XBRL if they choose not to adopt the EC’s iXBRL taxonomy. Importantly, the NBB confirmed that PDF submissions are not allowed in any case.
Regarding Belgium’s implementation of the pCbCR, it is important to note that:
- The Belgian implementation does not provide for the optional five-year deferral for publishing commercially sensitive information, which is permitted under the EU directive.
- The published form includes a field for explaining material discrepancies between tax accrued and tax paid in a jurisdiction. This disclosure is optional under the European regulation.
- Belgian law allows for an exemption for publication on the website: if specific conditions are met, the report can be filed solely with the NBB.
How can PwC Belgium support?
At PwC we can assist with:
- The preparation of the CbCR, including adapting existing CbCR data to align with the Public CbCR reporting framework.
- Transforming Public CbCR information into the required iXBRL format, ensuring technical compliance and readiness for submission.
- Filing assistance at the NBB.
