The European Union’s Public Country-by-Country Reporting (CbCR) Directive aims to make where multinationals operate and where they pay tax visible to investors, regulators, and the public. To that end, it requires large multinationals to publish jurisdiction-level data on revenues, profits, taxes, and employees. This report asks whether the Directive delivers on that objective. We examine three questions: does the regime add new public information, how complete is the disclosure, and how much of multinational activity does its geographical design make visible? Romania was the first Member State to transpose the Directive, with rules applying from financial year 2023. The Romanian filings are therefore the first mandatory disclosures under a framework that will soon apply across all 27 Member States, and provide the first empirical evidence on how multinationals respond to the Directive.
We construct the first comprehensive dataset of public CbCR filings: 144 multinationals from 24 headquarters countries, covering financial years 2023 and 2024, for a total of 164 reports. No centralised repository exists, and the data requires multilingual searches across company websites, followed by information extraction from heterogeneous PDFs. Each report was read in full and classified by geographical scope, variable completeness, and the reasons firms provide for incomplete disclosure.
Three findings emerge. First, on coverage and additionality: the Directive does add new public information, since the majority of multinationals now publishing have no prior voluntary disclosure history. But coverage falls short of the Directive’s theoretical scope: 20% of the 569 non-EU multinationals estimated to be in scope have published a report. Second, on disclosure quality: 38% of reports are incomplete, most commonly limited to Romania only Apple, Nestlé, and Procter & Gamble among them). The main causes are parent non-cooperation and safeguard clause invocations. Third, on geographical reach: the Directive’s design leaves a large share of multinational activity outside country-level disclosure. Separate reporting is required for EU Member States and jurisdictions on the EU non-cooperative list. Activity in other jurisdictions may be aggregated into a residual “Others” category that absorbs 71% of profits and 74% of revenues in the Romanian data. Because the early reporters are predominantly non-EU-headquartered, this residual is largely a proxy for parent-jurisdiction activity. The non-cooperative list, the Directive’s strongest transparency guarantee, has narrow coverage and qualitative compliance criteria that only partially match the geography of contemporary profit shifting.
Some of these gaps are transitional, while others are structural and require legislative reform. The Commission’s review should prioritise three changes. First, widen disclosure on two axes. Geographically, mandate separate reporting for more jurisdictions, in particular the ultimate parent’s home country. In terms of variables, add items such as tangible assets and the split between related- and unrelated-party revenues. Second, address parent non-cooperation, which currently reduces many subsidiary reports to Romania-only disclosure. Third, establish a centralised repository for filings.