The EU’s new Pillar Two compliance manual

On June 10, 2026, the ‘Manual for MNE Groups on Global Minimum Tax (Pillar Two) Compliance Obligations‘ was issued. This provides country level analysis of Pillar Two filings in Austria, Belgium, Croatia, Cyprus, Czech Republic, Finland, France, Germany, Greece, Ireland, Poland, Romania, Slovenia and Sweden.

This was produced under the European Commission’s SG REFORM Technical Support Instrument project on Member State capacity to implement the Pillar Two Directive. It is expressly not official EU interpretative guidance and is based on information available up to 1 May 2026, so domestic updates remain essential.

The manual’s key message is that, although Member States have transposed Directive (EU) 2022/2523, domestic compliance obligations vary materially, particularly where more than one constituent entity exists in a jurisdiction. Some jurisdictions use a designated or liable entity model, while others rely on optional appointments, local allocation rules or entity-by-entity filing.

Central filing under DAC9 v local compliance simplification

DAC9 enables one top-up tax information return to be filed centrally for the group and exchanged between tax administrations. The Commission has stated that Member States had to implement DAC9 by 31 December 2025, that the first top-up tax information return is expected by 30 June 2026, and that tax authorities must exchange the information by 31 December 2026.

But DAC9 generally addresses the information return (the EU equivalent of the OECD GloBE Information Return) not every domestic return, payment, registration, group representative appointment or notification. 

A group may centrally file the GIR/TTIR and still need local actions: registration, notification of the central filer, appointment of a local designated entity, local top-up tax return, payment, portal access, XML schema validation, or evidence of reasonable care. For non-EU central filing, groups must also verify whether the relevant GIR MCAA exchange relationship is in effect for the year; the OECD maintains a page showing activated bilateral exchange relationships for GloBE information under the GIR MCAA.

Deadline map

The manual’s annex provides a useful country-by-country deadline matrix. In general, “15/18 months” refers to 15 months from the end of the relevant fiscal year, extended to 18 months for a transitional year, unless a country-specific rule applies. The annex also notes special rules such as Poland’s 18/21-month timing and Belgium’s first-deadline extensions.

Country Differences