Article 2 — Transposition

1. Member States shall adopt and publish, by 31 December 2025, the laws, regulations and administrative provisions necessary to comply with this Directive. They shall immediately communicate the text of those measures to the Commission. They shall apply those measures from 1 January 2026. When Member States adopt those measures, they shall contain a reference to this Directive or be accompanied by such a reference on the occasion of their official publication. Member States shall determine how such reference is to be made. 2. Notwithstanding paragraph 1 of this Article, the Member States that have elected not to apply the IIR and the UTPR pursuant to Article 50(1) of Directive (EU) 2022/2523 shall adopt and publish the laws, regulations and administrative provisions necessary to comply with Article 1, point (1) and points (3) to (11), of this Directive by the day before the end of such election. They shall apply those measures from the day after the day such election ends. Notwithstanding the first subparagraph of this paragraph, the Member States that have elected not to apply the IIR and the UTPR pursuant to Article 50(1) of Directive (EU) 2022/2523 and have elected to apply a qualified domestic top-up tax pursuant to Article 11(1) of that Directive shall adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive by the day before the first Reporting fiscal year under the election to apply a qualified domestic top-up tax starts. They shall immediately communicate the text of those measures to the Commission. They shall apply those measures from the beginning of the first Reporting fiscal year under the election to apply a qualified domestic top-up tax. When the first Reporting fiscal year referred to in the third subparagraph of this paragraph begins before or on the day this Directive enters into force, the Member States that have elected not to apply the IIR and the UTPR pursuant to Article 50(1) of Directive (EU) 2022/2523 and have elected to apply a qualified domestic top-up tax pursuant to Article 11(1) of that Directive shall adopt and publish, by 31 December 2025, the laws, regulations and administrative provisions necessary to comply with this Directive. They shall immediately communicate the text of those measures to the Commission. They shall apply those measures from 1 January 2026. When Member States adopt those measures, they shall contain a reference to this Directive or be accompanied by such a reference on the occasion of their official publication. Member States shall determine how such reference is to be made. 3. By way of derogation from paragraph 1 of this Article, Member States shall adopt and publish, by 31 December 2027, the laws, regulations and administrative provisions necessary to comply with Article 1, point (8), of this Directive. They shall immediately communicate the text of those measures to the Commission. They shall apply those measures from 1 January 2028. When Member States adopt those measures, they shall contain a reference to this Directive or be accompanied by such a reference on the occasion of their official publication. Member States shall determine how such reference is to be made. 4. Member States shall communicate to the Commission, the text of the main measures of national law which they adopt in the field covered by this Directive.