1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total remuneration cannot be less than variable remuneration (EBA rule v09194_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on template R 01.00, general information and information on remuneration of all staff.

The rule in plain words

Total remuneration (EUR) cannot be less than variable remuneration (EUR).

EBA checks it for eight columns: MB supervisory function, MB management function, investment banking, retail banking, asset management, corporate functions, independent control functions and all other staff. That makes eight checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

MB Supervisory function: Total remuneration (EUR) >= Of which: variable remuneration (EUR)

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark R 01.00 as reported.
  5. 05This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

General information and information on remuneration of all staff (R 01.00)

Rows

  • 0040Total remuneration (EUR)
  • 0050Of which: variable remuneration (EUR)

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0030Investment banking
  • 0040Retail banking
  • 0050Asset management
  • 0060Corporate functions
  • 0070Independent control functions
  • 0080All other staff

A worked example

The first of its checks, with simple numbers.

Illustrative values
Total remuneration (EUR)1,200
What the rule then expects

Variable remuneration (EUR) can then be at most 1,200.

1,200Passes
1,300Fails

A file that reports 1,200 passes. One that reports 1,300 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{R_01.00,r0040,c0010,} >= {R_01.00,r0050,c0010,}

The next five:

{R_01.00,r0040,c0030,} >= {R_01.00,r0050,c0030,}{R_01.00,r0040,c0070,} >= {R_01.00,r0050,c0070,}{R_01.00,r0040,c0020,} >= {R_01.00,r0050,c0020,}{R_01.00,r0040,c0060,} >= {R_01.00,r0050,c0060,}{R_01.00,r0040,c0040,} >= {R_01.00,r0050,c0040,}

And 2 more, the same formula for the other cells it covers.

Every REM benchmarking rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.