1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total variable remuneration in year N cannot be less than severance payments awarded in previous periods, paid out during the financial year, total amount (EBA rule v12097_m)

A warning in the remuneration benchmarking, investment firms return, REM benchmarking (IF), on template R 02.01, information on remuneration of identified staff in investment firms.

The rule in plain words

Total variable remuneration (in EUR) in year N cannot be less than severance payments awarded in previous periods, paid out during the financial year – total amount.

EBA checks it for four columns: MB supervisory function, MB management function, other senior management and other identified staff. That makes four 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 Management function: Total variable remuneration (in EUR) in year N >= Severance payments awarded in previous periods, paid out during the financial year – total amount

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 02.01 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

Information on remuneration of identified staff in investment firms (R 02.01)

Rows

  • 0110Total variable remuneration (in EUR) in year N
  • 0330Severance payments awarded in previous periods, paid out during the financial year – total amount

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0090Other senior management
  • 0100Other identified staff

A worked example

The first of its checks, with simple numbers.

Illustrative values
Total variable remuneration (in EUR) in year N1,200
What the rule then expects

Severance payments awarded in previous periods, paid out during the financial year – total amount 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_02.01,r0110,c0020,} >= {R_02.01,r0330,c0020,}

The next three:

{R_02.01,r0110,c0100,} >= {R_02.01,r0330,c0100,}{R_02.01,r0110,c0010,} >= {R_02.01,r0330,c0010,}{R_02.01,r0110,c0090,} >= {R_02.01,r0330,c0090,}

Every REM benchmarking (IF) rule, by template

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