Line4

1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total variable remuneration in year N cannot be less than the sum of seven rows (EBA rule v12098_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.

Check your file against this ruleWhat to do if it fails

The rule in plain words

Total variable remuneration (in EUR) in year N cannot be less than these seven added up:

  • Deferred (under cash-based)
  • Deferred shares or equivalent ownership interests
  • Deferred share-linked instruments or equivalent non-cash instruments
  • Deferred (under other types of instruments under point (j)(iii))
  • Deferred (under non-cash instruments which reflect the instruments of the portfolios managed)
  • Deferred approved alternative arrangements
  • Deferred other forms

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.

Other identified staff: Total variable remuneration (in EUR) in year N >= Of which: cash-based, of which: deferred + Of which: shares or equivalent ownership interests, of which: deferred + Of which: share-linked instruments or equivalent non-cash instruments, of which: deferred + Of which: other types of instruments under point (j)(iii) of Article 32(1) IFD, of which: deferred + Of which: non-cash instruments which reflect the instruments of the portfolios managed, of which: deferred + Of which: approved alternative arrangements, of which: deferred + Of which: Other forms, of which: deferred

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
  • 0130Of which: deferred
  • 0150Of which: deferred
  • 0170Of which: deferred
  • 0190Of which: deferred
  • 0210Of which: deferred
  • 0230Of which: deferred
  • 0250Of which: deferred

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
deferred (under cash-based)1,200
deferred shares or equivalent ownership interests800
deferred share-linked instruments or equivalent non-cash instruments450
deferred (under other types of instruments under point (j)(iii))300
deferred (under non-cash instruments which reflect the instruments of the portfolios managed)150
deferred approved alternative arrangements100
deferred other forms60
Together3,060
What the rule then expects

Total variable remuneration (in EUR) in year N must then be at least 3,060.

3,060Passes
2,960Fails

A file that reports 3,060 passes. One that reports 2,960 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,c0100,} >= {R_02.01,r0130,c0100,} + {R_02.01,r0150,c0100,} + {R_02.01,r0170,c0100,} + {R_02.01,r0190,c0100,} + {R_02.01,r0210,c0100,} + {R_02.01,r0230,c0100,} + {R_02.01,r0250,c0100,}

The next three:

{R_02.01,r0110,c0010,} >= {R_02.01,r0130,c0010,} + {R_02.01,r0150,c0010,} + {R_02.01,r0170,c0010,} + {R_02.01,r0190,c0010,} + {R_02.01,r0210,c0010,} + {R_02.01,r0230,c0010,} + {R_02.01,r0250,c0010,}{R_02.01,r0110,c0020,} >= {R_02.01,r0130,c0020,} + {R_02.01,r0150,c0020,} + {R_02.01,r0170,c0020,} + {R_02.01,r0190,c0020,} + {R_02.01,r0210,c0020,} + {R_02.01,r0230,c0020,} + {R_02.01,r0250,c0020,}{R_02.01,r0110,c0090,} >= {R_02.01,r0130,c0090,} + {R_02.01,r0150,c0090,} + {R_02.01,r0170,c0090,} + {R_02.01,r0190,c0090,} + {R_02.01,r0210,c0090,} + {R_02.01,r0230,c0090,} + {R_02.01,r0250,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.