Line4

2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

A sum of five rows cannot be less than 0.5 times a calculation over four rows (EBA rule v12100_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

These five worked out cannot be less than 0.5 times total variable remuneration (in EUR) in year N minus guaranteed variable remuneration in year N – total amount minus severance payments awarded in year N – total amount minus for investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: variable remuneratio:

  • Shares or equivalent ownership interests
  • Share-linked instruments or equivalent non-cash instruments
  • Other types of instruments under point (j)(iii) of Article 32(1) of the IFD
  • Non-cash instruments which reflect the instruments of the portfolios managed
  • Approved alternative arrangements

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: Of which: shares or equivalent ownership interests + Of which: share-linked instruments or equivalent non-cash instruments + Of which: other types of instruments under point (j)(iii) of Article 32(1) IFD + Of which: non-cash instruments which reflect the instruments of the portfolios managed + Of which: approved alternative arrangements >= 0.5 × (Total variable remuneration (in EUR) in year N - Guaranteed variable remuneration in year N – total amount - Severance payments awarded in year N – total amount - For investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: variable remuneratio)

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Work out both sides from your file, as the rule in plain words sets out, and compare them.
  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
  • 0140Of which: shares or equivalent ownership interests
  • 0160Of which: share-linked instruments or equivalent non-cash instruments
  • 0180Of which: other types of instruments under point (j)(iii) of Article 32(1) IFD
  • 0200Of which: non-cash instruments which reflect the instruments of the portfolios managed
  • 0220Of which: approved alternative arrangements
  • 0310Guaranteed variable remuneration in year N – total amount
  • 0340Severance payments awarded in year N – total amount
  • 0420For investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: variable remuneratio

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0090Other senior management
  • 0100Other identified staff
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,r0140,c0020,} + {R_02.01,r0160,c0020,} + {R_02.01,r0180,c0020,} + {R_02.01,r0200,c0020,} + {R_02.01,r0220,c0020,}) >= 0.5 * ({R_02.01,r0110,c0020,} - {R_02.01,r0310,c0020,} - {R_02.01,r0340,c0020,} - {R_02.01,r0420,c0020,})

The next three:

({R_02.01,r0140,c0090,} + {R_02.01,r0160,c0090,} + {R_02.01,r0180,c0090,} + {R_02.01,r0200,c0090,} + {R_02.01,r0220,c0090,}) >= 0.5 * ({R_02.01,r0110,c0090,} - {R_02.01,r0310,c0090,} - {R_02.01,r0340,c0090,} - {R_02.01,r0420,c0090,})({R_02.01,r0140,c0010,} + {R_02.01,r0160,c0010,} + {R_02.01,r0180,c0010,} + {R_02.01,r0200,c0010,} + {R_02.01,r0220,c0010,}) >= 0.5 * ({R_02.01,r0110,c0010,} - {R_02.01,r0310,c0010,} - {R_02.01,r0340,c0010,} - {R_02.01,r0420,c0010,})({R_02.01,r0140,c0100,} + {R_02.01,r0160,c0100,} + {R_02.01,r0180,c0100,} + {R_02.01,r0200,c0100,} + {R_02.01,r0220,c0100,}) >= 0.5 * ({R_02.01,r0110,c0100,} - {R_02.01,r0310,c0100,} - {R_02.01,r0340,c0100,} - {R_02.01,r0420,c0100,})

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.