1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total number of high earners must equal the sum of its three parts (row 0040, EBA rule v12109_m)

A warning in the high earners, investment firms return, REM high earners (IF), on template R 04.01.a, information on the remuneration of high earners - IFD (I).

The rule in plain words

Total number of high earners must equal these three added up:

  • Number of male high earners
  • Number of female high earners
  • Number of high earners that have a different gender than the male or female gender

EBA checks it for eight columns: MB supervisory function, MB management function, dealing on own account, underwriting and placing of instruments, investment advice, order execution, portfolio management, operation of MTF/OTF, 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 Management function: Total number of high earners = Of which: number of male high earners + Of which: number of female high earners + Of which: number of high earners that have a different gender than the male or female gender

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Add up the parts in your file and compare the result with the total.
  3. 03If they differ, a part is missing, a value sits in the wrong cell, or the total is out of date.
  4. 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  5. 05It runs only when your filing indicators mark R 04.01 as reported.
  6. 06This 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 the remuneration of high earners - IFD (I) (R 04.01.a)

Rows

  • 0040Total number of high earners
  • 0041Of which: number of male high earners
  • 0042Of which: number of female high earners
  • 0043Of which: number of high earners that have a different gender than the male or female gender

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0030Dealing on own account, underwriting and placing of instruments
  • 0040Investment advice, order execution
  • 0050Portfolio management
  • 0060Operation of MTF/OTF
  • 0070Independent control functions
  • 0080All other staff

A worked example

The first of its checks, with simple numbers.

Illustrative values
number of male high earners1,200
number of female high earners800
number of high earners that have a different gender than the male or female gender450
Together2,450
What the rule then expects

Total number of high earners must then be 2,450.

2,450Passes
2,550Fails

A file that reports 2,450 passes. One that reports 2,550 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_04.01.a,r0040,c0020,} = {R_04.01.a,r0041,c0020,} + {R_04.01.a,r0042,c0020,} + {R_04.01.a,r0043,c0020,}

The next five:

{R_04.01.a,r0040,c0030,} = {R_04.01.a,r0041,c0030,} + {R_04.01.a,r0042,c0030,} + {R_04.01.a,r0043,c0030,}{R_04.01.a,r0040,c0050,} = {R_04.01.a,r0041,c0050,} + {R_04.01.a,r0042,c0050,} + {R_04.01.a,r0043,c0050,}{R_04.01.a,r0040,c0060,} = {R_04.01.a,r0041,c0060,} + {R_04.01.a,r0042,c0060,} + {R_04.01.a,r0043,c0060,}{R_04.01.a,r0040,c0010,} = {R_04.01.a,r0041,c0010,} + {R_04.01.a,r0042,c0010,} + {R_04.01.a,r0043,c0010,}{R_04.01.a,r0040,c0040,} = {R_04.01.a,r0041,c0040,} + {R_04.01.a,r0042,c0040,} + {R_04.01.a,r0043,c0040,}

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

Every REM high earners (IF) rule, by template

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