The rule in plain words
Number of high earners (included in row 4) in subsidiaries that are subject to a specific remuneration framework under other union cannot be more than total number of high earners.
EBA checks it for nine columns, from MB supervisory function (0010) to all high earners in investment firms that are subject to Articles 25 and 34 of Directive 2019/2034 (0090). That makes nine checks. A failure names the one that failed.
How the Line4 Check report words itShowHide
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: Number of high earners (included in row 4) in subsidiaries that are subject to a specific remuneration framework under other union <= Total number of high earners
What to do if your filing fails it
- 01Open the template below and find the cells the rule reads.
- 02Compare the values in your file. If the first is bigger than it may be, one of them is wrong: check both before you change either.
- 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
- 04It runs only when your filing indicators mark R 04.00 as reported.
- 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 the remuneration of high earners (I) (R 04.00.a)
Rows
- 0040Total number of high earners
- 0055Of which: Number of high earners (included in row 4) in subsidiaries that are subject to a specific remuneration framework under other union
Columns
- 0010MB Supervisory function
- 0020MB Management function
- 0030Investment banking
- 0040Retail banking
- 0050Asset management
- 0060Corporate functions
- 0070Independent control functions
- 0080All other high earners
- 0090All high earners in investment firms that are subject to Article 25 and 34 of Directive 2019/2034
A worked example
The first of its checks, with simple numbers.
Total number of high earners must then be at least 1,200.
A file that reports 1,200 passes. One that reports 1,100 fails, by 100.
The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.
Show the rule as writtenShowHide
EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.
{R_04.00.a,r0055,c0020,} <= {R_04.00.a,r0040,c0020,}The next five:
{R_04.00.a,r0055,c0060,} <= {R_04.00.a,r0040,c0060,}{R_04.00.a,r0055,c0070,} <= {R_04.00.a,r0040,c0070,}{R_04.00.a,r0055,c0010,} <= {R_04.00.a,r0040,c0010,}{R_04.00.a,r0055,c0090,} <= {R_04.00.a,r0040,c0090,}{R_04.00.a,r0055,c0050,} <= {R_04.00.a,r0040,c0050,}And 3 more, the same formula for the other cells it covers.
Other rules on R 04.00.a
- Total number of high earners must equal the sum of its three parts (row 0040, v12108_m)Warning
- Total variable remuneration of all high earners cannot be less than the sum of five rows (v12117_m)Warning
- Shares or equivalent ownership interests plus share-linked instruments or equivalent non-cash instruments plus other instruments cannot be less than 0.5 times a calculation over five rows (v12121_m)Warning
- None of the 222 values it checks in information on the remuneration of high earners (I) can be negative (v12132_s)Warning
- Total number of high earners must equal the sum of its three parts (row 0040, v12186_m)Warning
- Identified staff cannot be more than total number of high earners (row 0050, v12187_m)Warning
- Identified staff cannot be more than total number of high earners (row 0050, v12188_m)Warning
- Identified staff cannot be more than total number of high earners (row 0050, v12189_m)Warning
Every REM high earners rule, by template
Checks like this one, run at the point of submission, are the first step to real-time supervision.
