2 min readSwitched off by EBAEBA reporting framework 4.2Updated 10 November 2026

Total variable remuneration of all high earners cannot be less than the sum of four rows (EBA rule v12115_m)

A check in the high earners, credit institutions return (REM high earners), on template R 04.00.a, information on the remuneration of high earners (I).

EBA switched this rule off in its 4.2 severity package (January 2026), so it does not run on reporting framework 4.2 filings. EBA's list of validation rules of 12 October 2026 still has it switched off. Line4 Check does not run it either.

The rule in plain words

Total variable remuneration of all high earners (in EUR) cannot be less than these four added up:

  • Guaranteed variable remuneration awards – total amount
  • Severance payments awarded during the financial year - total amount
  • Total amount of contributions to discretionary pension benefits in year N (in EUR)
  • Total amount of variable remuneration awarded for multi- year periods under programmes which are not revolved annually (in EUR)

All the values are in the all high earners in investment firms that are subject to Articles 25 and 34 of Directive 2019/2034 column (0090) of R 04.00.a.

EBA writes it out nine times. These words are for the first; the others are the same rule on other cells.

The template it checks

Information on the remuneration of high earners (I) (R 04.00.a)

Rows

  • 0100Total variable remuneration of all high earners (in EUR)
  • 0182Guaranteed variable remuneration awards – Total amount
  • 0200Severance payments awarded during the financial year - Total amount
  • 0210Total amount of contributions to discretionary pension benefits in year N (in EUR)
  • 0220Total amount of variable remuneration awarded for multi- year periods under programmes which are not revolved annually (in EUR)

Column

  • 0090All high earners in investment firms that are subject to Article 25 and 34 of Directive 2019/2034
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_04.00.a,r0100,c0090,} >= {R_04.00.a,r0182,c0090,} + {R_04.00.a,r0200,c0090,} + {R_04.00.a,r0210,c0090,} + {R_04.00.a,r0220,c0090,}

And 8 more, the same formula for the other cells it covers.

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.