Line4

1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total variable remuneration of all high earners cannot be less than the sum of five rows (EBA rule v12117_m)

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

Check your file against this ruleWhat to do if it fails

The rule in plain words

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

  • Deferred
  • Deferred shares or equivalent ownership interests
  • Deferred share-linked instruments or equivalent non-cash instruments
  • Deferred other instruments
  • Deferred other forms

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 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.

All high earners in investment firms that are subject to Article 25 and 34 of Directive 2019/2034: Total variable remuneration of all high earners (in EUR) >= 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 instruments, 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 04.00 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 the remuneration of high earners (I) (R 04.00.a)

Rows

  • 0100Total variable remuneration of all high earners (in EUR)
  • 0111Of which: deferred
  • 0121Of which: deferred
  • 0123Of which: deferred
  • 0131Of which: deferred
  • 0133Of which: deferred

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.

Illustrative values
deferred1,200
deferred shares or equivalent ownership interests800
deferred share-linked instruments or equivalent non-cash instruments450
deferred other instruments300
deferred other forms150
Together2,900
What the rule then expects

Total variable remuneration of all high earners (in EUR) must then be at least 2,900.

2,900Passes
2,800Fails

A file that reports 2,900 passes. One that reports 2,800 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_04.00.a,r0100,c0090,} >= {R_04.00.a,r0111,c0090,} + {R_04.00.a,r0121,c0090,} + {R_04.00.a,r0123,c0090,} + {R_04.00.a,r0131,c0090,} + {R_04.00.a,r0133,c0090,}

The next five:

{R_04.00.a,r0100,c0020,} >= {R_04.00.a,r0111,c0020,} + {R_04.00.a,r0121,c0020,} + {R_04.00.a,r0123,c0020,} + {R_04.00.a,r0131,c0020,} + {R_04.00.a,r0133,c0020,}{R_04.00.a,r0100,c0010,} >= {R_04.00.a,r0111,c0010,} + {R_04.00.a,r0121,c0010,} + {R_04.00.a,r0123,c0010,} + {R_04.00.a,r0131,c0010,} + {R_04.00.a,r0133,c0010,}{R_04.00.a,r0100,c0050,} >= {R_04.00.a,r0111,c0050,} + {R_04.00.a,r0121,c0050,} + {R_04.00.a,r0123,c0050,} + {R_04.00.a,r0131,c0050,} + {R_04.00.a,r0133,c0050,}{R_04.00.a,r0100,c0070,} >= {R_04.00.a,r0111,c0070,} + {R_04.00.a,r0121,c0070,} + {R_04.00.a,r0123,c0070,} + {R_04.00.a,r0131,c0070,} + {R_04.00.a,r0133,c0070,}{R_04.00.a,r0100,c0030,} >= {R_04.00.a,r0111,c0030,} + {R_04.00.a,r0121,c0030,} + {R_04.00.a,r0123,c0030,} + {R_04.00.a,r0131,c0030,} + {R_04.00.a,r0133,c0030,}

And 3 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.