Line4

3 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total fixed remuneration (in EUR) in year N: none of the 82 values it checks in information on remuneration of identified staff in investment firms can be negative (R 02.01, EBA rule v12126_s)

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

For total fixed remuneration (in EUR) in year N: none of the values it checks in information on remuneration of identified staff in investment firms can be negative.

EBA checks it for two columns: MB supervisory function and MB management function. And for 41 rows, from members (headcount) (0010) to for investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: variable remuneratio (0420). That makes 82 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 Supervisory function: Of which: non-cash instruments which reflect the instruments of the portfolios managed >= 0

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Look for a value with the wrong sign in these cells, such as an amount entered as a negative number.
  3. 03EBA compares the values exactly here: there is no rounding tolerance.
  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

  • 0010Members (Headcount)
  • 0030Total fixed remuneration (in EUR) in year N
  • 0040Of which: cash-based
  • 0050Of which: shares or equivalent ownership interests
  • 0060Of which: share-linked instruments or equivalent non-cash instruments
  • 0070Of which: other types of instruments under point (j)(iii) of Article 32(1) IFD
  • 0080Of which: non-cash instruments which reflect the instruments of the portfolios managed
  • 0090Of which: approved alternative arrangements
  • 0100Of which: Other forms
  • 0110Total variable remuneration (in EUR) in year N
  • 0120Of which: cash-based
  • 0130Of which: deferred
  • 0140Of which: shares or equivalent ownership interests
  • 0150Of which: deferred
  • 0160Of which: share-linked instruments or equivalent non-cash instruments
  • 0170Of which: deferred
  • 0180Of which: other types of instruments under point (j)(iii) of Article 32(1) IFD
  • 0190Of which: deferred
  • 0200Of which: non-cash instruments which reflect the instruments of the portfolios managed
  • 0210Of which: deferred
  • 0220Of which: approved alternative arrangements
  • 0230Of which: deferred
  • 0240Of which: Other forms
  • 0250Of which: deferred
  • 0260Total amount of outstanding deferred variable remuneration awarded for previous performance periods and not in year N
  • 0270Of which: due to vest in the financial year
  • 0280Of which: vesting in subsequent financial years
  • 0290Total amount of explicit ex-post performance adjustment made in the financial year to deferred variable remuneration that was due to vest in
  • 0300Total amount of explicit ex-post performance adjustments made in the financial year to deferred variable remuneration that was due to vest i
  • 0310Guaranteed variable remuneration in year N – total amount
  • 0320Guaranteed variable remuneration in year N – total number of beneficiaries
  • 0330Severance payments awarded in previous periods, paid out during the financial year – total amount
  • 0340Severance payments awarded in year N – total amount
  • 0350Of which: deferred severance payments awarded in year N
  • 0360Severance payments awarded in year N – number of beneficiaries
  • 0370Highest amount of severance payments awarded in year N to a single person
  • 0380Number of beneficiaries of contributions to discretionary pension benefits in year N
  • 0390Total amount of contributions to discretionary pension benefits in year N (included in other forms of variable remuneration)
  • 0400Total amount of variable remuneration awarded for multi-year periods under programmes which are not revolved annually
  • 0410For investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: fixed remuneration o

And 1 more.

Columns

  • 0010MB Supervisory function
  • 0020MB Management function

A worked example

The first of its checks, with simple numbers.

What the rule then expects

Non-cash instruments which reflect the instruments of the portfolios managed, MB supervisory function must then be at least 0.

0Passes
-100Fails

A file that reports 0 passes. One that reports -100 fails, by 100.

The numbers are illustrative.

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,r0080,c0010,} >= 0

The next five:

{R_02.01,r0220,c0020,} >= 0{R_02.01,r0360,c0020,} >= 0{R_02.01,r0330,c0020,} >= 0{R_02.01,r0240,c0020,} >= 0{R_02.01,r0320,c0010,} >= 0

And 76 more, the same formula for the other cells it covers.

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.