Line4

3 min readWarningEBA reporting framework 4.2Updated 10 November 2026

None of the 240 values it checks in information on the remuneration of high earners can be negative (R 04.01.a, EBA rule v12149_s)

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).

Check your file against this ruleWhat to do if it fails

The rule in plain words

None of the values it checks in information on the remuneration of high earners can be negative.

EBA checks it for six columns: 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. And for 40 rows, from number of individuals in control functions (0020) to total amount of fixed remuneration of high earners that are not identified staff (0420). That makes 240 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.

Portfolio management: 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 04.01 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 the remuneration of high earners - IFD (I) (R 04.01.a)

Rows

  • 0020Number of individuals in control functions
  • 0030Number of other staff
  • 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
  • 0060Total fixed remuneration (in EUR) in year N of all high earners
  • 0070Of which: cash-based
  • 0080Of which: shares or equivalent ownership interests
  • 0090Of which: share-linked instruments or equivalent non-cash instruments
  • 0100Of which: other types of instruments under Article 32(1)(j)(iii) Directive (EU) 2019/2034
  • 0110Of which: non-cash instruments which reflect the instruments of the portfolios managed
  • 0120Of which: approved alternative arrangements
  • 0130Of which: other forms
  • 0140Total variable remuneration (in EUR) in year N of all high earners
  • 0150Of which: cash-based
  • 0160Of which: deferred
  • 0170Of which: shares or equivalent ownership interests
  • 0180Of which: deferred
  • 0190Of which: share-linked instruments or equivalent non-cash instruments
  • 0200Of which: deferred
  • 0210Of which: other types of instruments under of Article 32(1)(j)(iii) of Directive (EU) 2019/2034
  • 0220Of which: deferred
  • 0230Of which: non-cash instruments which reflect the instruments of the portfolios managed
  • 0240Of which: deferred
  • 0250Of which: approved alternative arrangements
  • 0260Of which: deferred
  • 0270Of which: other forms
  • 0280Of which: deferred
  • 0320Guaranteed variable remuneration awards – number of high earners
  • 0330Guaranteed variable remuneration awards – Total amount
  • 0340Severance payments awarded during the financial year – Number of high earners
  • 0350Severance payments awarded during the financial year - Total amount
  • 0360Number of beneficiaries of contributions to discretionary pension benefits in year N
  • 0370Total amount of contributions to discretionary pension benefits in year N (in EUR)
  • 0380Total amount of variable remuneration awarded for multi- year periods under programmes which are not revolved annually (in EUR)
  • 0390For investment firms that benefit from a derogation at an institutional level Number of high earners benefitting from the derogations under
  • 0400For investment firms that benefit from a derogation at an institutional level Thereof variable remuneration of high earners that are identi
  • 0410Total amount of variable remuneration of high earners that are not identified staff
  • 0420Total amount of fixed remuneration of high earners that are not identified staff

Columns

  • 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.

What the rule then expects

Non-cash instruments which reflect the instruments of the portfolios managed, portfolio management 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_04.01.a,r0110,c0050,} >= 0

The next five:

{R_04.01.a,r0200,c0060,} >= 0{R_04.01.a,r0230,c0080,} >= 0{R_04.01.a,r0041,c0070,} >= 0{R_04.01.a,r0090,c0040,} >= 0{R_04.01.a,r0060,c0030,} >= 0

And 234 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.