1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Number of identified staff benefitting from the above derogation, derogations for identified staff cannot be more than total number of identified staff, total (row 0180, EBA rule v12530_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on templates R 05.00, derogations from the application of requirements to pay out parts of variable remuneration deferred and in instruments under Directive 2013/36/EU (CRD) and R 12.00.b, information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (II).

The rule in plain words

Number of identified staff benefitting from the above derogation, derogations for identified staff under Article 94(3)(b) of the CRD cannot be more than total number of identified staff, total.

How the Line4 Check report words itShow

Word for word as the report shows it when the rule fails.

R_05.00: Number of identified staff benefitting from the above derogation, Derogations for identified staff under Art. 94(3)(b) CRD <= R_12.00.B: Total number of identified staff, Total

What to do if your filing fails it

  1. 01Open the templates below and find the cells the rule reads.
  2. 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.
  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 05.00 and R 12.00 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

Derogations from the application of requirements to pay out parts of variable remuneration deferred and in instruments under Directive 2013/36/EU (CRD) (R 05.00)

Row

  • 0180Number of identified staff benefitting from the above derogation

Column

  • 0020Derogations for identified staff under Art. 94(3)(b) CRD

A worked example

The first of its checks, with simple numbers.

Illustrative values
Number of identified staff benefitting from the above derogation, derogations for identified staff under Article 94(3)(b) of the CRD1,200
What the rule then expects

Total number of identified staff, total must then be at least 1,200.

1,200Passes
1,100Fails

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 writtenShow

EBA's formula. Cells are written as {template, row, column, sheet}.

{R_05.00,r0180,c0020,} <= {R_12.00.b,r0010,c0100,}

Every REM benchmarking rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.