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

Total variable remuneration cannot be more than the sum of two rows (EBA rule v12561_m)

A check in the remuneration benchmarking, credit institutions return (REM benchmarking), on templates R 09.00, remuneration awarded for the financial year and R 10.00, special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff).

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 cannot be more than guaranteed variable remuneration awards -total amount plus severance payments awarded during the financial year - total amount.

All the values are in the MB supervisory function column (0010).

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

The template it checks

Remuneration awarded for the financial year (R 09.00)

Row

  • 0090Total variable remuneration

Column

  • 0010MB Supervisory function

Special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (R 10.00)

Rows

  • 0020Guaranteed variable remuneration awards -Total amount
  • 0070Severance payments awarded during the financial year - Total amount

Column

  • 0010MB Supervisory function
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}.

sum({R_09.00,r0090,c0010,}) <= sum({R_10.00,r0020,c0010,}) + sum({R_10.00,r0070,c0010,})

And 3 more, the same formula for the other cells it covers.

Every REM benchmarking rule, by template

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