Line4

1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Variable remuneration: a balancing check across remuneration awarded for the financial year and information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (R 09.00, R 12.00.a, EBA rule v12563_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on templates R 09.00, remuneration awarded for the financial year and R 12.00.a, information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (I).

Check your file against this ruleWhat to do if it fails

The rule in plain words

For variable remuneration: take these four added up, all for total variable remuneration:

  • Other senior management
  • MB management function
  • Other identified staff
  • MB supervisory function

The result must equal these seven added up, all for variable remuneration:

  • Total MB
  • Retail banking
  • Asset management
  • Independent internal control functions
  • All other
  • Investment banking
  • Corporate functions

The headline gives only the kind of check and the template, because some of its cells have no name of their own in EBA’s template.

How the Line4 Check report words itShow

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

R_09.00: Total variable remuneration, Other senior management + R_09.00: Total variable remuneration, MB Management function + R_09.00: Total variable remuneration, Other identified staff + R_09.00: Total variable remuneration, MB Supervisory function = R_12.00.A: Of which: variable remuneration, Total MB + R_12.00.A: Of which: variable remuneration, Retail banking + R_12.00.A: Of which: variable remuneration, Asset management + R_12.00.A: Of which: variable remuneration, Independent internal control functions + R_12.00.A: Of which: variable remuneration, All other + R_12.00.A: Of which: variable remuneration, Investment banking + R_12.00.A: Of which: variable remuneration, Corporate functions

What to do if your filing fails it

  1. 01Open the templates below and find the cells the rule reads.
  2. 02Work out both sides from your file, as the rule in plain words sets out, and compare them.
  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 09.00 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

Remuneration awarded for the financial year (R 09.00)

Row

  • 0090Total variable remuneration

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0030Other senior management
  • 0040Other identified staff

Information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (I) (R 12.00.a)

Row

  • 0060Of which: variable remuneration

Columns

  • 0030Total MB
  • 0040Investment banking
  • 0050Retail banking
  • 0060Asset management
  • 0070Corporate functions
  • 0080Independent internal control functions
  • 0090All other
Show the rule as writtenShow

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

sum({R_09.00,r0090,c0030,},{R_09.00,r0090,c0020,},{R_09.00,r0090,c0040,},{R_09.00,r0090,c0010,}) = sum({R_12.00.a,r0060,c0030,},{R_12.00.a,r0060,c0050,},{R_12.00.a,r0060,c0060,},{R_12.00.a,r0060,c0080,},{R_12.00.a,r0060,c0090,},{R_12.00.a,r0060,c0040,},{R_12.00.a,r0060,c0070,})

Every REM benchmarking rule, by template

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